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 & 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.
In Dino Bash, players must protect their dinosaur egg from angry cavemen who are intent on attacking it. Players can drop rocks and bombs on the cavemen or send a variety of dinosaurs to attack. Different cavemen have different abilities- some shoot arrows, some carry shields, and some can heal others. Similarly, the dinosaurs have their own unique attack and defense capabilities, from shooting toxic poison to different health strengths.
Each level has a certain number of cavemen that come in waves to be defeated. Upon defeating all of the cavemen an animated dinosaur is shown dancing while confetti is shot off in the background. After winning a level the players also earn coins, stars, and diamonds that can be exchanged for upgrades to their dinosaurs and weapons. These upgrades allow the attacks on the cavemen to be more efficient or increase the defense of the egg they are trying to protect.
The animations in this game are very child-like with cheery dinosaurs that are brightly colored. The landscape in the background is reminiscent of child-friendly video games filled with simple trees and mountains that add vibrance without distracting from the main gameplay. The overly-large dinosaur egg that the player is tasked with protecting is larger than the cavemen and most of the dinosaurs. The animations and visuals give a child-like fantastical appeal to the game.
Jungleesque, video game-style music plays in the background while the app is open. Various sound effects accompany the attacks, such as explosions and grunting noises from the cavemen. After finishing a level celebratory cheers and fireworks can be heard.
There is no advertising as part of the normal gameplay. However, optional video ads are sometimes offered to increase rewards. These ads are for other child-directed gaming apps.
Dino Bash is rated 9+ in the Apple App Store, E in the US Google Play Store, and PEGI 7 in the European Google Play Stores. Tilting Point has a separate Children’s Privacy Policy, indicating that they expect children to be using many of their apps. However, their Terms of Use indicate otherwise by stating that most of their apps are not to be used by children under 13.
App reviews reflect the idea that children are the majority of the users of the app. There are many reviews from parents and children in both Google Play and Apple app stores indicating children under 13 are playing Dino-Bash. Most players who give their age seem to be within the age range of 7-12 years old.
Privacy
Tilting Point has a broad Privacy Policy, which was last updated on December 7, 2022, as well as a Child Privacy Policy, last updated on October 21, 2022. Their Child’s Privacy Policy implies that they adjust the information they collect if a user indicates they are under 13. However, there was not an age gate present in either the Android or Apple version of the app. It is difficult to tell if they are treating all users as under 13 in these apps, as they do not have any way of confirming age. Additionally buried within both privacy policies are links to a list of apps that are covered by each policy. Dino Dash is not listed on either policy, despite the generic privacy policy being linked in the app store and within the app. Based on this it is unclear what information is actually being collected from either children or adults using the app.
Screenshots of Dino Bash
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.
