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 & 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.
Hyper School is a simulation game where users participate in a variety of school-centered activities. Tasks include things such as earning higher grades on tests by cheating without getting caught by a teacher, putting all the children on buses without overfilling each bus, or catching kids while playing tag. These school-related tasks have a high appeal to younger children.
The graphics in the game are simple, with three-dimensional silhouette-style avatars. Brightly colored avatars and backgrounds are appealing to children. Each task has associated animations that indicate success or failure. For example, the buses stretch and expand as children are loaded, but if too many children are put on the bus it explodes and throws the children everywhere.
There is limited language and most tasks can be easily discerned without reading instructions. The language that is used is simple and child-centered, with lots of exclamation marks and speech bubbles. Even the app description is appealing to children by being short and to the point, “Can you cheat without being caught? The teachers are looking for you, but you need to pass this exam! Do what you have to do!”
Keys and coins are earned for completing tasks. Keys can be used to unlock treasure chests that contain coins. Coins are used to buy items for your bedroom. These do not seem to have any use during the tasks, but give another layer of interacting with the app.
Banner ads for general audience services and apps are constantly displayed across the bottom of the screen and are also displayed over the game at the start of levels, only disappearing when the player begins to play. Video ads are played between levels and additional video ads can be used to increase rewards. The ads shown are for a variety of general, mixed, and child-directed apps, products, and services.
This app is rated T in the US Google Play Store, PEGI 12 in the European Google Play Stores, and 4+ in the Apple App Store. The Google Play Stores mention simulated gambling as the reason for a higher rating. App reviews indicate that numerous children are playing this game. Most reviews seem to be written by children but the majority do not mention specific ages.
Privacy
Suji Games Privacy Policy, which was last updated on February 4, 2020, indicates that they do not address or collect any personally identifiable information from users under 13. However, there is no age gate in place for the developers to determine which users are over or under the age of 13. There is a small print upon first opening the app that says, “I accept that my age is older than 16,” However this is not a clear age gate and is buried within consent to privacy policies and targeted advertising, making it very easy to miss. Additionally, users can continue without checking the box to agree to any of the listed terms, including being over 16.
Screenshots of Hyper School
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.
