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 game (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).
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.
The gameplay screenshots for Farm Land - Farm Life Games has app language that is child directed, and bright visual content with animation that includes computer-animated images of pigs, cows, chickens, adorable pets, and other imagery that would appeal to children. The description in the “about this game” section of the Play Store explains that the user can turn into a “explore a fantastic farm island and nurture animals.” It features “3D graphics and a funny farm simulator.” The subject matter would appeal to children.
People of all ages would enjoy the game, even though it stated the game is for girls and boys.The game's purpose is to secure your land, grow your crop, feed, pet, and heal the animals. The app store description says, “Go on adventures, raise animals through harvesting and expand your island.” The game’s incentive structure is challenging enough that older teens and adults would also be interested in playing it.
During gameplay, before the game loads, ads pop up. There are numerous ads that are displayed in my sample play. As soon as you start playing the ads are constantly showing in the game at the bottom. The ads are adult directed, “Progressive Insurance, Brex Investments and Certified Air Care Inc.” This advertising would appeal to a general audience.
This game has a Everyone E rating in the Google Play store. I saw evidence of both adults and children using the app based on the user reviews in the Google Play Store. One review from February of 2023 mentioned “...This game is amazing, my son loves it.” It was from a parent who referred to the son using the app although there was no specification of age.
Privacy
The developer’s privacy policy was last updated on January 23, 2023. The policy states, “if you are under the age of 16, you must not use our services unless you have consent of a person who has parental responsibility.” The app's privacy policy also states that it is “not intended for children and will not be responsible for children who use your credit card, or other means of payment, to purchase and Services, such as in-game purchases.” However, the app is easily accessible without an age gate. The rating in the iOS app is 4+ and E for Everyone in the Google Play store.
Screenshots of Farm Land - Farming Life Game:
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.
