BMO, a Canadian bank, was searching for Canadian adults to apply for credit cards this year. So the bank’s advertising agency launched a YouTube campaign utilizing Google’s ad-targeting system, which leverages artificial intelligence to identify perfect customers.

However, Google, which owns YouTube, presented the ad to a viewer in the United States on a Barbie-themed children’s video on the “Kids Diana Show,” a YouTube channel for preschoolers with over 94 billion views.

According to new analysis from Adalytics, which analyzes ad campaigns for marketers, when that viewer clicked on the ad, it led to BMO’s website, which tagged the user’s browser with tracking software from Google, Meta, Microsoft, and other companies.

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The BMO commercial aired during a segment of the popular Kids Diana Show. According to a new analysis, clicking on the ad directed viewers to a BMO page that tagged their browser with trackers.Credit goes to…YouTube.

As a result, big tech firms may have tracked youngsters around the internet, raising worries about whether they were violating a federal privacy law, according to the paper. The Children’s internet Privacy Protection Act, or COPPA, mandates internet services for children to acquire parental permission before collecting personal data from users under the age of 13 for reasons such as ad targeting.

The findings of the investigation raise additional questions regarding YouTube’s advertising on children’s material. YouTube and Google agreed to pay a record $170 million fine in 2019 to settle allegations from the Federal Trade Commission and the State of New York that the corporation illegally acquired personal information from children watching kids’ channels. According to regulators, the corporation profited from utilizing children’s data to target them with advertisements.

YouTube then announced that it would limit data collecting from viewers and stop providing tailored advertising on children’s content.

On Thursday, two United States senators urged the F.T.C. to examine whether Google and YouTube violated COPPA, citing Adalytics and New York Times reporting. Senators Edward J. Markey (D-MA) and Marsha Blackburn (R-TN) expressed concern that the company may have tracked children and served them targeted ads without parental consent, facilitating “the vast collection and distribution” of children’s data.

“This behavior by YouTube and Google is estimated to have impacted hundreds of thousands, to potentially millions, of children across the United States,” the senators wrote.

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Adalytics found over 300 brand advertising for adult products such as vehicles on nearly 100 YouTube videos labeled “made for kids” that were seen to a user who was not signed in and linked to advertisers’ websites. It also discovered other YouTube commercials containing violent content on children’s channels, including explosions, sniper weapons, and vehicle accidents.

When a viewer who was not signed into YouTube clicked ads on some of the site’s children’s channels, they were taken to brand websites that placed trackers — bits of code used for purposes such as security, ad tracking, or user profiling — from Amazon, Meta’s Facebook, Google, Microsoft, and others on users’ browsers.

Ads for adult consumer products such as vehicles or credit cards are permitted and regular on children’s films, just as they are on children’s television. There is no evidence that Google or YouTube breached their 2019 FTC agreement.

Prior to publication, The Times shared some of Adalytics’ information with Google. A Google representative, Michael Aciman, called the report’s findings “deeply flawed and misleading.” Google has also disputed a prior Adalytics analysis on the company’s advertising methods, which was first reported by The Wall Street Journal.

Google told The Times that running adverts for adults on children’s films was beneficial since parents who watched could become customers. It also stated that placing violent advertising on children’s videos was against company policy, and that YouTube has “changed the classification” of the violent ads identified by Adalytics in order to prevent them from running on children’s content “moving forward.”

Google stated that it did not run tailored advertisements on children’s films and that its advertising operations were entirely compliant with COPPA. According to the firm, when advertising show on children’s videos, they are based on webpage content rather than user profiles. Google stated that it does not notify advertisers or monitoring services whether a viewer arriving from YouTube had seen a children’s film – only that the visitor had arrived from YouTube and clicked on the ad.

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The business went on to say that it couldn’t regulate data harvesting on a brand’s website once a YouTube viewer clicked on an ad. According to Google, such data collection might occur when a user clicks on an ad on any website.

