UNITED STATES OF AMERICA

FEDERAL TRADE COMMISSION

WASHINGTON, D.C. 20580

Office of the Secretary

July 7, 2023

[Name of Commenter] 

Re: BetterHelp, Inc., File No. 2023169 

Dear [Name]: 

Thank you for your comment regarding the Federal Trade Commission’s (“FTC” or 

“Commission”) proposed consent agreement in the above-titled proceeding against BetterHelp, 

Inc. (“BetterHelp”). The Commission has placed your comment on the public record pursuant to 

rule 4.9(b)(6)(ii) of the Commission’s Rules of Practice, 16 C.F.R. § 4.9(b)(6)(ii). Your 

comment raises important issues, and we have given it serious consideration. 

The Commission’s primary law enforcement tool is Section 5 of the FTC Act, 15 U.S.C. 

§ 45, which prohibits unfair and deceptive acts or practices. The Commission also enforces

numerous other laws and evaluates the unique circumstances of each case to determine the

appropriate charges.

Here, the Commission alleges that BetterHelp committed several Section 5 violations. 

The Commission’s complaint alleges that BetterHelp repeatedly pushed people to hand over their

sensitive health information through unavoidable prompts and assured consumers that it would 

keep that information private. The complaint alleges that, despite those promises, BetterHelp

used and shared the health information of millions of consumers with platforms like Facebook, 

Snapchat, Criteo, and Pinterest for advertising purposes. The complaint also alleges that 

BetterHelp failed to maintain sufficient policies or procedures to protect the sensitive 

information it collected from consumers. 

BetterHelp’s actions strike at the core of a key Commission priority, namely its 

commitment to protect consumers’ privacy. When consumers entrust a company with their 

personal information, the company must protect the privacy and confidentiality of that 

information. This is even more so the case when the information is sensitive, such as health 

information. When a company then betrays consumers’ trust and shares that information without 

consumers’ knowledge or approval, the company must be held responsible. 

The proposed consent agreement both holds BetterHelp accountable for its actions and 

requires it to implement measures to protect consumers’ privacy in the future. Specifically, the 

proposed consent agreement bans BetterHelp from sharing consumers’ health information for 
advertising and from sharing consumers’ personal information for re-targeting. It also requires 

BetterHelp to pay $7.8 million to provide partial refunds to people who signed up for and paid 

for BetterHelp’s services between August 1, 2017, and December 31, 2020. For more 

information on how to obtain a refund, visit the FTC’s refund page, available at 

https://www.ftc.gov/enforcement/refunds. 

In addition, the proposed consent agreement requires that BetterHelp obtain consumers’ 

affirmative express consent before disclosing their personal information to certain third parties 

for any permitted purpose. And it requires BetterHelp to implement a comprehensive privacy 

program that includes strong safeguards to protect consumers’ privacy and is subject to outside 

assessments by an independent third party. For example, under the privacy program, BetterHelp 

must conduct mandatory annual privacy training of all employees, delete consumers’ personal 

information that is no longer reasonably necessary, and institute testing of each mechanism by 

which BetterHelp discloses consumers’ personal information to third parties. Additionally, the 

proposed consent agreement prohibits BetterHelp from misrepresenting how BetterHelp collects, 

uses, and discloses consumers’ personal information and misrepresenting to consumers that a 

government agency or other third party certified BetterHelp’s compliance with the Health 

Insurance Portability and Accountability Act of 1996 (“HIPAA”). Although the Commission 

does not enforce HIPAA, this complaint and others previously brought by the Commission 

demonstrate that the Commission will hold entities accountable for false HIPAA certification 

claims. The proposed consent agreement also requires BetterHelp to tell consumers who signed 

up for an account before January 1, 2021—people affected by the practices alleged in the 

complaint—about the FTC’s action against BetterHelp.

