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 & 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.
Teachers have been fighting students over Coolmath Games since its debut as a website, long before the mobile apps existed. With the word “math” in the title, it seems like it should contain educational games that could align with the curriculum. In reality, Coolmath Games is a collection of mini games that are more fun than educational. The lack of educational content actually does cause many schools to block the Coolmath Games domain from their networks, including school districts that I have previously taught in.
While there are a few games that could be considered educational, this is not the focus of the app. Nevertheless, this lack of educational content does not detract from the child-directedness of the app. Most of the games are very appealing to children, with many featuring simple gameplay that is reliant on clicking or dragging around items or characters on the screen. Some have stories or a problem to solve, while others involve reaching a designated goal. However, one thing they all have in common is their appeal to children.
Many of the games within the app feature animated characters that are appealing to children. Even the apps without characters, often feature inanimate objects with faces and personalities. The Coolmath Games main page is also appealing to children, with brightly colored app descriptions offset by a dark background. The simple layout features new games, games the user has recently played, and popular games. This makes it easy for the youngest users to find the game they are looking for.
While the main home screen does not have any sounds, each app has its accompanying sound effects and music. While they are all slightly different, the presence of generally upbeat music and the prevalence of sound effects in each game is more appealing to children than to adults.
These simple games do not contain any complex incentive systems, and there is not an overarching rewards system stretching across all the games in the app. Each game has their own simple way of awarding points, but are mostly reliant on an intrinsic motivation of beating the game rather than elaborate rewards.
There is advertising at transitions between playing or switching games, as well as banner ads across the bottom of the screen. These ads are primarily for general audience or mixed audience apps, goods, and services. The Android app does seem to have more advertisements targeting a mixed audience, while the iPhone app seems to contain more general audience advertising. Location data does seem to be utilized, as I saw several apps for businesses near my current location when testing the app.
Coolmath Games is rated E in the US Google Play Store, PEGI 3 in the European Google Play Stores, and 9+ in the Apple App Store. While the descriptions differ slightly between the two app stores, both make it clear that children are a targeted audience. The Google Play Store description mentions, “Coolmath Games is kid-friendly because there is never violence, empty action, or inappropriate language – just a wide range of fun casual games and strategy puzzles.” While the Apple App Store does not specifically mention kids, it does include the rest of the above description and mentions that the app is “for all ages,” implying a mixed audience or child-directed app.
Looking at the reviews, most reviews do seem to be referencing children as the primary users of the app. While there are some parent reviews, most seem to be directly from elementary aged kids. Some reviews even go so far as to mention tricking teachers into thinking the app is educational.
Privacy
Despite the obvious child-directed nature of the app, the privacy policy, which was last updated on April 25, 2024, states.
“Our Apps are general audience Apps, are not designed for children under 13, and we do not intentionally collect information on our App from those we know are under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.”
The privacy policy also states that they collect user interactions with the app and usage data, including device information. They do share information with their affiliates, service providers, and advertising partners. Although they do not mention anything about collecting location data, I did see advertising for local businesses near my current location when testing the app.
Find Pixalate's full catalogue of reviews in our CTV and Mobile App Review Page
Screenshots of Coolmath Games Fun Mini 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.
