As we demonstrate in our comments, children and teenagers experience widespread commercial surveillance practices to collect data used to target them with marketing. Targeted and personalized advertising remains the dominant business model for digital media, with the marketing and advertising industry identifying children and teens as a prime target. Minors are relentlessly pursued while, simultaneously, they are spending more time online than ever before. Children’s lives are filled with surveillance, involving the collection of vast amounts of personal data of online users. This surveillance, informed by behavior science and maximized by evolving technologies, allows platforms and marketers to profile and manipulate children.
The prevalence of surveillance advertising and targeted marketing aimed at minors is unfair in violation of Section 5. Specifically, data-driven marketing and targeted advertising causes substantial harm to children and teens by:
- violating their privacy;
- manipulating them into being interested in harmful products;