We appreciate your support of the proposed consent agreement. The Commission 

believes the relief in the proposed consent agreement will hold BetterHelp accountable and 

protect the privacy of consumers who use BetterHelp’s products and services. If BetterHelp 

violates the Commission’s final order, the Commission may seek civil monetary penalties of 

over $50,000 per violation pursuant to Section 5(l) of the FTC Act, 15 U.S.C. § 45(l). The FTC 

is committed to the enforcement of its orders, including the order in this proceeding. If, in the 

future, you have specific information suggesting that BetterHelp is not maintaining reasonable 

privacy or security of user information, please contact the FTC at (877) 382-4357, or file a report 

online at https://reportfraud.ftc.gov. 

 The Commission has determined that the public interest would best be served by issuing 

the complaint and Decision and Order in the above-titled proceeding in final form without any 

modifications. The final Decision and Order and other relevant materials are available from the 

Commission’s website at http://www.ftc.gov. It helps the Commission’s analysis to hear from a 

variety of sources in its work, and it thanks you again for your comment.

By direction of the Commission. 

April J. Tabor 

Secretary

2
UNITED STATES OF AMERICA

FEDERAL TRADE COMMISSION

WASHINGTON, D.C. 20580

Office of the Secretary

July 7, 2023

Linda L. Michaels, PsyD MBA, Chair 

Pratyusha Tummala-Narra, PhD, Vice Chair

Janice Muhr, PhD, Treasurer 

Psychotherapy Action Network 

645 N. Michigan Ave, Suite 803 

Chicago, IL 60611 

Re: BetterHelp, Inc., File No. 2023169 

Dear Dr. Michaels, Dr. Tummala-Narra, and Dr. Muhr: 

Thank you for your comment regarding the Federal Trade Commission’s (“FTC” or 

“Commission”) proposed consent agreement in the above-titled proceeding against BetterHelp, 

Inc. (“BetterHelp”). The Commission has placed your comment on the public record pursuant to 

rule 4.9(b)(6)(ii) of the Commission’s Rules of Practice, 16 C.F.R. § 4.9(b)(6)(ii). Your 

comment raises important issues, and we have given it serious consideration. 

The Commission’s primary law enforcement tool is Section 5 of the FTC Act, 15 U.S.C. 

§ 45, which prohibits unfair and deceptive acts or practices. The Commission also enforces

numerous other laws and evaluates the unique circumstances of each case to determine the

appropriate charges.

Here, the Commission alleges that BetterHelp committed several Section 5 violations. 

The Commission’s complaint alleges that BetterHelp repeatedly pushed people to hand over their

sensitive health information through unavoidable prompts and assured consumers that it would 

keep that information private. The complaint alleges that, despite those promises, BetterHelp

used and shared the health information of millions of consumers with platforms like Facebook, 

Snapchat, Criteo, and Pinterest for advertising purposes. The complaint also alleges that 

BetterHelp failed to maintain sufficient policies or procedures to protect the sensitive 

information it collected from consumers.

BetterHelp’s actions strike at the core of a key Commission priority, namely its 

commitment to protect consumers’ privacy. When consumers entrust a company with their 

personal information, the company must protect the privacy and confidentiality of that 

information. This is even more so the case when the information is sensitive, such as health 
information. When a company then betrays consumers’ trust and shares that information without 

consumers’ knowledge or approval, the company must be held responsible. 

The proposed consent agreement both holds BetterHelp accountable for its actions and 

requires it to implement measures to protect consumers’ privacy in the future. Specifically, the 

proposed consent agreement bans BetterHelp from sharing consumers’ health information for 

advertising and from sharing consumers’ personal information for re-targeting. It also requires 

BetterHelp to pay $7.8 million to provide partial refunds to people who signed up for and paid 

for BetterHelp’s services between August 1, 2017, and December 31, 2020.1

 

