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Mobile App Manual Review under COPPA Rule: ‘Lily’s Garden: Design & Match'

May 17, 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 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


Manual Review: Lily’s Garden: Design & Match

Likely audience after manual review

  • Developer: Tactile Games (Google), Tactile Games ApS (Apple)
  • Google Bundle ID: dk.tactile.lilysgarden
  • Apple Bundle ID: 1437783446
  • Privacy Policy
  • Emma’s Take: A puzzle game wrapped in a story to keep the user playing.

COPPA factors used to determine audience


Lily’s Garden: Design & Match is a story game following the main character while she restores the gardens around her house. Other characters pop into the game to add interest and to move the story along. The story and animation are familiar and straightforward enough to appeal to children. There is a lot of reading involved so older children are more likely to play, although the story sections can be skipped. 

To progress through the game, the player must complete mini-games to gain stars. Stars can then be used to complete tasks in the garden. The mini-games are mostly puzzle-matching games along the lines of Candy Crush. Other mini-puzzle games are also available periodically throughout the game, which grants extra stars and coins. There is also the option to watch a video to double the amount of coins you receive.
The app also utilizes motivational hooks such as rewards for playing every day, special timed events, and limited-time discounts for in-app purchases. These all have an urgency around them to ensure the user has a fear of missing out and keeps on playing.


The developers’ Privacy Policy includes a list of countries and their minimum age for playing. The policy states that below this age, children may not use the game. There is no age gate on the app to determine the age of users, but they must accept the Privacy Policy and Terms of Service when launching the game.

Screenshots of Lily’s Garden: Design & Match:

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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