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 Store & Apple App 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).
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.
Logic Art combines logic puzzles and pixel painting in an engaging app that is appealing to both children and adults. Players start with blank grids with numbers along the top and side. The numbers indicate how many blocks are shaded in each row and column. A brief tutorial makes it easy for anyone, including children, to learn how to solve the puzzle. Different levels have grids of different sizes, with the larger the size the more difficult it becomes.
After shading in the correct blocks a picture is revealed, with more difficult puzzles making larger and more complex pictures. The pixelated style of the images not only works well for the grid style of the logic puzzle but is also an art style that is very appealing to children, similar to the type of graphics found in Minecraft.
The app itself also balances the line of being visually appealing to a mixed audience, with a variety of colors and shapes on the home screen and in the background.
There is limited language used during gameplay, with audio and visuals indicating if the user is selecting the correct boxes. However, written instructions are given when first opening the app. Instructions are simple and clear to understand, making it easy for players of all ages to understand how to play. Descriptions such as, “adorable pixel arts,” do seem geared more toward children than adults.
Background music and sound effects help keep children engaged in the app. Although there isn’t a lot of action for sounds to accompany, a bubbling sound is played each time a box is colored in, and celebratory chimes are heard when a row is completed correctly.
Completing the puzzle to reveal the hidden picture is the primary incentive for the game, appealing to users of all ages. Ad-free play time can also be earned by playing for so many days in a row. After the specified number of days, players can earn 1 hour, 6 hours, or 24 hours of ad-free play time.
Numerous video ads are played in the app. The ads are played at natural transitions between levels, but also sometimes pop up in the middle of playing a level. Additional ads must be viewed to continue playing if the set number of lives has been exceeded. Banner ads are also displayed across the bottom of the screen. All of the ads target a wide mixture of audiences, with most being mixed audience games and apps. However, parents should be aware that some of the general audience ads might not always be appropriate for children. On the flip side, there are also some child-directed ads, making the target audience a bit confusing to discern.
Logic Art is rated E for everyone in the US Google Play Store, PEGI 3 in the European Google Play Stores, and 4+ in the Apple App Store. There is no indication of a target age range in the description and most reviews don’t mention ages in any way.
When first opening the app it does ask users to agree to the privacy policy, as well as confirm they are over 13. However, this is all grouped together and might be easy to miss and no age gate is present to ensure users are over 13 and no parental consent is collected.
Privacy
Furyu has several different privacy policies linked, depending on which app store it is linked from. The linked policies in the Apple (last updated March 10, 2022) and Google Play (last updated February 19, 2024) stores are both written in Japanese. The privacy policy housed in the app is written in English and was last updated in March 2022. Although the privacy policy in the app and the one on the Apple store were last updated around the same time, they are not identical.
Despite the differences in the privacy policies, the policies are similar. The linked policy in the Apple App Store mentions collecting “device information, OS version, location information, behavioral history, play information, cookie ID, advertising identifier, etc.” This policy also mentions that they only share information for legal, safety, and academic research purposes. The linked policy from the Google Play store and the one in-app mention similar data collection, with the Google one adding more details about sharing information with advertisers for targeted advertising.
The policy linked in the Google Play store does not mention children in any capacity. The linked policy in the Apple Store does mention obtaining parental consent to collect information from minors. This is not elaborated upon and no parental consent is obtained in this app, with the only check being small print about being over 13 lumped in with the agreement to the privacy policy.
The in-app privacy policy also states, “Since we do not sell the Personal Information, we are not required to procure opt-in for collection of the Personal Information from children under the age of 17." This statement does not align with COPPA or GDPR requirements which does not just limit the selling of personal information from minors, but the collection of this information as well (minors are considered under 13 for COPPA in the US and under 16 for GDPR in the EU).
Find Pixalate's full catalogue of reviews in our CTV and Mobile App Review Page
Screenshots of the games:
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.