In addition, the proposed consent agreement requires that BetterHelp obtain consumers’ 

affirmative express consent before disclosing their personal information to certain third parties 

for any permitted purpose. And it requires BetterHelp to implement a comprehensive privacy 

program that includes strong safeguards to protect consumers’ privacy and is subject to outside 

assessments by an independent third party. For example, under the privacy program, BetterHelp 

must conduct mandatory annual privacy training of all employees, delete consumers’ personal 

information that is no longer reasonably necessary, and institute testing of each mechanism by 

which BetterHelp discloses consumers’ personal information to third parties. Additionally, the 

proposed consent agreement prohibits BetterHelp from misrepresenting how BetterHelp collects, 

uses, and discloses consumers’ personal information and misrepresenting to consumers that a 

government agency or other third party certified BetterHelp’s compliance with the Health 

Insurance Portability and Accountability Act of 1996 (“HIPAA”). Although the Commission 

does not enforce HIPAA, this complaint and others previously brought by the Commission 

demonstrate that the Commission will hold entities accountable for false HIPAA certification 

claims. The proposed consent agreement also requires BetterHelp to tell consumers who signed 

up for an account before January 1, 2021—people affected by the practices alleged in the 

complaint—about the FTC’s action against BetterHelp.

The Commission believes the relief in the proposed consent agreement will hold 

BetterHelp accountable and protect the privacy of consumers who use BetterHelp’s products and 

services. If BetterHelp violates the Commission’s final order, the Commission may seek civil 

monetary penalties of over $50,000 per violation pursuant to Section 5(l) of the FTC Act, 15 

U.S.C. § 45(l). The FTC is committed to the enforcement of its orders, including the order in 

this proceeding. If, in the future, you have specific information suggesting that BetterHelp is not 

maintaining reasonable privacy or security of user information, please contact the Consumer 

Response Center at (877) 382-4357, or file a report online at https://reportfraud.ftc.gov. 

PsiAN’s comment supports the proposed consent agreement, highlighting the importance 

of the proposed order’s restrictions on BetterHelp’s ability to disclose consumers’ personal 

information to third parties in the future, as well as the proposed order’s requirement for 

affirmative express consent before other disclosures of consumers’ personal information. We 

appreciate PsiAN’s support of the proposed consent agreement and the Commission will 

1 For more information on how to obtain a refund, visit the FTC’s refund page, available at 

https://www.ftc.gov/enforcement/refunds. 

2
continue to use its unfairness and deception authority when appropriate to protect consumers’ 

privacy. 

Your comment also states that BetterHelp should be required moving forward to make 

public any marketing, advertising, or customer-acquisition strategies. As noted above, the 

proposed consent agreement in this matter specifically prohibits BetterHelp from making 

misrepresentations about the privacy of consumer information, including in connection with 

promoting its products and services. 

The Commission has determined that the public interest would best be served by issuing 

the complaint and Decision and Order in the above-titled proceeding in final form without any 

modifications. The final Decision and Order and other relevant materials are available from the 

Commission’s website at http://www.ftc.gov. It helps the Commission’s analysis to hear from a 

variety of sources in its work, and it thanks you again for your comment. 

By direction of the Commission. 

April J. Tabor 

Secretary

3
UNITED STATES OF AMERICA

FEDERAL TRADE COMMISSION

WASHINGTON, D.C. 20580

Office of the Secretary

July 7, 2023

John Davisson, Director of Litigation & Senior Counsel 

Suzanne Bernstein, Law Fellow

Electronic Privacy Information Center 

1519 New Hampshire Ave. NW 

Washington, DC 20036 

Re: BetterHelp, Inc., File No. 2023169 

Dear Mr. Davisson and Ms. Bernstein: 

Thank you for your comment regarding the Federal Trade Commission’s (“FTC” or 

“Commission”) proposed consent agreement in the above-titled proceeding against BetterHelp, 

Inc. (“BetterHelp”). The Commission has placed your comment on the public record pursuant to 

rule 4.9(b)(6)(ii) of the Commission’s Rules of Practice, 16 C.F.R. § 4.9(b)(6)(ii). Your 

comment raises important issues, and we have given it serious consideration. 

