The Center for Digital Democracy, Consumer Action, Consumer Watchdog, and The Praxis Project joined in a complaint with the Federal Trade Commission about Pepsi’s online game sites, which the groups allege are deceptive and violate teen users’ right of privacy.

Pepsi and its subsidiary Frito-Lay, which owns Doritos snack foods, have mounted several digital marketing campaigns that the complainants find problematic.

“Frito-Lay has infiltrated the lives of teens by developing covert advertising campaigns centered on things teens love – video games, music, horror, sports, contests, and social networking,” according to the complaint.

The groups argue that the games and other campaigns are intended to “disguise advertising as entertainment” and are deceptive when evaluated from the perspective of teenagers, who are the target audience.

In one example, Doritos launched online games, including, where players try to escape from an insane asylum. The Web site encourages players to “make the scare personal” by enabling their webcams to take their pictures and project them into the game. Doritos also utilized players’ Twitter and Facebook accounts by sending tweets and status updates from the game to players’ followers and friends. While the game itself is devoid of advertising, players cannot finish the game without purchasing a bag of Doritos and using the infrared marker on the bag to unlock the ending, according to the complaint.

Other digital marketing campaigns launched by the company’s “Snack Strong Productions” include a make-your-own Super Bowl TV ad, a partnership with video games like Call of Duty and Madden NFL, and concerts with musicians like blink-182 and Rihanna.

“Frito-Lay uses legitimate media or creates its own fake media to promote its advertising campaigns. This technique contributes to the perception that these campaigns are legitimate entertainment, enabling Frito-Lay to capture the interest of adolescents who want nothing to do with advertising,” the groups contend.

In addition, the games request contact information without adequately disclosing that it will be used for marketing purposes, according to the complaint. Personal information provided during registration for the online games may be shared with other Pepsi companies, and when teens enable their webcams during games, they are consenting to the company’s use of their name, images, and other information in their social networks.

The groups also maintain that by posting messages on a player’s Twitter feed or Facebook wall without user knowledge, Pepsi violated the FTC’s Guides Concerning the Use of Endorsements and Testimonials in Advertising.

Messages are generated by Frito-Lay without the players knowing they are transmitted from their accounts. “Postings made without the explicit knowledge or consent of ‘sender’ by definition do not honestly reflect the views of the game player,” which violates the Guides, the groups argue.

“Teens are particularly susceptible to these kinds of campaigns because of certain physiological and psychological traits associated with adolescence that make them likely to take risks, act impulsively, and be unduly influenced by peers. Frito-Lay takes advantage of teens’ vulnerabilities by disguising its marketing campaigns as entertaining videogames, concerts, and other immersive forms of entertainment,” according to the complaint.

The groups requested that the FTC investigate Frito-Lay’s marketing to teens and “take action to stop these practices.”

To read the complaint, click here.

Why it matters: In a statement to AdAge, a spokesperson for the FTC said that it will “review [the complaint] carefully” and that it was the first filed with the agency about digital marketing to teens. The marketing of food to children and teens has been in the headlines recently. Currently under debate are proposed guidelines that would require food and beverage companies to modify the content of their products to meet nutrition standards or eliminate the marketing of such products to children under age 18. While the FTC recently backed off the proposal, saying that marketing directed to teens aged 12 to 17 would be allowed, food and beverage companies should be aware of the controversy.