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 mobile app (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.
and 
and 
and 
The gameplay screenshots for Clouds & Sheep show that the content is visually directed to children with a mixed audience based on the animated characters and orientation of activities in the game. Every level is themed and the graphics are pleasing and alluring. It's about tending to the sheep as if you are a shepherd while moving clouds, seeding the land, catching stars, rolling, and tossing the sheep in this relaxed game to make them happy. Players have missions to accomplish to progress in the game such as making rain with the clouds. It is a simple game with goofy animations that children would enjoy as well as adults packed with charm. The animal characters make delightful funny physical expressions and sounds. This game is a great way to give children the ability to manage tasks or assignments. The description in the “about this game" section of the Play Store states, “They’re cute, they’re fluffy, and they love to play….toys and gadgets.” It is a delightful game that kids and parents would enjoy together.
The incentive of the game is to make the sheep happy so you can earn points to purchase other items to make your tasks easier. Players have to be careful because some things are dangerous for the sheep such as poisonous plants and it is the players' responsibility to keep them safe. When the player does everything correctly at each level the flock is happy.
The app does have ads that sit at the top of the game. The ads shown are, “Premium outlets and Premium games by Handy Games.” Advertisement is directed to adults with a few such as the array of games directed to a mixed audience. With in-app purchases, there is a parental lock to disable purchases.
The game is rated E for Everyone in the Google play store and 4+ in the Apple store. There is no age gate. There is evidence that children use or have used the app. A review posted in December of 2022 in the Google Play store says, “I’ve been playing this since I was like 6 or 7.”
Another review without age specification in the play store posted in November of 2021 says, “I’m just 6 years old when I started downloading it and I loved it very much every time.”
Privacy:
The developer’s privacy policy states, “processing is necessary to protect the legitimate interest of persons responsible or a third party, unless the interests or fundamental rights or freedoms of the data subject, which require the protection of personal data, prevail, especially when the data subject is a child." The privacy policy is in German and without a proper COPPA policy.
Screenshots of Clouds and Sheep
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.
