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 and 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.
Crayola Scribble Scrubbie Pets is an app centered around the Scribble Scrubbie toys (also known as Washimals in some locations). These toys allow kids to color their toy animals with markers in their unique style, with a quick wash rinsing away the color whenever a new design is desired. The app contains virtual pets that can also be colored and designed in whatever way the player desires. Players can decorate animals with virtual markers and stamps in various colors.
After an animal is decorated to the player’s satisfaction, it is dropped into a virtual world where the player can play and interact with the animal and other objects in a variety of scenes. They can groom their animal and even provide medical care. Some mini-games are simple enough for even the youngest users to understand, such as a bathtub rollercoaster.
Like their real-life counterparts, the pets in the app are adorable and very much designed with children in mind. They have exaggerated facial expressions and large eyes that draw in children. They can be personalized with an array of color options and cute stamps such as hearts, stars, and flowers. The different scenes are very whimsical, with humongous star flowers, ice cream cones melting into a ‘mud’ pit, and giant fountains that can paint the animals in different color rainbows.
Playful and upbeat music plays in the background. Many sound effects are played when interacting with different objects, such as water flowing in the fountains or animals squishing around in the mud. The animals, themselves, also make a variety of sounds- from little sighs to squealing noises.
Paw tokens are earned by doing tasks and interacting with different features of the app. These tokens can also be purchased via an in-app purchase and are used to unlock additional pets. Additional pets can also be added if the user has purchased any of the toy Scribble Scrubbie Pets. A barcode can be found on their packaging and scanned into the app so that the player can have a virtual version of their real-world toy.
There is no external advertising. There is, however, an occasional video advertisement for a subscription to the app. This seems to be primarily upon first opening the app and is directed to parents before they pass the device to their child.
Crayola Scribble Scrubbie Pets is rated 4+ in the Apple App Store, E in the US Google Play Store, and PEGI 3 in the European Google Play Store. The app description mentions that it is “for toddlers, preschool age, pre-kindergarten age, and young children.” This is also reflected in the reviews with most reviews from parents writing about their children using this app, as well as reviews written by children themselves.
Privacy
As Crayola is a company that primarily markets its products to children, its privacy policy starts with a children’s privacy notice that was last updated on May 26, 2022. This notice is straightforward to understand, lacking the legal jargon that often weighs down privacy policies. They explain their policies in simple terms to ensure that parents know exactly what information is and isn’t being collected. They indicate that they do not collect any personal information from users but specify, “We do collect some information to help us run the app such as the country you live in, how much time you spend in our game, and the mobile devices you use and similar. But this information does not identify you, this means that we do not know who you are.”
The remainder of the privacy policy was last updated on February 23, 2022, and goes into more specific details about their compliance with COPPA and GDPR, as well as more specific information about the data and third parties they mention in their Children’s Privacy notice. It also contains information about links in the parent section of their website and apps that may redirect parents to third parties that might collect additional information.
Find Pixalate's full catalogue of reviews in our CTV and Mobile App Review Page
Screenshots of Crayola Scribble Scrubbie Pets
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.
