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Kids and teens cannot appreciate the depth and breadth of these data collection systems, nor
<br /> the way they are used to target them with precision. Younger children largely think about
<br /> privacy in interpersonal terms, such as the ability to be left alone and control access to physical
<br /> places.99 As children get older, they may start to think about privacy in terms of freedom from
<br /> surveillance at school or by the government, but they do not think about privacy in the sense
<br /> that companies might use information about them to influence their purchasing choices, for
<br /> example.100
<br /> Ultimately, surveillance ads are inherently unfair when targeted to children. As Fairplay, Global
<br /> Action Plan, and Reset Australia described in a report about Facebook:
<br /> On the one side is a child, poorly equipped to distinguish between advertising
<br /> and information, especially within digital contexts. On the other, Facebook with
<br /> its vast troves of data about the child, including but not limited to their browsing
<br /> history, mood, insecurities, their peers' interests, and more. This power
<br /> imbalance makes surveillance advertising inherently more manipulative than
<br /> contextual digital advertising, let alone traditional analogue advertising.101
<br /> As with algorithmically recommended content, surveillance ads can be used to target and
<br /> exacerbate young people's vulnerabilities. Leaked documents from Facebook revealed in 2017
<br /> that the company told advertisers it could help them target teens at moments when they are
<br /> feeling specific emotions, such as "silly," "defeated," "overwhelmed," "useless" and "a
<br /> failure."101 Facebook Australia told advertisers it could specify when teens are likely to
<br /> experience certain moods, sharing that "earlier in the week, teens post more about
<br /> 'anticipatory emotions' and 'building confidence,' while weekend teen posts contain more
<br /> 'reflective emotions' and 'achievement broadcasting."'103
<br /> This capability allows marketers to target vulnerable young people with ads for harmful
<br /> products. Ads for risky "Flat Tummy Teas" and dangerous exercise routines target young
<br /> women on Instagram. Early digital marketing campaigns for Juul vaping products were
<br /> deliberately targeted at young audiences.104 Researchers were able to target ads to teenagers
<br /> 91 Kaiwen Sun et al., They See You're a Girl if You Pick a Pink Robot with a Skirt:A Qualitative Study of How Children
<br /> Conceptualize Data Processing and Digital Privacy Risks,CHI Conference on Human Factors in Computing Systems
<br /> Ma 2021 12. p�.//dlalp.ryr /roc/coi7�/cl7u/Su.si7SASGRS2J• Priya Kumar et al. No Telling Passcodes Out Because
<br /> Y :...:.
<br /> They're Private: Understanding Children's Mental Models of Privacy and Security Online, 1 Proceedings of the ACM
<br /> on Human-Computer Interaction 64 Nov.2017 !2. ttps. ��:arl.u.ui d.�:du.0 w coi���:i�� u.0 Toads ar
<br /> tI0'.8 C;SG;VOd GJiiliiie =ir,at...la .
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<br /> "I Mariya Stoilova et al.,Digital by Default:Children's Capacity to Understand and Manage Online Data and
<br /> Privacy,8 Media and Commc'n 197,200, (2020), .:I:..p.:. /.d. .:.�.p..i,.p.C:L/. . ..:.. ..f. q::`../..is!.�!.a...v8i.q:.:.yq:07.
<br /> ...Yi-ching Ho, E., Farthing, R., How Facebook still targets surveillance ads to teens, Reset Australia, Fairplay,and
<br /> Global Action Plan (Nov.2021), 17„G;G,ps.//fairplayforl<iids.orR/wp� cou7G i7G/u.sp,.r,.d..s./. :.CY.:. ./..../:flos,u.s.r:v.eu.1..1,ancer,e,ggEL 2df.
<br /> 112 Sam Machkovech, Report:Facebook Helped Advertisers Target Teens Who Feel "Worthless",ArsTechnica (May
<br /> 1,2017),.17„G;tpas.//arstechi7ica.corn/llyforrriaGioi7-Gec17iio1opy,/, :CY, ..//.CY,.`-../: ,c. „I r.r..l<.::.!7.. .�..p dadv
<br /> w ho-feel-wou G171 ss/.
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<br /> 103 Id
<br /> 104 Jidong Huang et al., Vaping versus JUULing:how the extraordinary growth and marketing of JUUL transformed
<br /> the US retail e-cigarette market, 28 Tobacco Control 146, 150(Feb.22,2019),
<br /> 17„G;G„ s. dolor J.O.J.J.36¢%2FGolaaccocoi7Gro1-20J8-054382("JUULwas one of the first major retail e-cigarette
<br /> Testimony of Josh Galin, Fairplay, February 14, 2023 16
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