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 Roku Channel Store, Amazon Fire TV Store, and the Samsung CTV App 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.
Baby Hazel Nursery Rhymes provides users with numerous animated videos set to educational songs and nursery rhymes. The content contains a mix of classic nursery rhymes and children’s songs alongside original educational songs teaching letters, numbers, and more. The subject matter is geared toward toddlers.
The lyrics of the songs often rhyme and are catchy and repetitive, allowing younger children to catch on quickly and learn the lyrics.
Each video is animated with cartoon-like characters and backgrounds that are appealing to young children. The videos are full of bright colors and many animated objects that will catch and hold the attention of a toddler.
Baby Hazel appears to be about 2 or 3 years old, and many of the other animated children frequently seen seem to be 5 years old or under. In addition to the animated children, there are plenty of animated animals regularly featured in the videos. The animals are animated in the same fashion as the children and often wear clothing and talk, even driving cars and playing instruments.
Video advertisements are played before each video starts. These ads are for general audience products and services, such as discount cards, travel, and other apps.
The frequency of these advertisements can be slowed by selecting the compilations to view, rather than individual songs. The compilation videos are anywhere from 15 minutes to over an hour in length, and feature several songs played back to back without interruption.
The description of the Baby Hazel Nursery Rhyme app contains references to children using the app, “keep your children excited watching our video episodes” and “children can learn while enjoying their Animated Video Episodes and you can relax for a while.” The description additionally includes various educational keywords such as preschool, nursery rhymes, phonics, shapes, ABCs, numbers, and colors.
Even the title of the app and the main character are phrased as “Baby Hazel,” rather than just Hazel. The language used in the title, characters, and descriptions indicates that the developers intended preschool-aged children to be the primary audience of this app.
This app is rated “All Ages” on Amazon and is in the “Kids & Family” category on Roku.
Samsung and Roku do not collect written reviews and Amazon does not yet have any written reviews for this app to indicate what the audience composition actually is.
Privacy
According to the privacy policy, Castify does collect personal usage information, such as IP addresses and general locations, alongside non-personal technical and third-party information. They write that they have not sold any personal information in the past 12 months, but do not have any written guarantees to not do so in the future.
While the privacy policy does not address children in any way, the terms of use indicates that Castify apps are not intended for users under 13. They also indicate that users under 18 should have parental permission before using any Castify services. As mentioned previously, the wording of the app descriptions indicates that the intended audience of this app is children. It is surprising to see the opposite indicated in the terms of use. The privacy policy and terms of use are not app specific, and are blanket policies for all apps under Castify. However, Castify does have numerous other child-directed apps with the same attached policies.
Screenshots of Baby Hazel Nursery Rhymes
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.
