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Mobile App Manual Review under COPPA Rule: 'My Town Home: Family Playhouse'

Mar 16, 2023 11:00:00 AM

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 (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).

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: My Town Home: Family Playhouse

Likely audience after manual review

COPPA Audience - Child Directed

  • Developer: My Town Games Ltd
  • Bundle ID: mytown.home
  • Privacy Policy
  • Crystal’s Take: Fun stimulating game that allows you to choose characters for the virtual family you create and  play house with family games that uses child oriented interactive activities.

COPPA factors used to determine audience

and and and subject matter

The gameplay screenshots for My Town Home: Family Playhouse uses language that is child directed, and bright visual animation that includes family pets, doll house, small town, kids and toys that would appeal to children. The description in the “about this game" section of the Play Store states “my home town game is all about kids and their creativity and imagination”. It features “play with toys or swing or slide in the playhouse playground”. The subject matter would suggest that this game appeals to children.

During gameplay, ads appear when you need to take a spin when you are creating a family scrapbook. The ads are numerous kinds of ads and you have to wait until it finishes playing in order to continue playing the game. The ads are child directed, such as, “Frosted Flakes have a different flavor of cereal.” This advertising would appeal to children.

This game has an Everyone E rating in the Google Play store. There was evidence of children using the app based on some of the user reviews in the Google Play Store. One review from September of 2022 mentioned “...I love this game me and my granddaughter have been playing for a couple of years now."  It was from a grandparent who referred to the granddaughter using the app although there was no specification of age. A review from March of 2021 mentioned  “...My daughter Holly loves this, she gets creative with it, and she was thrilled to play this on her ipad.”  This was from a parent with no age specified.

The target audience for this game is children. In the “about this game,” it says the recommended age is 4 -12.

Privacy:

The developer’s privacy policy was last updated on July 18, 2022. The policy states, “it does not actively collect information from children. "  There is no age gate. The rating in the iOS app is 4+  made for 6-8 and E for Everyone in the Google Play store.

Screenshots of My Town Home: Family Playhouse:

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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