The Commission’s primary law enforcement tool is Section 5 of the FTC Act, 15 U.S.C. 

§ 45, which prohibits unfair and deceptive acts or practices. The Commission also enforces

numerous other laws and evaluates the unique circumstances of each case to determine the

appropriate charges.

Here, the Commission alleges that BetterHelp committed several Section 5 violations. 

The Commission’s complaint alleges that BetterHelp repeatedly pushed people to hand over their

sensitive health information through unavoidable prompts and assured consumers that it would

keep that information private. The complaint alleges that, despite those promises, BetterHelp

used and shared the health information of millions of consumers with platforms like Facebook, 

Snapchat, Criteo, and Pinterest for advertising purposes. The complaint also alleges that 

BetterHelp failed to maintain sufficient policies or procedures to protect the sensitive 

information it collected from consumers.

BetterHelp’s actions strike at the core of a key Commission priority, namely its 

commitment to protect consumers’ privacy. When consumers entrust a company with their 

personal information, the company must protect the privacy and confidentiality of that 

information. This is even more so the case when the information is sensitive, such as health 

information. When a company then betrays consumers’ trust and shares that information without 

consumers’ knowledge or approval, the company must be held responsible. 
The proposed consent agreement both holds BetterHelp accountable for its actions and 

requires it to implement measures to protect consumers’ privacy in the future. Specifically, the 

proposed consent agreement bans BetterHelp from sharing consumers’ health information for 

advertising and from sharing consumers’ personal information for re-targeting. It also requires 

BetterHelp to pay $7.8 million to provide partial refunds to people who signed up for and paid 

for BetterHelp’s services between August 1, 2017, and December 31, 2020.1

 

In addition, the proposed consent agreement requires that BetterHelp obtain consumers’ 

affirmative express consent before disclosing their personal information to certain third parties 

for any permitted purpose. And it requires BetterHelp to implement a comprehensive privacy 

program that includes strong safeguards to protect consumers’ privacy and is subject to outside 

assessments by an independent third party. For example, under the privacy program, BetterHelp 

must conduct mandatory annual privacy training of all employees, delete consumers’ personal 

information that is no longer reasonably necessary, and institute testing of each mechanism by 

which BetterHelp discloses consumers’ personal information to third parties. Additionally, the 

proposed consent agreement prohibits BetterHelp from misrepresenting how BetterHelp collects, 

uses, and discloses consumers’ personal information and misrepresenting to consumers that a 

government agency or other third party certified BetterHelp’s compliance with the Health 

Insurance Portability and Accountability Act of 1996 (“HIPAA”). Although the Commission 

does not enforce HIPAA, this complaint and others previously brought by the Commission 

demonstrate that the Commission will hold entities accountable for false HIPAA certification 

claims. The proposed consent agreement also requires BetterHelp to tell consumers who signed 

up for an account before January 1, 2021—people affected by the practices alleged in the 

complaint—about the FTC’s action against BetterHelp. 

The Commission believes the relief in the proposed consent agreement will hold 

BetterHelp accountable and protect the privacy of consumers who use BetterHelp’s products and 

services. If BetterHelp violates the Commission’s final order, the Commission may seek civil 

monetary penalties of over $50,000 per violation pursuant to Section 5(l) of the FTC Act. The 

FTC is committed to the enforcement of its orders, including the order in this proceeding. If, in 

the future, you have specific information suggesting that BetterHelp is not maintaining 

reasonable privacy or security of user information, please contact the FTC at (877) 382-4357, or 

file a report online at https://reportfraud.ftc.gov. 

