FTC/DOJ v. Cerebral and its former CEO
The adDisclosed health data via tracking for ads. Misleading easy-cancel claims.
OutcomeMore than $7M and a ban on health data for most ads
LessonAudit tracking pixels. Make cancellation claims accurate.
Mental health apps ads are allowed with rules on Meta and restricted on Google. Ads must not assert or imply "physical or mental health" attributes. Disallowed example: "Do you have diabetes?" (the same logic applies to depression and anxiety). The phrases most likely to cause trouble include "Are you depressed?", "cure depression", "replace your therapist".
Allowed. The personal attributes rule and health data restrictions apply.
Sources: transparency.meta.com · transparency.meta.com · axios.com · cardinaldigitalmarketing.com
Allowed. Health is a sensitive personalized ads category. Addiction services need certification.
Sources: support.google.com · support.google.com · support.google.com
8 phrases that often lead to rejection, limited delivery or regulator action. High means the phrase or claim is named in a policy or ruling. Medium means it's our reading of a rule.
| Phrase | Why it's risky | Rule or source | Risk |
|---|---|---|---|
| Are you depressed? / Struggling with your anxiety? | Implies a mental-health personal attribute | Meta: Personal attributes transparency.meta.com | High |
| cure depression / cure anxiety / cure ADHD | Cure claim. Must not discourage essential treatment. | CAP12 12.2 · Google: Unreliable claims asa.org.uk · support.google.com | High |
| replace your therapist / no need for medication | Discourages essential treatment | CAP12 12.2 asa.org.uk | High |
| online diagnosis in 5 minutes | Diagnosis must be under a suitably qualified professional | CAP12 12.2 · 12.2.1 asa.org.uk | High |
| clinically proven app (without RCT) | Health apps are within the FTC guidance scope | FTC health products guidance ftc.gov | High |
| HIPAA-compliant / your data is never shared (if false) | Privacy misrepresentation | FTC BetterHelp 2023 · Cerebral 2024 | High |
| rehab / addiction treatment (uncertified) | Certification required | Google addiction policy | High |
| get Adderall/Xanax prescribed online | Rx drug promotion. Needs LegitScript and eligible countries. | Meta: Drugs and pharmaceuticals · Google: Healthcare and medicines transparency.meta.com · support.google.com | High |
Before and after examples. Swap the bracketed parts for your real details.
Are you depressed? Try our app
Support for everyday stress and low mood, with licensed therapists.
Cure your anxiety without meds
Evidence-informed tools to help manage anxious thoughts, alongside professional care.
Diagnosed in minutes online
Start with a confidential assessment by a licensed clinician.
Struggling with addiction? (uncertified)
Information and resources on recovery support. (Certification required for treatment ads)
Never need a therapist again
Therapy that fits your schedule.
Your data is 100% private
Read how we protect your information. (Link to accurate policy)
Google requires LegitScript certification for addiction treatment ads in the US.
Meta removes health detailed targeting.
FTC orders BetterHelp to pay $7.8M for sharing health data with Facebook and others for ads.
FTC proposes an order against Cerebral: ban on using health data for ads and more than $7M.
Meta's health and wellness data-sharing restrictions begin.
The adDisclosed health data via tracking for ads. Misleading easy-cancel claims.
OutcomeMore than $7M and a ban on health data for most ads
LessonAudit tracking pixels. Make cancellation claims accurate.
The adPromised privacy, then shared emails and intake data with Facebook for lookalike audiences
Outcome$7.8M refunds and a ban on sharing health data for ads
LessonNever build ad audiences from therapy intake data.
Main risks are the FTC Act and privacy enforcement (BetterHelp, Cerebral), plus the Meta and Google targeting limits.
CAP 12.2 requires diagnosis and treatment to be supervised by suitably qualified professionals.
No mental-health-specific ad rule was verified (see unverified list).
Covered by MOHAP and DHA health-advertising permits, which apply to healthcare services and professionals. Source: UAE_CMS, DHA_2026.
ASCI 2023: health influencers must hold relevant qualifications, psychology among them, and disclose them up front. Source: IN_ASCI_2023.
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This tool is a pre-launch screen, not legal advice. Meta and Google do not publish banned-word lists, so each flag is a risk signal tied to a published rule, regulator ruling or court case. Policies change often. Data last checked 5 October 2026.