Marketing to Children Through Online Targeted Advertising: Targeting Mechanisms and Legal Aspects

Many researchers and organizations, such as WHO and UNICEF, have raised awareness of the dangers of advertisements targeted at children. While most existing laws only regulate ads on television that may reach children, lawmakers have been working on extending regulations to online advertising and, for example, forbid (e.g., the DSA) or restrict (e.g., the COPPA) advertising based on profiling to children. At first sight, ad platforms such as Google seem to protect children by not allowing advertisers to target their ads to users that are less than 18 years old. However, this paper shows that other targeting features can be exploited to reach children. For example, on YouTube, advertisers can target their ads to users watching a particular video through placement-based targeting, a form of contextual targeting. Hence, advertisers can target children by simply placing their ads in children-focused videos. Through a series of ad experiments, we show that placement-based targeting is possible on children-focused videos and, hence, enables marketing to children. In addition, our ad experiments show that advertisers can use targeting based on profiling (e.g., interest, location, behavior) in combination with placement-based advertising on children-focused videos. We discuss the lawfulness of these two practices with respect to DSA and COPPA. Finally, we investigate to which extent real-world advertisers are employing placement-based targeting to reach children with ads on YouTube. We propose a measurement methodology consisting of building a Chrome extension able to capture ads and instrumenting six browser profiles to watch children-focused videos. Our results show that 7% of ads that appear in the children-focused videos we test use placement-based targeting. Hence, targeting children with ads on YouTube is not only hypothetically possible but also occurs in practice. We believe that the current legal and technical solutions are not enough to protect children from harm due to online advertising. A straightforward solution would be to forbid placement-based advertising on children-focused content.