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 mobile app (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.
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The gameplay screenshots for Lingokids-Play and Learn include images of childlike animated characters, age of models, and illustrations. The sounds are that of animals and kids playing as well as many fun whimsical songs. A lot of the content focuses on early literacy skills and it has interactive educational learning content such as personal hygiene, vocabulary, songs, stories, tracing, and observational skills. The app store description says, “kids can explore exciting adventures... kids can play, learn, and thrive… helping to shape them into curious, life long learners.” The language is child directed and it is subscription based but there is a basic plan free of charge with a few activities per day.
This game is rated E for Everyone in the Google Play Store and 4+ (made for ages 0-5) in the Apple store. There is no age gate but the app does ask for the age of the child when the parent is setting up the children’s profile. There is a parent dashboard where parents can create an account for each child so that the app can tailor the activities to each child while choosing how long their children can play. The app shows evidence that children use the app. In January of 2023, a reviewer said, “the app helps my child to be more confident in speaking at 5 years old.” The review was by a parent and the age was specified. In October of 2022, a reviewer stated, “My child absolutely loves it.” The review was a parent but no actual age was given. In June of 2020, a reviewer stated and specified the age of the child, “My 3 year old loves this app and I love it more.”
Privacy:
The developer’s privacy policy was last updated in June 2020. The policy states, “ We inform you that we may include pop-up ads or advertisements directed at children but only exclusively related to Lingokids products or services. We do not collect any information from children. The only information we collect is from parents.”
Screenshots of Lingokids - Play and Learn:
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.
