According to the complaint, the company contradicted its privacy promises. From 2020-2022, the company allegedly disclosed users’ personal information, including their health information, to numerous third-party advertising platforms via tracking technologies, known as pixels and application programming interfaces (APIs), which Monument integrated into its website. Monument used the information to target ads for its services to both current users who subscribe to the lowest cost memberships and to target new consumers, according to the complaint.

Monument used these pixels and APIs to track “standard” and “custom events,” meaning instances in which consumers interacted with Monument’s website. The FTC says that Monument gave the custom events descriptive titles that revealed details about its users such as “Paid: Weekly Therapy” or “Paid: Med Management,” when a user signed up for a service. Monument disclosed this custom events information to advertising platforms along with users’ email addresses, IP addresses, and other identifiers, which enabled third parties to identify the users and associate the custom events with specific individuals, according to the complaint.