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Mobile App Manual Review under COPPA Rule: ‘Kids Coloring Game'

Apr 12, 2023 2:00:00 PM

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 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).

Manually reviewed in this post

 

The 10 COPPA Rule factors

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.

Reviewed by: Crystal Pearson

Crystal Pearson

Manual Review: Kids Coloring Game

Likely audience after manual review

COPPA factors used to determine audience

and and

The gameplay screenshots for Kids Coloring Game are visually appealing to kids who love to color.  Subject matter discusses useful and educational information that would be likely to excite a parent enough to download the app for their child. The age of the models in the game and coloring pages are toddlers. The description in the “about this game" section of the Play Store states “Our kids coloring game are excellent for teaching toddlers and preschoolers new skills….perfect for preparing 2-5 year old children.” This suggest that this game appeals to children.

The app offers a great way for kids to express themselves so that it helps them learn the skill of patience. There are educational games such as matching which is a paid version of the app. This type of app is good for children to relax and process emotions, train their brain to focus, and is also a good tool to help them develop hand and eye coordination.

This app has an Everyone E rating in the Google Play store. There is evidence of children using the app based on some of the user reviews in the Google Play Store. One review from September of 2021 mentioned “... The app is fantastic for my 2 year old who loves to draw/color."  It was from a parent who specified the age. Another review from July of 2021 said, “My little brother loves this game, he want stop playing...”  This review was from a sibling who did not specify the age of his brother.

Privacy:

The developer’s privacy policy was last updated in May of 2022. The policy states, “are designed for the use of children. "  There is no age gate or parental control after downloading the app and opening it.

Screenshots of Kids Coloring Game:

 

About Pixalate’s Trust & Safety Advisory Board

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.

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