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 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.
Violet Cinderella Castle Clean manages to combine several app subjects that are very popular with children - cleaning games, princesses, and makeovers. The app follows Princess Violet, who needs to clean her castle so that she can fulfill all of her royal duties and attend the ball. Violet guides users through the different rooms in her castle as they go from dirty and drab to clean and shining. After cleaning up the mess, users are able to refresh paint and add new furniture or items to give the room a makeover. Once the castle is clean, users can help Violet select a dress and get ready for the ball.
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The instructions use simple language, ensuring that young users can comprehend. For children that are not yet reading, there are easy to follow animations that show what they need to do to help Violet clean her castle. Rather than saying the names of the cleaning products, Violet has cute nicknames for each item (Mr. Noisy the vacuum, Lady Feathers the duster, Mr. Hat the mop). The cleaning actions are simple and involve swiping back and forth on the screen, easy for toddler fingers to follow.
The castle itself is very appealing to young children with lots of bright pinks and purples and makeover-esque items, such as nail polish and ball gowns. The landscape around the castle is filled with purple and blue trees with a light purple sky. Violet even has bright purple hair. When selecting a level to play, the room to be cleaned is shown inside a purple pumpkin, reminiscent of Cinderella's pumpkin carriage. While cleaning, a star wand directs what part of the room to swipe on to clean up.
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Upbeat music plays in the background of the entire game. As an object is cleaned or put away, accompanying sounds motivate the user to continue playing. Small chimes are played when putting an object where it belongs and loud chimes and stars are awarded for finishing a specific cleaning task (i.e. mopping the floor or dusting the cobwebs). Each cleaning action has an accompanying sound to mirror the real action (i.e. vacuuming, spraying cleaning solution). As the game progresses there are multiple levels per room, with the last level in the room being an incentive task, such as decorating cookies or a relaxing bath.
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Most of this game is guided clicking, making it most suitable for young children. There are no options or choices for users to select, and each cleaning task must be done in the specified order. Older children and adults would likely bore easily after a couple rooms. I would say this game would most appeal to children under the age of 5.
Banner ads are present across the top of the screen and video ads are played after completing a level. Both types of advertisements are for general audience items such as anti-virus software and internet service providers.
Privacy
According to the privacy policy, Winky Pinky does not collect any personal information but rather collects “the minimim information possible so you can be safe.” The spelling errors, typos, and general vagueness of the privacy policy do not instill confidence in this privacy policy. Winky Pinky indicates that they collect “a general location of the user, no city name or street name is collected” but do not indicate what type of location information they actually are collecting. The policy also seems to indicate that most of the information is collected via third parties and is not actually covered by the developer’s privacy policy.
In the Children’s Privacy section, they indicate that they are COPPA compliant and link to their “general privacy policy,” which in fact links to the Walt Disney Privacy Policy. There is no indication that this app or developer are in any way associated with Disney and it is unclear as to why there is a link to another company’s privacy policy within their own.
Screenshots of Lingokids - Play and Learn:
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.
