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 takes a look at a game which is available from the Google Play & Apple App Stores. 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.
Barbiemania is sweeping the globe so I thought this would be a perfect time to review a Barbie-themed app. As if Barbie were not previously enough of a celebrity, Greta Gerwig and Margot Robbie have catapulted the celebrity of Barbie to new heights, expanding the appeal of Barbie to both children and adults. Despite this newly universal appeal, this app remains firmly geared towards children and not something that would necessarily appeal to adults. At its core, this is a makeover app. With limited free options, this is not something that would hold the attention of teens and adults and is solidly geared toward younger children.
Within this app are only options to makeover Barbie and her unicorn. While Ken would probably enjoy all the different makeover options he is, after all, just Ken and is nowhere to be found within this app.
Players are able to choose hair, makeup, accessories, and a dress for Barbie. There are a handful of base options for each step of the makeover that can be customized with different colors. Color options are limited to the typical Barbie colors, with several shades of pink and purple with a few icy blues, yellows, and orange. Make-up is masquerade-style with swirly designs that can be painted on the face. There are plenty of glitter options available for makeup and hair highlights. Even the tiara and necklace are customizable, with players able to select the jewels that they want to include in their accessories.
Paid options include fairy wings, mermaid tails, and additional options for the other steps of the makeover.
After the player finishes designing their Barbie, it is placed in “The Gallery of Magic” where users can browse through the different looks that they have created. There are also “magical gift boxes” that allow the user to earn extra items that can be used within the makeovers.
Most of the language and instructions within the app are verbal. This allows younger children, who are not yet able to read, to understand how to navigate and interact with the app. The narrator is upbeat and very Barbie-like. She will prompt you to “tap the arrow when you are ready to move on” if you haven’t interacted with anything on screen for a few minutes. Each step of the way she explains in simple and concise language what needs to be done to continue the makeover.
The music that plays in the background sounds like the type of music you might find at the beginning of an animated fairytale adventure movie. Sparkly chimes can be heard whenever a new option is selected for Barbie’s look. There are plenty of starbursts and sparkles accompanying the sounds, encouraging children to try out the different options in each step.
There are a variety of different advertisements throughout the app that are all for other child-directed games developed by Budge Studios, such as My Little Pony, Hello Kitty, and Paw Patrol. On the start screen a banner ad across the bottom scrolls with numerous Budge apps. Once inside the app, the home screen has a small advertisement in the top left corner that rotates between different games. Video advertisements are played after each step in the makeover process and will play in a loop until they are closed.
‘Barbie Magical Fashion’ is rated 4+ in the Apple App Store, E in the US Google Play Store, and PEGI 3 in European Google Play Stores. The language in the app description is also geared towards children. Descriptions such as, “Ready to start your magical journey? Anything is possible when you dream big with Barbie!” draw children into the Barbie world and encourage them to download and use this app.
Reviews reflect the target audience with a mix of reviews written by parents whose children are using the app and reviews from the children themselves.
Privacy
According to the privacy policy, which was last updated on May 31, 2021, Budge Studios acknowledges that most of their apps are child-directed. They indicate that they do not use an age gate and treat all the users of their child-directed apps as children. They state that they are in compliance with COPPA and that “Budge Studios does not knowingly collect personal information as defined by COPPA from children through its Sites or Programs.” They are certified by the Entertainment Software Rating Board's Privacy Certified Program (ESRB). They additionally link directly to the Federal Trade Commission’s website on COPPA as part of their privacy policy.
Screenshots of Barbie Magical Fashion
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.
