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 game (1 million+ downloads) 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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The gameplay screenshots for Unnie Doll show that the visual content is directed to a mixed audience. This is a bright and fun game that allows the player to create dolls that reflect imagination and creativity. When you are finished designing your doll it can be used as an emoticon or mobile wallpaper. The description in the “about this game" section of the Play Store states “You can make your own girl character in the world.” It features “luxury costumes, concert costumes and halloween costumes”. The subject matter would suggest that this game appeals to children as well as adults.
During gameplay, advertisements appear when you complete a character. Ads are also at the top bar of the game and they are continuous at the top. The ads are mixed audience directed, such as, “Harry Potter- Puzzles and Spells, Tap to build.” This advertising would appeal to children. The ads that would appeal to adults are at the top, such as “ Instacart and Huggies.”
This app has an Everyone E rating in the Google Play store and rating of 4+ in the Apple store iOS. There was evidence of children using the app based on some of the user reviews in the Google Play Store. One review from August of 2019 mentioned “...I love this game, I got this game for my daughter when she was 6, she is now 7 and she loves it so much." It was from a parent who specified the age.
Privacy:
The developer’s privacy policy was last updated in March of 2021. The policy states, “You will accept full responsibility for any unauthorized minor use. " There is no age gate.
Screenshots of Unnie doll:
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.
