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Mobile App Manual Review under COPPA Rule: ‘100 Doors-Without Internet'

Nov 1, 2023 1:00:00 PM

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 (1 million+ downloads) 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).

Manually reviewed in this post

 

The 10 COPPA Rule factors

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.

Reviewed by: Crystal Pearson

Crystal Pearson

Manual Review: 100 Doors-Without Internet

Likely audience after manual review

  • Google Developer: Bonbeart Games
  • Google Bundle ID: com.bonbeart.doorsseasons.part1
  • Privacy Policy
  • Crystal’s Take: 100 Doors - Without Internet is a puzzle game used to sharpen players' logical reasoning.

COPPA factors used to determine audience

and and

100 Doors - Without the Internet, the game is about solving challenging puzzles and tracking down an escape through 100 doors. Players can request game tips from friends to assist in finding out how to escape the 100 doors. Get coins for tackling difficult puzzles that require an objective way of thinking. Players will find hidden gadgets, get new puzzle games with different objects, and will have the ability to skip rooms that may be too difficult.  The visual content and animation are directed at a mixed audience based on the types of simple fun graphics in the gameplay. The language is directed to children in the about this game section states, “appeal to players of all ages.”

The incentive is to escape by solving all the puzzles in the doors.

The advertising directed to a general audience is shown as a banner and after collecting coin rewards such as, “homes.com “.  The game does have continuous ads throughout that are directed to a mixed audience, such as, “Candy Crush Saga and Royal Match.” The advertisements require players to watch a game trailer advertisement in order to collect the rewards.

The app is rated E for Everyone in the Google Play store. There is no age gate. The app starts immediately for play. 

Privacy:

The developer’s privacy policy  states, ” Our games are intended for general audiences and we do not knowingly collect any personal information from children, except as expressly described otherwise in our terms.”

Screenshots of 100 Doors-Without Internet

About Pixalate’s Trust & Safety Advisory Board

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.

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