EPIC’s comment supports the proposed consent agreement, highlighting the importance 

of the proposed order’s restrictions on BetterHelp’s ability to disclose consumers’ personal 

information to third parties in the future, as well as the proposed order’s explicit prohibitions 

against future misrepresentations. We appreciate EPIC’s support of the proposed consent 

agreement and the Commission will continue to use its unfairness and deception authority when 

appropriate to protect consumers’ privacy. 

1 For more information on how to obtain a refund, visit the FTC’s refund page, available at 

https://www.ftc.gov/enforcement/refunds. 

2
 The Commission has determined that the public interest would best be served by issuing 

the complaint and Decision and Order in the above-titled proceeding in final form without any 

modifications. The final Decision and Order and other relevant materials are available from the 

Commission’s website at http://www.ftc.gov. It helps the Commission’s analysis to hear from a 

variety of sources in its work, and it thanks you again for your comment. 

By direction of the Commission. 

April J. Tabor 

Secretary

3
UNITED STATES OF AMERICA

FEDERAL TRADE COMMISSION

WASHINGTON, D.C. 20580

Office of the Secretary

July 7, 2023

Joy Alafia, Executive Director 

Bradly J. Muldrow, Staff Attorney 

California Association of Marriage and Family Therapists 

7901 Raytheon Road 

San Diego, CA 92111-1606 

Re: BetterHelp, Inc., File No. 2023169 

Dear Ms. Alafia and Mr. Muldrow: 

Thank you for your comment regarding the Federal Trade Commission’s (“FTC” or 

“Commission”) proposed consent agreement in the above-titled proceeding against BetterHelp, 

Inc. (“BetterHelp”). The Commission has placed your comment on the public record pursuant to 

rule 4.9(b)(6)(ii) of the Commission’s Rules of Practice, 16 C.F.R. § 4.9(b)(6)(ii). Your 

comment raises important issues, and we have given it serious consideration. 

The Commission’s primary law enforcement tool is Section 5 of the FTC Act, 15 U.S.C. 

§ 45, which prohibits unfair and deceptive acts or practices. The Commission also enforces

numerous other laws and evaluates the unique circumstances of each case to determine the

appropriate charges.

Here, the Commission alleges that BetterHelp committed several Section 5 violations. 

The Commission’s complaint alleges that BetterHelp repeatedly pushed people to hand over their

sensitive health information through unavoidable prompts and assured consumers that it would 

keep that information private. The complaint alleges that, despite those promises, BetterHelp

used and shared the health information of millions of consumers with platforms like Facebook, 

Snapchat, Criteo, and Pinterest for advertising purposes. The complaint also alleges that 

BetterHelp failed to maintain sufficient policies or procedures to protect the sensitive 

information it collected from consumers.

BetterHelp’s actions strike at the core of a key Commission priority, namely its 

commitment to protect consumers’ privacy. When consumers entrust a company with their 

personal information, the company must protect the privacy and confidentiality of that 

information. This is even more so the case when the information is sensitive, such as health 

information. When a company then betrays consumers’ trust and shares that information without 

consumers’ knowledge or approval, the company must be held responsible. 
The proposed consent agreement both holds BetterHelp accountable for its actions and 

requires it to implement measures to protect consumers’ privacy in the future. Specifically, the 

proposed consent agreement bans BetterHelp from sharing consumers’ health information for 

advertising and from sharing consumers’ personal information for re-targeting. It also requires 

BetterHelp to pay $7.8 million to provide partial refunds to people who signed up for and paid 

for BetterHelp’s services between August 1, 2017, and December 31, 2020.1

 

In addition, the proposed consent agreement requires that BetterHelp obtain consumers’ 

affirmative express consent before disclosing their personal information to certain third parties 

for any permitted purpose. And it requires BetterHelp to implement a comprehensive privacy 

program that includes strong safeguards to protect consumers’ privacy and is subject to outside 

assessments by an independent third party. For example, under the privacy program, BetterHelp 

must conduct mandatory annual privacy training of all employees, delete consumers’ personal 

information that is no longer reasonably necessary, and institute testing of each mechanism by 

which BetterHelp discloses consumers’ personal information to third parties. Additionally, the 

proposed consent agreement prohibits BetterHelp from misrepresenting how BetterHelp collects, 

uses, and discloses consumers’ personal information and misrepresenting to consumers that a 

government agency or other third party certified BetterHelp’s compliance with the Health 

