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 CTV app from the Roku Channel Store and the Amazon Fire TV 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.
FailArmy is a collection of videos featuring people falling down, crashing into things, spilling things, breaking things, and other unfortunate situations. These fails would appeal to children, teens, and college students, but mature adults would probably not find them as amusing. It is reminiscent of America’s Funniest Home Videos which my siblings and I watched religiously while my parents rolled their eyes from another room.
The videos on FailArmy are a mixture of curated playlists, numerous fail videos, commentary on these types of videos, and prank videos. While most of the content are collections of videos from others, they do have some of their own original content which feature the employees of FailTV and their antics around the office.
The FailTV app can be sorted by categories of animals, body parts, girls, kids, old people, on the job, pranks, school, sports, technology, vehicles, and weather.
The original videos, and many of the curated videos, include the types of jokes and egging each other on that would appeal to children and teenagers. The descriptions of videos are also written in teen and child directed language, describing videos with “derpy dogs,” “the ultimate faceplant,” and “humans being idiots.”
The videos feature people of all ages, including many younger children. Quite a few of the videos feature school performances or sports teams. While children are featured prominently in most categories, there is also an entire category of videos featuring fails from children.
Most of the videos featured in this app are home videos without any extra content or features. Some of the videos, most notably the FailArmy Originals, feature colorful frames, doodle drawings, and child-like handwriting style fonts. A few videos even feature fire animation at the bottom of the screen to emphasize the epic fail nature of the content. These visuals are appealing to children and teens.
The description of the FailArmy app states, “FailArmy is like your big brother who warns you what not to do but also laughs at you in your most embarrassing moments.” While this could certainly be the case with adult sibling relationships, this type of description would appeal more to children and teens. Roku does not collect written reviews to give insight into the audience composition and most of the Amazon reviews are too general to determine the age of the user. However, the Amazon store does have a few reviews from parents that indicate their children are either watching the app independently or as a part of the entire family watching together.
There are occasional video ads for general audience items, such as coffee and banks.
Privacy:
According to the privacy policy, which was last updated on February 1, 2021, FailArmy does not intend their apps and content to be consumed by children under 13. However, they do not indicate that under 13s may not use the app. There is no age gate on this app and FailArmy does not distinguish in any way if users are under or over the age of 13. They indicate that anyone under 13 should not provide personal information to the developers. They do provide contact information for parents or guardians to have a minor’s personal information removed if they discover that it has been given without parental consent.
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.
