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 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.
Coco Play’s Gymnastic Superstar app appears in both the Apple App Store and the Google Play Store under slightly different names. The iOS version is named ‘Gymnastics Superstar Gold Girl,’ while the Android version is ‘Gymnastics Superstar Star Girl.’ I spent time testing the app on both operating systems and did not find any discernible differences. The characters, graphics, and story are the same and similar advertisements are shown. The descriptions in the app store are also very similar, with the Apple App Store editing down a few phrases to make a slightly shorter description. The same privacy policy is given for both app versions.
Gymnastic Superstar allows users to be immersed in a gymnastic competition. Players can choose from four avatars to go through the different aspects of a competition, in hopes of winning a gold medal. The actual competitions are only one small part of the game, with users choosing a leotard, applying make-up, and visiting the hair and nail salons before events. Both the makeover and the gymnastic aspects of the game are very appealing to younger users. I can see the content of this app being especially captivating for girls around 7-11 years old.
The app uses bright colors to draw in users, with backgrounds featuring neons and pastels. The competition arenas are far too brightly colored to be mistaken for anything resembling a professional gymnastics arena, further adding to the appeal for children. Players are also able to customize the arenas to their own preferred color palette and style.
The animated characters are also visually appealing to children with cheery expressions, glittering eyes, and exaggerated facial features. The characters’ hair, nails, makeup, and clothing can be customized with many bright colors, glitter, and sparkles.
Even the loading screen is a rainbow of neon colors, drawing in children to continue playing the game as the next section loads.
Several upbeat songs are available for the user to choreograph their routines to. The audience can be heard cheering in the background during competitions, encouraging the user to continue playing. When a medal is won in a competition the player is able to interact with the medal by putting it on their character, further engaging a child with the action and rewards from the game.
The scoreboard is updated after a competition has been completed and whistling fireworks are shot off to celebrate an increase in the ranking against other players. The combination of visual and audio rewards used in Gymnastics Superstar is exactly what a child needs to stay engaged.
Gymnastics Superstar is rated as 12+ on the Apple App Store and Teen on the Google Play Store. However, the language and phrasing in the app description reflects the developer’s intent of targeting a younger audience. Younger children would be drawn to sentences in the description such as, “WOW. Your dream has come true” and “OMG! Golden Gymnast magazine asked you to be on their cover! Photo shoot, here you come!” The characters' conversations within the app are similarly written in a way that would entice younger children to engage with the story.
The reviews on both app stores indicate children under 13 are commonly using the app. There are a few reviews from parents indicating that their children are using the app, but many reviews seem to be written directly by the children themselves. The developers have even responded to some of these reviews from minors, indicating that they are aware that children are commonly using the app, despite the 12+/Teen ratings on the app stores.
There is quite a lot of advertising, with similar ads shown on the iPhone and Android apps. Every advertisement that I saw was for another app. Most of the advertised apps were other child directed or mixed audience apps. There were occasional apps that were more general audience, including a few romance based role-playing/story apps that did not seem child-friendly.
Privacy
According to the privacy policy, which was last updated on May 5, 2021, “we operate Apps for all ages” and the developers have included a dedicated children’s privacy policy included as part of their overall privacy policy. They do indicate that they collect non-personal information from children that they share this with third parties. The privacy policy does indicate that any user under 18 should have a parent or guardian review the policy and minors should not install the app if their legal guardians do not agree to the privacy policy. Despite this indication, Gymnastics Superstar does not have an age gate to check the age of the user or to obtain verifiable parental consent for a minor to use the app.
Screenshots of Gymnastics Superstar
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.
