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.
Duddu - My Virtual Pet Dog is an idle pet game, where players can care for and interact with an animated dog. Users need to ensure that Duddu is fed, clean, rested, and entertained. Duddu can be dressed up in different clothing and there are numerous items that Duddu can interact with, such as toys and books. Outside of Duddu’s house, players can take Duddu to other locations, such as the hospital or the gym. However, without a paid subscription, these outside locations can only be visited when Duddu specifically requests to go.
Duddu and the other animals he encounters are animated in a child-directed way. The dogs all walk on two legs, like a person, and engage in normal tasks that you would expect people to be doing. Rather than eating dog food, Duddu’s meals come from the refrigerator and consist of things such as juice boxes, cookies, and coffee. Duddu happily takes a shower, instead of a bath, and the walk-in shower is filled with brightly colored bubbles to illustrate the dog becoming clean. The backgrounds are similarly illustrated in ways that appeal to children, with brightly colored rooms and furniture.
There is no written language within the app, Duddu shows users what he wants with images in speech bubbles. This ensures that all children are easily able to infer how to interact with the app, even if they are not yet able to read.
Sound effects are played for most actions, such as bubbles and water when bathing or snoring when asleep, encouraging young children to continue to interact with the app to discover the sound effects each item makes. Upbeat, child-like music is played throughout the game.
As players interact with Duddu and meet his needs, they earn points that help to advance levels. Unlocking new levels earns items such as new clothing, furniture, and food for Duddu.
Mini games can also be played to earn coins which in turn can be used to purchase customization items and items needed to interact with Duddu.
A banner ad is consistently displayed at the top of the game. This banner ad sometimes promotes child-directed apps and other times has general audience items and apps. A pop-up ad for other child-directed games by the same developer (primarily a similar game but with a cat), is displayed sometimes when moving between locations in the game. Optional video ads for other child-directed games can be viewed to earn extra rewards or unlock some customization items.
‘Duddu - My Virtual Pet Dog’ is rated 4+ in the Apple App Store, E in the US Google Play Store, and PEGI 3 in the European Google Play Stores. The app description mentions that it is, “guaranteed fun for people of all ages” and “is certified compliant with the Children’s Online Privacy Protection Act (COPPA) by FTC-approved COPPA safe harbor PRIVO;” indicating that the developers are expecting children to be the primary audience of the game.
The reviews reflect the child-directed designation, with reviews indicating that children are the primary users of the app. There are reviews from children, as well as parents indicating their children are playing the game. A few parents mention that they are playing the game as well, but this is only after they downloaded the app for their children.
Privacy
According to the privacy policy, which was last updated in December 2023, the developers expect children to be the primary audience of their apps. They indicate that most of the content in their apps can be accessed without providing any personal information and that they only collect “as much information about a child as is reasonably necessary for the child to participate in an activity.” They indicate that they collect broad location information to provide relevant advertising, information necessary to maintain the functionality of the app, information to protect user security, and any legally required information. They do not profile or track the user's information, use targeted advertising, or collect any personally identifiable information. They also indicate that they do not sell information and only share the information with third parties that support the app and are contractually obligated to keep the information confidential. They may also share information if legally required or to ensure the safety of the user.
Bubadu is a member of the PRIVO Kids Privacy Assured COPPA Safe Harbor Certification Program, indicating that they are committed to remaining in compliance with COPPA and safeguarding children’s privacy.
Find Pixalate's full catalogue of reviews in our CTV and Mobile App Review Page
Screenshots of Duddu - My Virtual Pet Dog
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.
