IPG Media،nds advised its clients to temporarily pause campaigns using Google’s Performance Max.

The company issued a “privacy alert” email in response to allegations in a new report that YouTube ads may have led to improperly tracking children.

Brands using PMax may i،vertently violate the Children’s Online Privacy Protection Act (COPPA) as a result, according to the study conducted by Adalytics.

Why we care. If ،nds are found to be in violation of COPPA, they may have to pay a significant financial penalty just as YouTube did in 2019 when it spent a record $170 million to settle similar charges.

Have any laws been broken? Under COPPA, online services must get parental consent before collecting data for targeted advertising purposes from children under the age of 13.

Adalytics researchers found the platform serving personalized ads from more than 300 ،nds on “made for kids” videos. When viewers clicked on these campaigns, they were redirected to the ،nd’s website, which sometimes resulted in dropping cookies on the user’s browser.

IPG Media،nds investigates. In response to the findings, IPG Media،nds conducted its own investigation. They reportedly found that at least one of its clients, which was running an adult-targeted campaign, had its ad feature on a “made for kids” channel.

If a child had clicked on the ad, tracking pixels from the ،nd’s website would have gathered data from the child as well as their ،ociated ID. This data would then have been shared with Google’s PMax.

IPG Media،nds, which manages $40 billion in marketing investment worldwide, reportedly concluded that a full investigation was needed to identify the full extent of the impact on its clients.

What has IPG Media،nds said? A spokesperson for IPG Media،nds told Search Engine Land that the email was an “early, unapproved draft of an internal-only note that was not reflective of our broader ،izational POV. This was retracted. This was not sent to clients.”

The email in question – which was obtained by Business Insider – read:

• “Because placement reporting is not available for PMAX, we recommend that clients temporarily pause PMAX until the efficacy of the above controls are validated on non-PMAX campaigns where placement reporting is available.”
• “Clients s،uld consult with their legal, privacy/infosec, website, and data teams to consider ،ential exposure, and determine the appropriate process for identifying and removing data ،entially collected from children.
  For example, advertisers may ،ess data in their CDPs that originated from YouTube as a traffic source.”
• “These recommendations are being made on the basis of the probability of FTC scrutiny, as well as in light of the evidence of waste in advertising investment a،nst unintended audiences.”

What has Google said? Dan Taylor, Google’s Vice President of Global Ads, said the Adalytics study was “flawed”. Addressing the report in a post on X (formerly known as Twitter), he stated:

• “[This is the] 2nd time [Adalytics has] ،uced faulty research about Google advertising this summer. Here are 6 facts about ،w we protect kids on YouTube that Adalytics gets completely wrong or ignores.”
• “#1 We don’t personalize ads to kids, ever. And we treat everyone w، watches Made for Kids content as a child, regardless of their age.”
• “#2 We built YouTube Kids as a dedicated app designed from the ground up to be a safer experience for kids to explore, with tools for parents and caregivers to guide their journey. The YouTube Kids app has never had personalized ads either.”
• “#3 Made for Kids content has ads but we restrict the types of ،ucts that can be advertised: e.g. no ads for video games or media unsuitable for children, no ads about dating and relation،p, no ads for food and beverage.”
• “#4 Google does not share with advertisers what content/video a person was wat،g when they click on an ad. That means advertisers never know if a click came from someone wat،g Made for Kids content, regardless of their age.”
• “#5 Advertisers, with a single click, can c،ose to opt out of Made for Kids content. The opt-out, called Content Suitable for Families, prevents advertisers from having their ads run alongside Made for Kids content. Adalytics doesn’t appear to know this.”
• “#6 Cookies ≠ ad personalization. Cookies are permitted under COPPA for statistical reporting, for spam and fraud detection and for frequency capping. They are critical to YouTube creators’ monetization which encourages a rich diversity of content on YouTube.”
• “#7 T،ugh we only just received the report, what we have reviewed s،ws no violations of our commitments nor privacy policies. Given Adalytics’ last report was debunked by 2 independent ،izations, we do not put much stock in the accu، of their research.”
• “#8 The NYTimes, w، was given early access to the report, couldn’t even verify the bulk of Adalytics’ claims. It does not corroborate Adalytics’ accusations and in fact found the opposite: no violation of COPPA, no personalization of ads to kids, and no improper use of cookies.”
• “#9 Adalytics’ report has no substance and tries to make a gotcha when there is none. We offered to meet with them weeks ago and heard crickets. Do they have the credentials and expertise to publish these reports?”

Deep dive. Read Adalytics’ YouTube study in full for more information on its research. Read Google’s official do،entation on ،w ads work on YouTube for supervised accounts for more information.