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Mobile App Manual Review under COPPA Rule: ‘Disney - Maleficent Free Fall'

May 24, 2023 12:15:00 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 and Apple App 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


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: Maleficent Free Fall

Likely audience after manual review

  • Developer: Kongregate (Google), Kongregate, Inc. (Apple)
  • Google Bundle ID: com.disney.maleficent_goo
  • Apple Bundle ID: 839618264
  • Privacy Policy
  • Crystal’s Take: A match 3 puzzle game themed around the movie Maleficent with magic spells and a dark twist.

COPPA factors used to determine audience


and and and

The gameplay screenshots for Disney Maleficent Free Fall show that the content is visually directed to children with a mixed audience based on the Disney characters, and colorful images. At the start of the game the players begin as a young Maleficent and with each level you unlock other characters. Players throughout the game swap out gems on the game board to make matches of three.  The music and sounds are that of intense magic spells and bells. Players match three or more and unlock more power ups along the way with a restricted amount of moves. The game is similar to the Disney Frozen free fall game because it is fun and easy to play.  It is great for learning attention to detail and logical thinking. The description in the play store says, “embark on a spectacular journey….puzzle adventure."

The incentive of the game is to tell the story of Maleficent and work your way through levels by powering up gems to clear rows that result in more powerful moves. As the players level up there is an increase in the level of difficulty.  Players do have the option of in-app purchases. It does have the ability to lock so that children playing don’t make any in-app purchases.

The game is rated E for Everyone in the Google play store and 4+ in the Apple Store. There is no age gate. There is evidence that the app is used by children. A review posted in December of 2022 in the Google play store says, “I played this game when I was a kid and again as an adult.”  The review did not give a specific age.


The developer’s privacy policy states, “we do not rent or sell personal information collected by or from any service or portion of a service that is directed to children."

Screenshots of Maleficent Free Fall

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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