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 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.
Toon Goggles is primarily a video service directed at children. They have a variety of on-demand videos, as well as live channels. Numerous videos are centering around different subjects and interests including gaming, cartoons, songs, educational, and more. Well-known names such as Baby Einstein, Angry Birds, and Transformers are featured. The videos vary in length, some as short as 10 minutes ranging up to feature-length movies.
The app itself is easy to navigate around with a bright blue background and childlike fonts displaying the titles of the video channels. Thumbnails are prominently displayed so that children that can not yet read can navigate on their own.
Most of the videos are animated, featuring a variety of different animation styles. Some of the animated videos are very simple with eye-catching animation and limited language for babies and toddlers. Other videos contain more sophisticated animations and language that appeal to older elementary-aged children.
While most of the videos are animated, there are a few gaming walkthroughs and other live-action videos. These almost exclusively feature children that appear to be under 13.
The Amazon App Store description also includes mention of kid-friendly radio and music. However, this seems to be an old feature that is no longer available. Music is not indicated in Roku, Samsung, or mobile app store descriptions and it is not included in the Firestick app. It seems that the app has been updated but the updated description was not uploaded to the Amazon App Store.
Video advertisements play before each on-demand video plays. Ads are for both child-directed products, such as movies and games, and general audience products, such as insurance and travel. The advertisements on TV apps tend to be a more general audience, while the advertisements on mobile apps tend to be more child-directed.
The app description makes it clear that the developers intended this app to be child-directed. Most of the app store descriptions include, “100% Kid-Safe and parent friendly” and “our service is kidSAFE Certified, and strictly follows all COPPA rules and CARU guidelines.” While the Amazon App Store does not mention COPPA compliance or use the same language as above, it does still indicate that the app is “perfect for kids of any age.”
The targeted audience is reflected in the reviews, with most reviews from parents indicating that their children or grandchildren are the primary users of the app. There are also several reviews from children indicating that they and their younger siblings use the app.
Privacy
According to the privacy policy, which was last updated on April 13, 2020, Toon Goggles does collect device information and identifiers for operational purposes. They do not require users to provide any personal information to use the app and would only receive this information from children if they contact the developers. They do indicate they collect personal information from parents that subscribe to premium accounts. While they do utilize ads, the privacy policy indicates that they do not use targeted advertising.
Screenshots of Toon Goggles - Cartoons and Music for Kids
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.