Insurance Portability and Accountability Act of 1996 (“HIPAA”). Although the Commission 

does not enforce HIPAA, this complaint and others previously brought by the Commission 

demonstrate that the Commission will hold entities accountable for false HIPAA certification 

claims. The proposed consent agreement also requires BetterHelp to tell consumers who signed 

up for an account before January 1, 2021—people affected by the practices alleged in the 

complaint—about the FTC’s action against BetterHelp.

The Commission believes the relief in the proposed consent agreement will hold 

BetterHelp accountable and protect the privacy of consumers who use BetterHelp’s products and 

services. If BetterHelp violates the Commission’s final order, the Commission may seek civil 

monetary penalties of over $50,000 per violation pursuant to Section 5(l) of the FTC Act, 15 

U.S.C. § 45(l). The FTC is committed to the enforcement of its orders, including the order in 

this proceeding. If, in the future, you have specific information suggesting that BetterHelp is not 

maintaining reasonable privacy or security of user information, please contact the FTC at (877) 

382-4357, or file a report online at https://reportfraud.ftc.gov.

 Your comment supports the proposed consent agreement, highlighting the importance of 

the proposed order’s restrictions on BetterHelp’s ability to disclose consumers’ personal 

information to third parties, as well as its requirement that BetterHelp implement a 

comprehensive privacy program. We appreciate CAMFT’s support of the proposed consent 

agreement and the Commission will continue to use its unfairness and deception authority when 

appropriate to protect consumers’ privacy. 

1 For more information on how to obtain a refund, visit the FTC’s refund page, available at 

https://www.ftc.gov/enforcement/refunds. 

2
 The Commission has determined that the public interest would best be served by issuing 

the complaint and Decision and Order in the above-titled proceeding in final form without any 

modifications. The final Decision and Order and other relevant materials are available from the 

Commission’s website at http://www.ftc.gov. It helps the Commission’s analysis to hear from a 

variety of sources in its work, and it thanks you again for your comment. 

By direction of the Commission. 

April J. Tabor 

Secretary

3
UNITED STATES OF AMERICA

FEDERAL TRADE COMMISSION

WASHINGTON, D.C. 20580

Office of the Secretary

Nicole Sugerman, Kairos Campaign Manager 

Kairos Fellowship

nicole@kairosfellows.org 

Re: BetterHelp, Inc., File No. 2023169 

Dear Ms. Sugerman: 

Thank you for your comment regarding the Federal Trade Commission’s (“FTC” or 

“Commission”) proposed consent agreement in the above-titled proceeding against BetterHelp, 

Inc. (“BetterHelp”). The Commission has placed your comment on the public record pursuant to 

rule 4.9(b)(6)(ii) of the Commission’s Rules of Practice, 16 C.F.R. § 4.9(b)(6)(ii). Your 

comment raises important issues, and we have given it serious consideration. 

The Commission’s primary law enforcement tool is Section 5 of the FTC Act, 15 U.S.C. 

§ 45, which prohibits unfair and deceptive acts or practices. The Commission also enforces

numerous other laws and evaluates the unique circumstances of each case to determine the

appropriate charges.

Here, the Commission alleges that BetterHelp committed several Section 5 violations. 

The Commission’s complaint alleges that BetterHelp repeatedly pushed people to hand over their

sensitive health information through unavoidable prompts and assured consumers that it would 

keep that information private. The complaint alleges that, despite those promises, BetterHelp

used and shared the health information of millions of consumers with platforms like Facebook, 

Snapchat, Criteo, and Pinterest for advertising purposes. The complaint also alleges that 

BetterHelp failed to maintain sufficient policies or procedures to protect the sensitive

information it collected from consumers.

