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Mobile App Manual Review under COPPA Rule: 'Match Animal'

Feb 22, 2023 5:00:00 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 game (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: Match Animal

Likely audience after manual review

Child Directed_Final

  • Developer: Spearmint Games
  • Bundle ID: games.spearmint.matchanimal
  • Privacy Policy
  • Crystal’s Take: Entertaining, colorful, fun puzzle game centered on matching animals to clear levels with animated characters that are visually child directed.

COPPA factors used to determine audience

.and .and

The gameplay screenshots for Match Animal have visual content directed to children with animation that includes computer-animated images of childlike animals that would appeal to children. The subject matter would also appeal to children. The app store description says, “Attractive visuals, easy to learn puzzle game by matching 3 animal tile right away and have fun.”

The goal of the game is to tap on a tile in the puzzle and choose the same tile in that area until the tile disappears, leaving room for more tiles. This simple game would be attractive to children under 13.

During gameplay, there are numerous ads that are displayed in my sample play. As soon as you start playing the ads are at the bottom of the game. The ads are, "Temu and HBO Max. "This advertising would appeal to a general adult audience.

This game is rated E for Everyone in the Google Play Store and 4+ in the Apple store. The app shows evidence that children use the app. In October 2022, a reviewer said, "Love playing this game, I remember playing this game as a child. "In December 2022, a reviewer said, “Good game to play with my granddaughter.”


The developer’s privacy policy was last updated in March 2021. The policy states, “we will use reasonable efforts to ensure that the third party ad networks are configured to comply with applicable privacy laws. If we determine a service to be directed to children under the age of 13, we configure each of these ad networks to be compliant with the Children’s Online Privacy Protection Act of 1998 (COPPA).”

Screenshots of Match Animal:
















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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