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Mobile App Manual Review under COPPA Rule: "Clumsy Ninja"

Dec 21, 2022 2:30:00 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 Google Play & Apple App Stores with over 1 million+ downloads. 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: Crystal Pearson

Teacher Quotes Template-3

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: Clumsy Ninja

Likely audience after manual review

Mixed Audience (1)

  • Developer: NaturalMotionGames Ltd
  • Bundle ID: com.naturalmotion.clumsyninja
  • Privacy Policy
  • Crystal’s take: Fun entertaining game centered on a ninja appealing to a mixed audience.

COPPA factors used to determine audience

and and

The gameplay screenshots for Clumsy Ninja have visual content directed to children with animation that includes computer-animated images of childlike ninjas with actual simulation and other images that would appeal to children. The subject matter would appeal to both adults and children. The app store description says, “Meet Clumsy Ninja, the most hapless ninja ever to grace a touchscreen! Train him, throw him, tickle him, and even tie balloons to him.”

The goal of the game is to train the clumsy ninja and travel to new locations to complete quests while doing so, which would appeal to a mixed audience. The interactive game allows the person to meet new characters and learn new moves. The app store description says, “Everything you do will make Clumsy Ninja more skillful, and help him find his missing friend, Kira.”

This game is rated E for Everyone in the Google Play Store and 4+ in the Apple store. I saw evidence of both adults and children using the app in the online reviews. At least two reviews demonstrate that kids use the app. In June of 2021, a reviewer said “...My younger siblings have this game as well and as far as I've seen their progress is saved perfectly..” In May of 2022, another reviewer said “.... I loved playing it when I was 10-12 and got pretty far into the story..”


The developer’s privacy policy was recently updated in November 2022. There is a Children’s Privacy section in the privacy policy which states that the app is not marketed to or intended for children under 13. The policy states, “If we learn that we have inadvertently gathered personal information about a child that is not subject to an exemption under COPPA or another applicable privacy law, we will take measures to promptly remove that information from our records.”

Screenshots of Clumsy Ninja:

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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