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 from both the Google Play Store and 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.
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My Town Hospital is a creative, role-playing game, similar to how a child would play and interact with dolls or action figures. App users can navigate around a very cheery hospital, entering different rooms and interacting with the characters and objects in each room. There is minimal text when navigating through the app, allowing children that cannot yet read to navigate the hospital using the symbols on the door to each room.
Each room in the hospital provides a different experience for the player, from feeding a newborn to administering an MRI. Rather than having users move through a pre-made story, this app encourages children to use their imagination and create their own story.
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The animated characters and hospital scenes are bright and cheery. Despite the fact that many of the characters are patients in a hospital, the default facial expression is a big smile. Users can adjust the facial expressions to fit the story they are creating, but even the less-happy looking expressions still have a happy, cartoonish quality that would appeal to children. When a new facial expression is selected, accompanying sounds are played to express the appropriate emotion.
Most of the objects in each room can be interacted with and they each present an accompanying sound when clicked, such as a heart monitor beeping after being attached to a patient or the sound of running water when a sink is turned on. The sounds encourage younger children to continue to interact with the app, and help them learn which objects are able to be manipulated while playing.
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The intention that children are the target audience of this this app is indicated within the app description; “My Town Doctor game for kids aged 4-12. All My Town playhouse games are safe to play even when parents are out of the room.” This targeted audience is also reflected in the reviews. Many of the reviews are from children writing about their own experiences with the app, while other reviews are from parents. The reviews reflect a wide variety of ages of children using this app.
My Town Hospital does contain several different types of advertisements. Banner ads are always present on the top of the screen, advertising general audience products and services, such as wealth management and dentists. Video ads play at regular intervals when switching rooms in the hospital. These video ads appeared to be more child-oriented, advertising other child-directed apps and snacks geared towards children. Finally, on the main screen seen before entering the hospital, there are advertisements along the left hand side and bottom right corner for other games by the same developers.
Privacy
According to the privacy policy , which was last updated on July 18, 2022, My Town Games “acknowledges that our games are meant for young children” and that their app “does not actively collect any information from children.” However, further down in the privacy policy they clarify that they do not collect any personal information from children, but they do indicate that they pass along non-personal information to their advertising and analytics partners.
Screenshots of My Town Hospital - Doctor Game:
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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Disclaimer: The content of this page reflects Pixalate’s opinions with respect to the factors that Pixalate believes can be useful to the digital media industry. Any proprietary data shared is grounded in Pixalate’s proprietary technology and analytics, which Pixalate is continuously evaluating and updating. Any references to outside sources should not be construed as endorsements. Pixalate’s opinions are just that - opinion, not facts or guarantees.
Per the MRC, “'Fraud' is not intended to represent fraud as defined in various laws, statutes and ordinances or as conventionally used in U.S. Court or other legal proceedings, but rather a custom definition strictly for advertising measurement purposes. Also per the MRC, “‘Invalid Traffic’ is defined generally as traffic that does not meet certain ad serving quality or completeness criteria, or otherwise does not represent legitimate ad traffic that should be included in measurement counts. Among the reasons why ad traffic may be deemed invalid is it is a result of non-human traffic (spiders, bots, etc.), or activity designed to produce fraudulent traffic.”