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 the Google Play and 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.
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Stupid Zombies is a game where players step into the role of zombie hunters and try to kill zombies. The zombies don’t move at all and are positioned across the screen with various platforms, walls, and items in the way. The player must aim the gun and fire in a way that ricochets off the obstacles and hits as many zombies as possible. There are additional items in the way that can be hit that either explode or fall on top of zombies to help kill them. The teacher in me would even argue that this game could almost be considered educational, as players have to think about how the angles they are shooting at the influence the direction of the bullet as it bounces off obstacles in its path.
The zombie subject matter and the title, “Stupid Zombies” reflects more of a child geared game, although many teens and adults would also be interested in this content matter. There is very little text within the app itself, just indicating what level the player is on as they progress through the game. The wording of the app description is brief and to the point, drawing in children with the tagline “One man, one shotgun... and lots of stupid zombies.”
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The game has a simple haunted house-esque background that adds a bit to the creep factor. Multiple animated zombies stand in increasingly difficult to get to places. There is no customization available for the shooter character, it is just a simply animated man that looks ready to tackle a zombie apocalypse. The zombies and the characters are not able to walk around and move across the screen. The only movement possible is the shooter moving his arm to aim the gun and the zombies falling upon getting hit.
As the Zombies die, their heads often fall off and they sometimes land in piles with their feet sticking out in weird directions. There is occasional green goo sputtering out of the dead zombies. As gruesome as this sounds, it is a simple and non-gory animation; exactly the type of ick factor that is perfect for 9 -12-year-olds without being too over the top.
The sounds in this app seemed to be designed with adolescents in mind. The zombie groans can be heard in the background throughout the levels, further enticing users to shoot them. The bullets can be heard pinging off the walls and squishing noises can be heard when zombies are shot or something falls on top of them. Like the visuals, the sounds are not gory but instead, provide just the right amount of grossness for younger players to be attracted to.
Upon completion of each level, a celebratory sound is played and a star rating is given based on how many attempts it took to kill all the zombies. Users have the option of replaying a level if they want to earn a higher rating. High-score alerts are also given to incentivize the player to retry levels in hopes of killing more zombies in fewer attempts.
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The Apple app store gives Stupid Zombies an age rating of 12+ for “Infrequent/Mild Horror/Fear Themes” and “Frequent/Intense Cartoon or Fantasy Violence.” The American Google Play store rates the app as Everyone 10+ for “Fantasy Violence, Mild Blood,” while the European Google Play stores give a PEGI rating of 7 for “mild violence.”
Reviews indicate a mixture of children and adults using this app. Several user reviews indicated they used to play the game when they were younger, some as young as 4 or 5 years old. It does seem the current children using the app seem to range in age from about 7-12 years old.
Video advertisements are shown occasionally throughout the play. Ads are usually shown if a player replays a level, either because they ran out of bullets or if they want to try and achieve a higher score. Ads are also shown occasionally before starting a new level, although they are not shown each time the user progresses to the next level. Video ads are a general audience, usually for other mobile games or applications.
There is also an advertisement on the home screen for another Stupid Zombie game by the same developer. Clicking on this advertisement opens the app store to download the game.
Privacy
GamesResort indicates in their privacy policy that their games are not intended for children under 13, despite the appeal of this app to those under 13. They indicate that they do not collect any data from children and that minors should have parental permission before playing. However, there is no age gate or verifiable parental consent collected within the app to determine a user's age and get parental permissions. As the developers do not know the age of the user, they are still collecting personal information from every user. The full list of the information they are collecting is detailed in their privacy policy, but they do indicate they collect and sell personal identifiers, location data, and network history. They also indicate that they create profiles about users based on the information they collect and they do sell these to third parties. They again indicate that they “do not knowingly sell the PII of minors under the age of 16 without authorization.” However, the one piece of information they are not collecting is the age of the user to know if they are under 16.
While the game might be appealing, the privacy policy does leave something to be desired. Parents should consider this before allowing their children to download this app.
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.
