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 Store and Apple 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.
The concept of Turbo Stars is simple: beat the other skateboarders by crossing the finish line first. The different racetracks contain a variety of obstacles, such as walls and beams, that can either be static or in motion.
Along the way, players can also collect coins and game-boosting items, like spinning swords to knock away opponents. The race course is shaped in a way that the player can do tricks and flips off ramps or the sides of the track. Players can even ride upside down on the ceiling in tunnels and throw opponents that are nearby.
The simple graphics make this game appealing to children. The backgrounds range from space to western themes, with matching racetrack aesthetics. The racing people are just a step up from stick figures, with no defining features other than their bright colors. Animations are smooth but simple, with numerous flips and tricks appealing to children and adults.
The numerous sound effects during gameplay add to the child-directed nature of the game, such as the skateboard landing after jumps and even the simple rolling sounds as the skateboard moves through the course. Dinging can be heard when collecting items along the track and there are cheers when the finish line is crossed. 80s techno music playing in the background nicely rounds out the sounds and matches the graphic style of the game.
Gems, coins, and keys are used as incentives for the game. Gems are earned based on how well the player performs and their final place after finishing the race. They can be used to purchase new avatars and skateboard skins or character emotes.
Coins can be collected along the track during the game and can be used to upgrade speed or to buy a starting boost during a race.
Keys can also be collected during the race. Once three keys are earned they can unlock treasure chests full of coins and gems.
There are video advertisements during transitions, such as completing a level. Additional video advertisements can also be viewed to earn extra incentives. Most of the video advertisements appear to be for other mixed audience games.
The level completion screen also has a small embedded video ad for other games by the developer.
The app description doesn’t specifically mention a target audience and is written in a way that would appeal to both children and adults. The app is rated E in the US Google Play Store, PEGI 3 in the European Google Play Store, and 12+ in the Apple App Store. The reviews reflect these ratings, with numerous reviews written by children.
Privacy
According to the privacy policy, which was last updated on February 29, 2020, Say Games limits their apps to users over 13 (over 16 in Europe). They indicate that accepting the privacy policy is certifying that you are over 13 (or 16 in Europe). However, there is no age gate in place to ensure that children are not accessing the game.
Say Games indicates that they collect device and usage information while users are using the app, this includes location information. They do indicate that they share information with third parties. While they maintain that they do not exchange information for money, the way they share information is “interpreted to constitute a ‘sale’ under the CCPA.”
Find Pixalate's full catalogue of reviews in our CTV and Mobile App Review Page
Screenshots of Turbo Stars
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.