Despite this, ad industry veterans claimed it was impossible to keep their clients’ YouTube advertising from showing on children’s films, according to a recent Times interview with ten top workers at ad agency and related companies. They also claimed that YouTube’s ad placement put famous consumer companies at risk of violating children’s privacy.

“I’m incredibly concerned about it,” said Arielle Garcia, chief privacy officer at UM Worldwide, the marketing agency behind the BMO campaign.

A woman dressed in a sport coat and black shirt poses for a photograph next to a cement wall.
Arielle Garcia, UM Worldwide’s chief privacy officer, expressed concern that children’s data could be improperly gathered and used.Credit…The New York Times’ Sarah Blesener

Ms. Garcia stated that she was speaking generally and could not comment on the BMO ad directly. “It shouldn’t be this difficult to ensure that children’s data isn’t being collected and used inappropriately,” she said.

Google stated that it has provided advertisers with a one-click option to remove their advertising from appearing on YouTube videos aimed at youngsters.

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The BMO campaign targeted the ads with Performance Max, a specialist Google A.I. tool that does not notify firms whose videos their ads appeared on. Google stated that the adverts did not initially exclude children’s movies and that it recently assisted the campaign in updating its settings.

An advertisement for a separate BMO credit card appeared in August on a video on the Moolt Kids Toons Happy Bear channel, which has over 600 million views on its cartoon videos. According to Google, the second ad campaign did not appear to exclude children’s movies.

BMO spokesman Jeff Roman stated, “BMO does not seek to or knowingly target minors with its online advertising and takes steps to prevent its ads from being served to minors.”

Several industry professionals noticed issues with more traditional Google advertising offerings. They revealed how they had received reports of their advertising appearing on children’s videos, created lengthy lists to exclude such movies, only to have their adverts appear on other children’s videos later.

“It’s a constant game of Whac-a-Mole,” said Lou Paskalis, a former Bank of America global media executive who now heads a marketing consultancy firm.

According to Adalytics, Google has also placed permanent cookies — files that can track which advertising a user clicks on and which websites they visit — on YouTube children’s movies.

The Times discovered persistent Google cookies, including an advertising cookie called IDE, on children’s films. When a viewer clicked on an ad, the same cookie was displayed on the ad page they were directed to.

Google stated that it only uses such cookies on children’s movies for commercial objectives approved by COPPA, such as fraud prevention or counting the number of times a viewer views an ad. According to Google, the cookie contents “were encrypted and were not readable by third parties.”

“Under COPPA, the presence of cookies is permissible for internal operations, including fraud detection,” said Paul Lekas, head of global public policy at the SIIA, a software industry group that includes Google and BMO, “so long as cookies and other persistent identifiers are not used to contact an individual, amass a profile, or engage in behavioral advertising.”

The New York Times discovered a Kohl’s clothes advertisement that aired on “Wheels on the Bus,” a nursery rhyme film that has been viewed 2.4 billion times. When a visitor clicked on the ad, they were directed to a Kohl’s web page that had over 300 tracking requests from over 80 third-party services. These included Meta’s cross-site tracking code, which could allow it to track viewers of children’s videos throughout the web.

Several requests for comment were not returned by Kohl’s.

“Our commitment to privacy shapes the way we build all of our products and services,” a Microsoft spokesman said. We’re gathering more information so that we can perform any additional investigations that are necessary.” Amazon stated that advertisers are not permitted to obtain children’s data using its technologies. Meta did not respond.

youngsters’s privacy experts expressed alarm that Google’s interlocking ecosystem — which includes the most popular internet browser, video platform, and largest digital ad business — had permitted the online tracking of youngsters by tech titans, advertisers, and data brokers.

“They have created a conveyor belt that is scooping up the data of children,” said Jeff Chester, executive director of the Center for Digital Democracy, an organization dedicated to digital privacy.


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