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Mobile App Manual Review under COPPA Rule: ‘Dragon City Mobile'

May 17, 2023 12:45:00 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: Dragon City Mobile

Likely audience after manual review

  • Developer: Social Point (Google), Socialpoint (Apple)
  • Google Bundle ID: eu.bandainamcoent.mytamagotchiforever
  • Apple Bundle ID: 1267861706
  • Privacy Policy
  • Crystal’s Take: A fun and entertaining magical game that takes place in a floating dragon city.

COPPA factors used to determine audience

and and

The gameplay screenshots for Dragon City Mobile show that the content is visually directed to children with a mixed audience based on the animated dragons, floating city, and activities in the game. The description in the “about this game" section of the Play Store states, “build a dragon city…..adorable fire breathing dragons.” The language and keywords would suggest that this game appeals to children and adults. It has nice colorful graphic details in which the animated dragons and images are appealing to children. This game is about collecting and breeding adorable fire-breathing dragons. Players will be building a dragon team and in the long run, fight other teams to see who the true dragon master is. Players can connect with the Facebook version to manage their dragons but that is an option. It is free to download and play but there are in-app purchases. It is a delightful game that teaches patience.

The incentive of the game is to train your dragons, grow your collection and build your city, and fill it with buildings, habitats, and lots of dragons. The player has to breed baby dragons and develop them while creating a dragon city.

The game is rated E for Everyone in the Google play store and 4+ in the Apple Store. There is an age gate but you are still able to play the game. There is evidence that the app is used by children. A review posted in March of 2023 in the Google Play store says, “It changed a lot since I played it as a child, it is very fun.” The person did not specify the age in the review.
Another review in the iOS store without age specification, posted in June of 2022 says, “ok so I love this game and I’m also a kid.”


The developer’s privacy policy states, “we seek to ensure that we do not collect information from children."   “ For users who identify themselves as children in our age gate….we will either provide a version of that service that does not collect, use, or disclose personal information as defined in COPPA.”

Screenshots of Dragon City Mobile:

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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