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 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.
Color by Number ®: 3D No. The draw is a color-by-numbers game that sets itself apart from similar apps by allowing users to color a three-dimensional figure, rather than a flat two-dimensional drawing. The blank pictures are composed of boxes with numbers inside that correspond to different colors along the bottom of the screen. Users select a color and tap all the boxes with the corresponding number to color in the picture. App users can rotate the 3D illustration in all directions to color the front, back, top, bottom, and sides of the image.
There are numerous different types of pictures to choose from, but most are appealing to children. Cute animals, emojis, and food are some of the more common options. Due to the nature of coloring individual squares in the pictures, each image has a blocky, Minecraft-type feel to it, further appealing to children.
There is very limited language within the app, just a few simple instructions upon opening the first photo to color. There is no reading or language involved when coloring the pictures, just number matching. Young children wouldn’t even need to know the numbers, as only the selected color’s numbers are available to click and color in on the picture.
Fireworks shoot off upon completing a picture. An animation is then displayed showing the three-dimensional object being created in the same order that it was colored. Completed images are also added to “My Works,” enabling users to go back and revisit their previously colored pictures.
Video ads are played upon completing or exiting an image being colored and banner ads are displayed across the bottom of the screen while coloring. The ads are for a variety of child-directed, mixed-audience, and general-audience apps, products, and services. While some of the advertising did seem specifically directed at children, others were not entirely appropriate for children- such as role-playing games focused on dating.
Color by Number ®: 3D No. Draw is rated E in the Google Play Store. App reviews indicate that children and adults are regular users of the app. There are numerous reviews written by children, themselves, as well as parents writing about their children using the app.
Privacy
According to the privacy policy, which was last updated on May 22, 2018, users under 15 should obtain parental permission before using the app. Upon first opening the app users must agree to a user statement, which states that the developers collect age and birthday information. However, no age gate was present and the app is accessible without providing any age information or gaining verifiable parental consent.
Creative APPS indicates that they do collect personal data, including device information, local country, language, and any social media information if accounts are linked. They indicate that they do not sell this information.
Find Pixalate's full catalogue of reviews in our CTV and Mobile App Review Page
Screenshots of Color by Number ®: 3D No.Draw
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.
