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CTV App Manual Review under COPPA Rule: ‘Nat & Essie'

Sep 19, 2024 2:00:00 PM

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 Amazon Fire TV App Store and the Roku Channel 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).

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: Tabitha Walker

Tabitha Walker

Manual Review: Nat & Essie

Likely audience after manual review


COPPA factors used to determine audience

Nat & Essie is an app that pulls together videos from the Nat & Essie YouTube channel for easy viewing on Amazon Fire TV and Roku devices. The videos are primarily toy unboxing coupled with creative play. An unseen person unboxes different toys and then seamlessly introduces them into the collection through play.

In addition to the unboxing videos, some videos are more educational, as well as some gaming videos (mostly Roblox). Each of the different types of videos is geared towards children, appealing to a broad spectrum of interests.

The main visual focus is the different toys, usually against a neutral wall as a background. Visible hands move the toys around, but there aren’t any other effects added to the videos. This helps focus on the creative play nature of the app and helps cement its appeal to children.

It isn’t initially clear if Nat & Essie are kids or adults, although it does seem to be an adult narrating the videos and moving the toys around. This was confirmed by some digging around online to find that Nat & Essie are two moms who run the channel together.

That being said, their children do occasionally pop up in some of the videos. For example, an educational video teaching about different body parts features a little boy who seems to be Nat or Essie’s son.

The language used in the videos is simple and engaging for children, with phrases such as, “Super cool, right?” The narrator frequently speaks directly to the viewer, encouraging audience participation. Items are often counted out to encourage learning, such as saying, “There are 1, 2, 3, 4 chairs” instead of just stating there are four. When playing with the toys, different voices are given to the variety of characters, modeling this type of play for children to try themselves.

There does not appear to be any external advertising, and the next video just automatically plays after the previous one is complete. The only advertising within the channel seems to be a prompt embedded at the end of each video encouraging users to like the videos and subscribe to their YouTube channel.

and

The Roku and Amazon app stores have slightly differing descriptions for this app. However, they both are clear that children are the intended audience. The Amazon store states that the app is a “family & child-friendly YouTube channel” and the Roku store mentions the app, “teach[es] kids important things like colors and words.” Both descriptions also center around toys, further showing the child-directedness of the app. The App is rated “All Ages” in the Amazon App Store and is present in the “Kids & Family” category of the Roku App Store.

There are not enough written reviews to determine the composition of the audience.

Privacy

According to the privacy policy, which was last updated on April 22, 2024, Future Today indicates that they do adhere to COPPA rules. They also state that “Viewers under the age of 16 must use the Future Today Inc. sites under adult supervision.” However, there is no age gate or other check in place to ensure that an adult is supervising a child on the app. The developers do indicate that they collect personal information including, “IP address, device and advertising identifiers, first name and last name, usage data and other information obtained with cookies and similar tracking technologies.” They also indicate that they share location information with advertisers.

Find Pixalate's full catalogue of reviews in our CTV and Mobile App Review Page

Screenshots of Nat & Essie

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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