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 on Google Play Store with over 1 million+ downloads. 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 Pegasus Flying Horse Simulator has app language directed to a mixed audience, and visual content with animation that includes computer-animated images of unicorns, pegasuses, wizards, dragons, and other imagery that would likely appeal to children. The description in the “about this game” section of the Play Store explains that the user can turn into a “beautiful Pegasus and start adventures.” The features “your own magic animal, that you can feed, ride and play with!”
Music during game play has sounds of the forest and rivers. It’s soothing and would appeal to a mixed audience.
People of all ages would enjoy the game, which is to finish all of the quests by looking for treasures and magic flowers while fighting wizards and dragons. The app store description says, "Survival is not easy - create a strategy to support your horses.” The game’s incentive structure is challenging enough that older teens and adults would also be interested in playing it.
During gameplay, before the game loads, ads pop up. The ad that displayed in my sample play was Jungle Parrot Simulator; however, you can click the “X” to the left and it disappears. When you choose either mission or survival to play the game an ad pops up with an adult discussing how great it is to play the game, “Royal Match” (a matching puzzle app directed to everyone). This ad continues to show throughout the game. This advertising would appeal to a mixed audience.
This game has a Teen rating in the Google Play store. I saw evidence of both adults and children using the app based on the user reviews in the Google Play Store. One review from June of 2020 mentioned “...I’m a child.” Another review from July of 2021 was from a parent who referred to her daughter using the app although she did not specify her daughter’s age.
Privacy
The developer’s privacy policy does not indicate when it was last updated and it does not state how it treats personal information of children under 13. The policy states, “it does collect personal information and share with third party providers.” The app's privacy policy does, however, share link one and link two to opt out, but states that it may not reach all advertising partners and may still show targeted advertising.
Screenshots of Pegasus Flying Horse Simulator:
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.