BetterHelp’s actions strike at the core of a key Commission priority, namely its

commitment to protect consumers’ privacy. When consumers entrust a company with their

personal information, the company must protect the privacy and confidentiality of that 

information. This is even more so the case when the information is sensitive, such as health 

information. When a company then betrays consumers’ trust and shares that information without 

consumers’ knowledge or approval, the company must be held responsible. 

July 7, 2023
The proposed consent agreement both holds BetterHelp accountable for its actions and 

requires it to implement measures to protect consumers’ privacy in the future. Specifically, the 

proposed consent agreement bans BetterHelp from sharing consumers’ health information for 

advertising and from sharing consumers’ personal information for re-targeting. It also requires 

BetterHelp to pay $7.8 million to provide partial refunds to people who signed up for and paid 

for BetterHelp’s services between August 1, 2017, and December 31, 2020.1 

In addition, the proposed consent agreement requires that BetterHelp obtain consumers’ 

affirmative express consent before disclosing their personal information to certain third parties 

for any permitted purpose. And it requires BetterHelp to implement a comprehensive privacy 

program that includes strong safeguards to protect consumers’ privacy and is subject to outside 

assessments by an independent third party. For example, under the privacy program, BetterHelp 

must conduct mandatory annual privacy training of all employees, delete consumers’ personal 

information that is no longer reasonably necessary, and institute testing of each mechanism by 

which BetterHelp discloses consumers’ personal information to third parties. Additionally, the 

proposed consent agreement prohibits BetterHelp from misrepresenting how BetterHelp collects, 

uses, and discloses consumers’ personal information and misrepresenting to consumers that a 

government agency or other third party certified BetterHelp’s compliance with the Health 

Insurance Portability and Accountability Act of 1996 (“HIPAA”). Although the Commission 

does not enforce HIPAA, this complaint and others previously brought by the Commission 

demonstrate that the Commission will hold entities accountable for false HIPAA certification 

claims. The proposed consent agreement also requires BetterHelp to tell consumers who signed 

up for an account before January 1, 2021—people affected by the practices alleged in the 

complaint—about the FTC’s action against BetterHelp.

The Commission believes the relief in the proposed consent agreement will hold 

BetterHelp accountable and protect the privacy of consumers who use BetterHelp’s products and 

services. If BetterHelp violates the Commission’s final order, the Commission may seek civil 

monetary penalties of over $50,000 per violation pursuant to Section 5(l) of the FTC Act, 15 

U.S.C. § 45(l). The FTC is committed to the enforcement of its orders, including the order in 

this proceeding. If, in the future, you have specific information suggesting that BetterHelp is not 

maintaining reasonable privacy or security of user information, please contact the FTC at (877) 

382-4357, or file a report online at https://reportfraud.ftc.gov.

 Your comment supports the proposed consent agreement, highlighting the importance of 

the proposed order’s restrictions on BetterHelp’s ability to disclose consumers’ personal 

information to third parties, as well as the partial refunds that will be paid to certain of 

BetterHelp’s users. We appreciate Kairos Fellowship’s support of the proposed consent 

agreement and the Commission will continue to use its unfairness and deception authority when 

appropriate to protect consumers’ privacy. 

 The Commission has determined that the public interest would best be served by issuing 

the complaint and Decision and Order in the above-titled proceeding in final form without any 

1 For more information on how to obtain a refund, visit the FTC’s refund page, available at 

https://www.ftc.gov/enforcement/refunds. 

2
modifications. The final Decision and Order and other relevant materials are available from the 

Commission’s website at http://www.ftc.gov. It helps the Commission’s analysis to hear from a 

variety of sources in its work, and it thanks you again for your comment. 

By direction of the Commission. 

April J. Tabor 

Secretary

3