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Connected TV (CTV) App Manual Review under COPPA Rule: ‘GamingWithKev - Let’s Play’

Jan 11, 2023 9:30:00 AM

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 CTV app from the Amazon Fire TV App store and the Roku Channel 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).

Manually reviewed in this post


This Week’s Reviewer: Amanda Moody

Teacher Quotes Template-1

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: GamingWithKev - Let’s Play

Likely audience after manual review

Mixed Audience (1)

  • Developer: Studio 71 Apps
  • Roku App Store ID: 215728
  • Amazon Fire TV App Store ID: B07HYGT73M
  • Privacy Policy
  • Amanda’s take: GamingWithKev - Let’s Play is a collection of gameplay videos from a popular YouTuber @gamingwithkev who has over 8 million subscribers. Kevin’s high energy gaming videos are mostly of him playing Roblox, a game known to interest all ages, including appealing to children. This channel app seems to have a mixed audience.

COPPA factors used to determine audience

subject-matter and  

The GamingWithKev - Let’s Play app is a collection of over 100 gameplay videos featuring a host, Kevin, showing his face in a small section of the screen and sharing commentary while playing video/computer games. Most of the games in this collection feature Kevin playing Roblox: a popular platform where kids, teens, and adults create, share, and play games. Kevin’s Roblox avatar on the screen during gameplay, like other Roblox characters, resembles a Lego-like character moving about a world built from blocks. This visual content appeals to children. 

On the Roku App Store landing page for this app, the app description says that “GamingWithKev combines his family man persona with his serious gaming skills across the metaverse with games like Roblox and more! Kev brings a diverse take to his engaging and adoring fanbase.” This description supports the idea that the target audience for this content is a mix of children and adults.

Three of the thumbnails for videos contained images that could appeal to a younger audience: the “2 Player Roblox HIGH HEELS Challenge” thumbnail showed images of Barbies and a small toy puppy, the “ROBLOX PENGUIN TYCOON” video showed animated penguins that looked to be from the computer-animated movie Madagascar, and finally the “ROBLOX DISNEYLAND” thumbnail includes Elsa from Frozen, Mickey Mouse, and a vomiting emoji on a rollercoaster.

Privacy 

The operator’s privacy policy does not mention how it treats children’s data.

Screenshots of GamingWithKev - Let’s Play:

 

 

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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