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Mobile App Manual Review under COPPA Rule: ‘Flick Shoot 2'

Jun 14, 2023 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 game which is available 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: Emma Burdis

image10-1

Manual Review: Flick Shoot 2

Likely audience after manual review

COPPA factors used to determine audience

Flick Shoot 2 uses realistic animation similar to the style of FIFA. Users control a player to score goals in several different game modes. A training level is available for instructions on how to play. The gameplay is intuitive and easy to learn. There is nothing about the visual content that appears to be aimed specifically at children. 

Soccer is a game enjoyed by those of all ages, so this could easily have a broad appeal.

Users earn coins for achieving targets within the game modes and mini-games are available to achieve bonus coins. A premium subscription is available which gives access to special balls, extra coins, and VIP game modes. For $12.99 a week, I can’t envisage many children subscribing to this. 

The app has nearly 9000 reviews on the Apple App Store, and 1.35m on the Google Play Store. On reviewing a selection of them, they appear to be written by adults rather than children. The majority of the reviews give balanced feedback to the developers, expanding on their points with evidence and examples. I didn’t see any reviews which appeared to be written by children. 

Privacy:

The Privacy Policy from the game developers has a standard clause relating to children: “We do not knowingly collect or solicit personal data about or direct or target interest-based advertising to anyone under the age of 13 or knowingly allow such persons to use our Services.” It goes on to ask that children under 13 not provide any information about themselves to the company. There is no age gate present on the app.

Screenshots of Flick Shoot 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.

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.

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