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Mobile App Manual Review under COPPA Rule: ‘Differences - Find Difference'

May 3, 2023 12:00:00 PM

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).

Manually reviewed in this post

 

The 10 COPPA Rule factors

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.

Reviewed by: Crystal Pearson

Crystal Pearson

Manual Review: Differences - Find Difference

Likely audience after manual review

  • Developer: Guru Puzzle Game (Google), Guru Smart Holding Limited (Apple)
  • Google Bundle ID: puzzle.game.find.differences
  • Apple Bundle ID: 1522840765
  • Privacy Policy
  • Crystal’s Take: Relaxing colorful game that helps players to focus and notice subtle differences. The activities in this fun game could stimulate the brain in real life by facilitating good cognitive development.

COPPA factors used to determine audience

and and

The gameplay screenshots for Differences-Find Difference show that the visual content is for a child directed mixed audience because of the age of the models in the images. It would seem that the app is geared towards deepening the observation skills of the player and encourages them to use the power of focus and concentration. The game has different scenarios such as objects, almost identical images, and altered photographs. The music and audio are that of a banjo playing with nursery rhyme type sounds. The description in the “about this game" section of the Play Store states “Preferred parent-child interaction, suitable for adults and children.”

The app has advertising throughout while playing the game.  The apps that show at the bottom of the game are Amazon Fresh, Instagram, Instant Ink, Walgreens, Wordscape and others. These ads are geared towards the general audience.

This game is rated E for Everyone in the Google Play Store and 4+ in the Apple store. There is no age gate or parental control.

Privacy:

The developer’s privacy policy states, “We do not knowingly collect information directly from children under 16 without parental consent."

Screenshots of Differences - Find Difference:

About Pixalate’s Trust & Safety Advisory Board

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.

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