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 popular game (1 million+ downloads) from the Google Play and 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.
The gameplay screenshots for Catch Tiles Magic Piano Game have visual content and subject matter that is directed to a mixed audience. The piano keys in the game have an animation that includes images of animals, people, and other imagery that would appeal to children and adults. The description in the “about this game" section of the Play Store explains that the user can “try to complete magic songs while catching the tiles of the magic piano".
The purpose is to tap the black tiles and enjoy the music. You lose if you miss the black tile and tap on a white one. The app store description says, “Challenge your hand speed limit". The incentive structure of the game is daily rewards and a lucky wheel.
During gameplay, if you miss a black tile, game ads pop up and automatically play. The ads are child-directed with a mixed audience.
This game has an Everyone E rating in the Google Play store. I saw evidence of adults and children using the app based on the user reviews in the Google Play Store. One review from August 2022 stated, “...I love this app bc I know how to beat endless mode even though I am still a child, download this app and you guys will love it because my school is music.” The review was from a child, although there was no specification of their age.
Privacy:
The developer’s privacy policy states, “if you are under the age of 15, you need to ask legal guardian’s permission to use or access our services.” The privacy policy does state it will take reasonable measures to promptly erase personal data for children under the aforementioned age. "However, the app is easily accessible without an age gate. The rating in the iOS app is 4+ and E for Everyone in the Google Play store.
Screenshots of Catch Tiles Magic Piano Game:
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.
