Nearly two dozen child advocacy and consumer watchdog groups are calling on the Federal Trade Commission to investigate Google for allegedly violating children’s privacy laws with its YouTube online video service.

A complaint argues that Google has made “substantial profits” gathering information about children — potentially tens of millions of them — and targeting these young YouTube users with advertising.

These groups, which include the Campaign for a Commercial-Free Childhood, the Parents Television Council and the Teachers Resisting Unhealthy Childhood Entertainment — call on the FTC to investigate what it calls “overwhelming evidence” that Google is violating the Children’s Online Privacy Protection Act.

YouTube issued a statement this morning saying it’s still reviewing the complaint but noting its terms of service clearly state the Google-owned service is not for kids younger than 13. Its ad policies also restrict advertisers from targeting personalized ads to children under age 13 or collecting personally identifiable information.

“Protecting kids and families has always been a top priority for us,” a YouTube spokesperson said. “Because YouTube is not for children, we’ve invested significantly in the creation of the YouTube Kids app to offer an alternative specifically designed for children.”

Child advocates say YouTube has emerged as perhaps the most popular online destination for young viewers, with channels such as ChuChuTV Nursery Rhymes & Kids Songs and Ryan ToysReview among its most popular channels. One 2017 study found that 80% of kids ages 6-12 use YouTube daily.

YouTube

One of the most popular YouTube channels, Ryan ToysReview, has 13 million subscribers and more than 20 billion views. The channel’s host, a 6-year-old named Ryan, is not only among the Forbes ranking of most popular of YouTubers — his site has raked in $11 million in revenue, according to a Washington Post report.

YouTube stands to reap 45% of those ad revenues, earning an estimated $5 million from just one of its many kid-targeted channels, the complaint argues. It’s not surprising, therefore, that YouTube actually encourages the creation of children’s content for YouTube, the complaint argues.

The streaming video service is well aware of its appeal with young users, advocates say.

The FTC complaint notes YouTube encourages the creation of child-focused programs, and, through its YouTube Partner Program, splits the ad revenue. One of its executives even boasted of its extensive collection of child-targeted videos at MIPJunior, a showcase for children’s programming.

Advocates say Google’s advertising technologies make it possible for brands to target children on YouTube, using keywords such as “kid,” “child,” “toddler,” “baby” or “toy,” the complaint maintains. And that its privacy policy notes that it collects personal information from users, including phone numbers and location.

“There is no reason to think that YouTube treats information collected from children any differently that that collected from other users,” the complaint argues.

The complaint maintains that YouTube has failed to comply with COPPA requirements, which require a clearly labeled link spelling out its what information it gathers about children. It also requires making reasonable efforts to notify parents of how it gathers and uses a child’s data.

Google prevents kids younger than 13 from registering for a YouTube account and it blocks those who enter a date of birth showing they’re underage from creating an account. YouTube also will disable an account if it becomes aware that it was created by someone who is underage, a spokesperson said.

Child advocates argue, in their complaint, that the language of YouTube’s terms of service “does not exempt YouTube from complying with COPPA.” Age-gating the registration process this doesn’t shield YouTube from COPPA requirements, because it requires registration to post videos — not to watch them, the complaint argues.