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 Roku Channel Store and Amazon Fire TV 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.
Doll Time creates stories that are played out through dolls. Elsie and Annie are the main doll characters with numerous other supporting characters that make appearances in different episodes. The characters are continuous throughout all the videos but the stories do not build on each other, making it easy for young viewers to watch episodes at random. The storylines are engaging for children of a variety of ages and the variety of lengths ensure that differing attention spans are taken into account.
Almost all of the visual aspects of the videos in the app are made up of children’s toys. The dolls have numerous different outfits, hairstyles, and even houses. They are moved around by hands, although the rest of the human handlers’ identities are hidden off-camera. Even the thumbnails for each video are visually appealing to children, with photos of the dolls overlaid with child-friendly artwork, some even featuring cartoon versions of the characters.
While there are no real celebrities in these videos, they do occasionally have dolls that are acting as celebrities. For example, one episode features the dolls at the Eras Tour seeing Taylor Swift. Another episode features the main doll characters auditioning for American Idol, complete with doll versions of Katy Perry, Lionel Richie, and Luke Bryan. Numerous popular fictional characters also make appearances, most notably Elsa and Anna from Frozen; who are the mother/aunt to Elsie and Annie. Thumbnails for these videos show real photos of the featured celebrities and characters, capitalizing on children’s interest in these celebrities.
The language within the app is geared towards children, mirroring the creative play of a child. This type of language will be familiar and comfortable to children, and I wouldn't be surprised if children model some of the same conversations and language in their play.
The differing voices of the different dolls help to pique interest and build continuity throughout all the videos. There are also occasional sound effects, such as bringing noises during an attempt to cut into noncake items in a parody of the show “Is It Cake?” Items being used by the characters often also have accompanying sound effects, like a timer dinging or an instrument being played.
There is also very quiet background music that is just barely distinguishable, allowing the dialogue between the characters to be the main focus.
At the end of each video, there is an advertisement for the Doll Time channel and all the different ways to watch with different apps and devices. The app automatically plays the next video after completing one and there are also occasional video advertisements between these videos. These advertisements are for other child-directed apps and items.
The app description in the Amazon App Store makes it clear that children are the intended audience. The description mentions that the app, “entertains and educates kids on manners, determination, persistence, the importance of laughter and friends through creative storytelling.” While the Roku App Store doesn’t mention children so specifically, it does use language that implies children would be using the app; “pretend play, learn manners, colors, numbers, and the joy of friendship through imaginative stories.” The app is also listed in the Kids & Family category of the Roku App Store, further enforcing an expected child-directed audience.
There are limited reviews available to give an approximation of the audience composition. Roku does not collect written reviews and most of the reviews given on Amazon do not have accompanying written feedback. However, two out of the three reviews specifically mention children using the app.
Privacy
Both the privacy policy and the Amazon App Store description mention the app’s adherence to COPPA rules. According to the privacy policy, which was last updated on April 22, 2024, Future Today indicates that “Viewers under the age of 16 must use the Future Today Inc. sites under adult supervision.” However, there is no age gate or other check in place to ensure that an adult is supervising a child on the app. The developers do indicate that they collect personal information including, “IP address, device and advertising identifiers, first name and last name, usage data and other information obtained with cookies and similar tracking technologies.” They also indicate that they share location information with advertisers.
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Screenshots of Doll Time
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.
