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. 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.
Pets Frenzy TV aims to teach users about different kinds of pets. The videos are primarily specific to various breeds of dogs, but other pets are featured as well. There are also more general videos, such as dogs in costumes. Most videos are educational and include dialogue between puppets to engage younger viewers.
Besides the cute pets that are featured in the videos, there are also puppets. The app description indicates these puppets were made by the creator’s 12-year-old son. The logo is also visually appealing to children, created to look as if it were hand-drawn with markers. The puppets, app logo, and virtual backgrounds make it clear that the audience is primarily children.
The language is clear and simple, appealing to children. Dialogue and conversations are often used to present information engagingly. The puppets are voiced with cartoon-like voices and often real videos of pets are given voiceovers to make it appear as if the dogs or cats are speaking. When the actual video creator is shown, she is often speaking directly to the pets, more so than the pet owners. An example of this is when she asks a dog where its “mommy” is, rather than asking who owns the dog. The vocabulary she uses and the way she speaks is far more appealing to children than to adults.
The app is essentially pulling videos from a YouTube channel, so the typical advertisements for the next video appear after a video has been watched. Within each video, there are sometimes advertisements, primarily for downloading the Pets Frenzy TV apps. Several of these ads mention a Roku app, but at the time of writing this blog, it does not seem that they currently have a Roku App.
Additionally, some of the videos have sponsored advertisements for other pet-related items. For example, QR codes link to online stores to buy pet food, toys, and costumes. These are not in-app advertisements, but rather part of the videos themselves.
The app description specifically says, “To be legal, we did not make this channel for kids, but we promise to keep this channel family-friendly as we expect kids will watch this.” This indicates that they expect this app to be child-directed. The description further indicates a child-directed nature by mentioning how the puppets were created by a 12-year-old and how “Pets keep your kids entertained and learning about responsibility.”
The app does not have any reviews to indicate the audience composition.
Privacy
There is no privacy policy linked to the Amazon App Store. Inside the app, the ‘About' section contains a generic statement about the app using Amazon software and YouTube API services, indicating that using the app is agreeing to both Amazon and YouTube terms and privacy. They provide an external link to these policies but give no additional information or mention of their privacy policy.
That being said, a privacy policy can be found on the Pets Frenzy TV website which says it applies to their website, Facebook page, "or any other application of ours that links to this privacy notice.” As this specific app does not link to this privacy notice it is not clear if this applies to the app or now. However, I thought it was worth looking at and mentioning as it does seem to be associated with the developer and channel creator. It does state that by using the app users are “represent[ing] that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services.” However, there is no age gate or parental consent to enforce this within the app. This is directly in conflict with the app description, as mentioned above, stating that they expect children to be using this app. However, the privacy policy does seem to indicate that the information collected is information that is provided directly to the app (such as usernames and information to create accounts that are not needed to use the app). It does not mention collecting any additional information, such as location data, device information, or IP addresses.
Find Pixalate's full catalogue of reviews in our CTV and Mobile App Review Page
Screenshots of Pets Frenzy TV
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.
