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. 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.
Twinkle—Unicorn Cat Princess is a virtual pet care game in which players tend to the needs of a unicorn cat. The player must ensure Twinkle’s needs are being met by feeding, bathing, playing, sleeping, and even making sure Twinkle uses the bathroom. These needs pop up fairly regularly, ensuring that children are continually interacting with the game, but they would feel rather repetitive to an adult.
In addition to taking care of Twinkle’s needs, players can choose Twinkle’s clothing, decorate her room, and play mini-games with her.
Twinkle, the main character of this game, is a sparkly, purple unicorn cat with rainbow hair and a rainbow tail. Her features are very appealing to children, with huge eyes that can be customized to the color of the player’s choosing, including rainbow colors. Twinkle ages as the player progresses through the levels; growing new features, like wings, as she gets older.
The interactions with Twinkle are also very visually appealing to children. The rainbow-colored shampoo is featured when giving her a bath, food items like donuts with pink frosting and sprinkles can be fed to her, and animated sheep clouds dance around Twinkle while she is sleeping.
Icons in speech bubbles indicate what Twinkle needs so that pre-readers can interact without text. For example, if she is hungry a knife and fork appear in a speech bubble to prompt the user to feed the cat. Matching icons can be found along the top of the screen to easily navigate around the app to meet Twinke’s needs.
When additional explanation may be needed, verbal instructions are also given. Verbal commentary and praise are also present throughout the app. The phrasing of this commentary is very child-like and often speaks directly to the player such as, “What a happy little munchkin, thank you.”
The background music is appealing to children, upbeat and kind of twinkly sounding. Numerous sound effects throughout the game further engage children, such as chewing sounds when feeding or flushing sounds after using the toilet.
As Twinkle’s needs are met she celebrates birthdays, which signal that a new level has been achieved. Reaching new levels unlocks new ways to interact with Twinkle and new items that can be used in the game.
Completing tasks also earns coins. These coins can be used to purchase a wide variety of additional items to use while playing the game, such as room decorations or food to feed Twinkle.
Video ads are the primary form of advertising in this game, and they are shown quite often. They are mostly played during transitions between scenes, but occasionally play in the middle of tasks or in other non-transition times. These ads are mostly for other child-directed games but also are occasionally for general audience items and services. Additional video ads can also be watched to earn extra coins or game items.
The start screen has a small icon advertising other child-directed games from the same developer, clicking redirects users to the app store to download the advertised app.
In the top right corner is an advertising button that prompts users to pay to eliminate the ads. This button can be very easily pushed on accident and could trigger an accidental purchase. While testing this app, my Google Pay popped up several times without me realizing that I had clicked this button. It seemed like the only reason the purchase did not go through was that I did not have a payment method linked to the account to make a purchase. It did not seem that there were steps in place to avoid accidental purchases by children.
Twinkle - Unicorn Cat Princess is rated E for Everyone in the US Google Play Store and PEGI 3 in the European Google Play Stores.
The description makes it very clear that this app is intended for children. It includes an “Important Message to Parents,” implying that children will be playing the game and not adults. The description also contains information about the developer saying, “Crafted and play-tested with kids and toddlers, TutoTOONS games foster kids’ creativity and help them learn while playing the games they love. Fun and educational TutoTOONS games strive to bring meaningful and safe mobile experiences to millions of children worldwide.”
The reviews also reflect primarily children using the app. Most reviews seem to be written by parents, detailing that their children are the ones playing. There are also numerous reviews written by children as well.
Privacy
TutoToons provides an easy to understand privacy policy, which was last updated on June 4, 2024. They state that “we’re not in the business of collecting personal information like full names, addresses, or contact details. Our focus is on providing a wholesome and safe digital space.” They go on to explain the information that they do collect including, “general data, such as the country of residence, time spent in our games, and the types of devices being used. Fear not, this information is aggregated and anonymized – it's more like statistical puzzle pieces than individual profiles. This data aids us in understanding our audience better and refining our games.” They also explain that they have a team that ensures the in-app advertising is child-friendly and that advertisers do not collect any personal information from the children playing. They indicate that their privacy policy is compliant with both COPPA and GDPR.
Find Pixalate's full catalogue of reviews in our CTV and Mobile App Review Page
Screenshots of Twinkle - Unicorn Cat Princess
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.
