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 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.
Lullaby Songs for Sleep hosts a collection of 24 lullabies to help babies relax and fall asleep. In addition to the lullaby songs, there are also nature sounds that can be played to help lull a baby to sleep. While it might be expected for a parent to open the app and start the songs playing, it is highly unlikely that an adult would be using this app without a child nearby. The app is easy enough to navigate that most toddlers would be able to select a song and play it on their own.
The main focus of the app is the music, which is soft and relaxing to help babies fall asleep. Some of the lullabies are familiar, such as Twinkle, Twinkle, Little Star, and Brahms Lullaby. Other songs might be unfamiliar, but equally calming. As mentioned above, there are also natural sounds, such as ocean waves and rainforest noises. These provide more of a white noise background to help block out other noises while sleeping.
The music continues to play even if the app is closed, with the music continuing to play in the background of the device even if other apps have their own sound.
While each song is playing, a static image is displayed on the screen. These are all very child-directed images, featuring cartoon babies, animals, and night skies. While most users would likely only be listening to the music, the app does provide visual stimulation for young children if they are holding the phone with the app open.
A banner ad is consistently present at the bottom of the screen. Pop-up ads and occasional video ads appear at random. The video ads do have sound which is played over the music from the lullabies playing in the app.
All of these advertisements seem to be general audiences, often for local businesses, reflecting a collection of location data. Users are also encouraged to approve the Apple prompt for target advertising to keep the app free. However, users are free to approve or deny the targeted advertising through the prompts from their Apple devices.
Lullaby Songs for Sleep is rated 4+ in the Apple App Store. The description specifically mentions babies, children, and infants and how this app can help them fall asleep. App reviews reflect this use with reviews from parents and grandparents that have been using the app with their children/grandchildren.
Privacy
The privacy policy, which does not have a publication date, does not specifically mention children in any way. The policy states that they use third-party services to collect data such as IP addresses, diagnostic and analytical information, performance data, device IDs, advertising data, and user interaction information. The developers also use their cookies, in addition to cookies used by the third parties that they work with. They indicate that they do not store any personal information but that the third-party services they work with do use and store “some identifiable information.”
Find Pixalate's full catalogue of reviews in our CTV and Mobile App Review Page
Screenshots of Lullaby Songs for Sleep
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.
