Welcome to Pixalate’s CTV & Mobile App Manual Reviews According to COPPA, a series containing the detailed factors the Trust & Safety Advisory Board educators used to assess an app’s child-directedness.
The educators manually review thousands of mobile apps available in the Google Play & Apple App Stores as well as connected TV (CTV) apps from the Roku Channel Store and Amazon Fire TV App Store using the COPPA Rule factors shown below & make those results available to the public at ratings.pixalate.com.
This post looks at a game from the Apple App Store. Our reviewer discusses how the subjective factors set forth in the COPPA Rule apply to the app and factor into the reviewer's determination as to whether the app is child-directed or general audience (i.e., it is not targeting children).
The teacher will indicate the factors they relied upon in their assessment using the 10 factors shown below that reflect the 10 child-directed factors in the COPPA Rule.
The game uses bright animation, in a style which is familiar from other games of this nature: wide, blinking eyes and large heads to aim for a cute aesthetic, similar to the look of LOL dolls.
Baby games appeal to children with the cute factor, and dressing up is a common play theme for young children. The aim of the game is to look after mother and baby, dressing and feeding them. Children often enjoy role playing games of this nature in real life, and this would likely appeal to them in a game too.
Regular advertisements appear for other games by the same developer, including other Baby Adventures and face painting games. These are likely to have the same target audience. These advertisements are very difficult to dismiss without accidentally loading them in the App Store, which is common with in-game advertising.
From the very first level, it is impossible to complete the tasks without watching an advertisement or making an in-app purchase. Unfortunately the video on the first level was “unavailable”, meaning that unless I paid $2.99, I could progress no further.
Privacy
The developers’ Privacy Policy is fairly brief, but states that minors must have their parent or guardian read and accept the policy on their behalf. There is no age gate on the app to determine the age of users.
Screenshots of Baby Adventure - Salon Dress-Up & Makeover Games:
Pixalate’s Trust and Safety Advisory Board was created to bring in individuals with experience using child-directed apps in the classroom to review and assess which apps are child-directed. This manual review process serves to quality check Pixalate’s automated review process. See our full methodology for more information.
Disclaimer
This blog post published by Pixalate is available for informational purposes only and is not considered legal advice. By viewing this blog post, the reader understands and agrees that there is no attorney-client relationship between the reader and the blog publisher. The blog should not be used as a substitute for legal advice from a licensed professional attorney in the applicable jurisdiction(s), and readers are urged to consult their own legal counsel on any specific legal questions concerning any specific situation. The content of this blog post reflects Pixalate's opinions with respect to factors that Pixalate believes may be useful to the digital media industry. Pixalate's opinions are just that, opinions, which means that they are neither facts nor guarantees; and this blog post is not intended to impugn the standing or reputation of any entity, person or app, but instead, to report findings pertaining to mobile and Connected TV (CTV) apps.
