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 Google Play & 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).
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.
Stumble Guys is a racing game where players’ avatars race through a variety of different obstacle courses. Games are played live with players competing against others in real-time, which fuels the competitiveness of the play and makes no two games alike. Obstacle courses center around a variety of themes, such as running across spinning logs in a jungle or slipping on the ice with giant snowballs trying to flatten the players. Many of the courses are elevated in the air but if the player stumbles and falls off course it is not game over, they are just placed back at a designated spot to try again. As the title suggests, it is inevitable that most players will stumble and fall at some point during the race but this does not prevent them from crossing the finish line.
Each round ends after half of the players cross the finish line. These players go on to the next round, where half are once again eliminated. The final round is the true race to the finish, with only one player allowed to win. There are three rounds together and the further you make it the more stars you win. These stars can be used to earn new avatars and other customization pieces that can be used while playing the game. These customization items are rated as common, rare, or epic to further incentivize and appeal to players.
Stumble Guys is visually appealing to children with lots of bright colors and visually exciting obstacle courses. Although the player starts out with only one animated avatar option, additional avatars are quickly earned through playing. There are hundreds of different avatar options ranging from cute animals to fierce wizards. They are all similarly shaped and are simple, child-friendly animations.
The sounds and music are very similar to what would be expected in a children’s video game. Energetic music encourages players to run through the courses and boinking noises indicate jumping.
Video advertisements are played after a race has ended and optional video ads can be viewed to earn additional prizes. These ads are primarily for other mixed-audience games and apps.
Stumble Guys is rated E in the US Google Play Store, PEGI 3 in the European Google Play Stores, and 9+ on the Apple App Store. While the app description doesn’t specifically mention children, it does use very child-friendly language such as, “Dive into a series of ridiculous challenges and bizarre obstacles, knock down your rivals, and overcome everything to win!”
While there are not many reviews indicating the ages of users, there are many reviews from parents indicating they downloaded the game for their children and reviews that seem to be written by children.
Privacy
According to the privacy policy, which was last updated on October 1, 2022, the developers do not usually allow children under the age of consent (13 in the United States, 16 in the EU) to play their games. However, they do indicate that they make an exception for Stumble Guys. The privacy policy indicates that “we take additional steps to limit access to certain features of STUMBLE GUYS based on players’ ages, and also limit the personal information collection and sharing of such younger players’ information to only what is necessary to support our internal operations.” An age gate does pop up when first opening the app, so the developers are aware of the age of the players to limit their data collection from that underage.
Screenshots of Stumble Guys
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.
