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Mobile App Manual Review under COPPA Rule: ‘Avatar Maker: Cats 2’

Dec 14, 2022 12:30:00 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 on both the Apple App and Google Play 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).

Manually reviewed in this post


This Week’s Reviewer: Tabitha Walker

Teacher Quotes Template-2

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.

Manual Review: Avatar Makers: Cats 2 (Apple) and Avatar Makers: Cats 2 (Google)

Likely audience after manual review

Mixed Audience (1)

COPPA factors used to determine audience

and visual-content

This mixed audience app allows the user to design their own cat avatar. Users can select the cat’s color, eyes, ears, tail, clothing, accessories, and even extras such as wings or items held in the cat’s mouth. Once the cat is complete, there are a variety of backgrounds to choose from. The cats, their possible features, and the backgrounds are anime style, with big eyes and fantasy themes that would appeal to both children and adults.


While the app, itself, focuses on the visual creation of these cat avatars; the language of the app description seems to be targeting children. While the title of the app contains the word “cat,” every reference in the description uses “kitty” instead of “cat,” indicating a younger targeted demographic. Star shaped bullet points in the description and emoticon cats further indicate that the developers are targeting children as part of their intended audience.

Banner advertisements are always present across the bottom of the app and video advertisements play often. Some of the advertisements are for other apps that would appeal to kids, while others are for things that would appeal to adults such as banks, news sites, and streaming services. Certain avatar features are only available by watching an ad first.

Reviews indicate that both adults and children are enjoying this app. Several reviews mention Warrior Cats, which is a popular children’s book series by Erin Hunter, however the app itself doesn’t seem to have any direct connection to these books. Some users seem to be children that are currently reading the books, while other reviews indicate nostalgic adults recalling a favorite series from their childhood.

This app has a US rating of E and a European PEGI of 3 and up. This app is also available on the Apple App Store with an age rating of 4+.


According to the developer’s privacy policy which was last updated on July 11, 2022, the app does not collect data from children under 13. However, there is no age gate upon installing or opening the app to determine the age of the user.

Screenshots for Avatar Maker: Cats 2:

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.


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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