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 Monster High Beauty Salon show that the content is visually directed to children with a mixed audience based on the animated characters and images. At the start of the game, you immediately choose a model and create a fun unique fashion look with the beauty tools available. The catwalk music helps set the mood and atmosphere. Players can dye their hair, manicure, perm, assist monster friends with their fashion modifications as the owner fashionista Claudine Wolf, and many other ghostly fashion possibilities. Players need a lot of time and many transformation beauty gadgets that are available in the game. The game has minimal settings. Parents can enable a time limit and completely turn off the music and sounds. There are six sections and each has its purpose. The game is a great way to create a space for creativity. It encourages creative thinking. The description in the “all the fashion girls are ready….the choices are endless like the colors of the rainbow." A section of the Play Store states, “dolls…..dress up….monster girls.” The language and keywords would suggest that this game appeals to children and adults.
The incentive of the game is to create an incredible image with the fashion trends for your clients who are monsters. You choose the right hairstyle, nails, clothes, shoes and more to create distinctive combinations. After you complete each transformation, you will receive a gift to create new images.
The advertisement happens in between each fashion tool used. You can either sign up for in-app purchases or have to watch before you move on to the next beauty gadget such as AI Mirror AI Art Photo Editor which is adult in nature and other games called Grow Island, Covet Fashion, and Fantasy Island. At the bottom of the game, there will be ads such as Chick-Fil-A. The ads are directed to adults but some of the games are directed to children.
The game is rated E for Everyone in the Google play store and 12+ in the Apple Store. There is no age gate. There is evidence that the app is used by children. A review posted in April of 2023 in the Google Play store says, “I downloaded this for my kids, they were so happy.” The review is from a parent but no age was specified. A review posted in the iOS Apple store says, “ Hello I am 7 and I got this game thinking it would be the best game ever.” The review is from a child whose age is specified.
Privacy:
The developer’s privacy policy states, “we hereby prohibit children from actively and directly providing us with any personal information other than specified in section 3.3." Privacy policy also states, “ we and third parties may passively collect a persistent device identifier from children.”
Screenshots of Monster High Beauty Salon
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.
