Mobile App Manual Review under COPPA Rule: 'Surprise Eggs' and 'My Bakery Empire: Cake & Bake'

Nov 9, 2022 12:40:00 PM

Welcome to Pixalate’s 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 apps available in the Google Play & Apple App Stores using the COPPA Rule factors shown below & make those results available to the public at ratings.pixalate.com.

This post takes a look at two popular (1 million+ downloads each) mobile apps from the Google Play Store. Our reviewer discusses how the subjective factors set forth in the COPPA Rule apply to each 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).

Apps manually reviewed in this post

This Week’s Reviewer: Amanda Moody

amanda-moody-quote

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: Surprise Eggs

Likely audience after manual review

COPPA factors used to determine audience

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The gameplay screenshots for Surprise Eggs have visual content and subject matter that includes computer-animated images of young girl ballerinas, fairies, and other images that would likely appeal to children. The description in the “about this game” section of the Play Store includes phrases such as “best application for entertaining small children.”

Additionally, music during game play is very childlike (xylophone sounds) and happy-toned sounds play when candy is unwrapped to reveal a prize (the objective of this game). 

Children would enjoy the main incentive of the game which is to find out what is hidden inside the eggs. The interactive surprises inside of the eggs are princesses and other cartoon and movie characters.

During gameplay, ads sit at the bottom bar of the game. The ad that displayed in my sample play was from SAE International; however, after a minute into the game, in order to unlock a reward, a 30 second video ad from ABC Mouse (a learning app for children) played.

Furthermore, many reviews for this Surprise Eggs app suggested that children were users. For example, one review from February of 2022 said “...I still play it now and I’m 9 years old.” The Play Store highlights some information about data safety in this app including that the app is committed to the Play Families Policy. The app itself has a two sentence privacy policy that says “it does not collect or publish any personal information.”

Privacy

The Play Store highlights some information about data safety in this app including that the app is committed to the Play Families Policy. The app itself has a two sentence privacy policy that says “it does not collect or publish any personal information.”

Screenshot of Surprise Eggs:

Manual Review: My Bakery Empire: Cake & Bake

Likely audience after manual review

COPPA factors used to determine audience

In my opinion, My Bakery Empire: Cake & Bake is child directed as it contains elements that appeal to a mixed aged audience (meaning the app is targeting children under 13 as a portion of the audience). The subject matter of the game, cake design and sales, could appeal to both children and adults.

The visual content in the game is another factor that led me to conclude that this app is child directed. The entire game is painted in bright colors, mostly pinks and purples. Additionally with the cake designs, many of the colors are ombré rainbows with glitter and the design elements include stuffed animals and princesses. Several of the characters are young girls wearing shirts with sayings like “skateboard girl.” These visual content elements appeal to children.

After completing a level of gameplay in this app, an ad from Macy’s popped up to cover the game screen. The advertisement for the Macy’s app showed four toys that would appeal to children including a Cocomelon toy laptop, unicorn headphones, a Sonic the Hedgehog plush toy, and a “Kids Spiderman Digital Watch.”

Finally, some reviews indicate that children use the app. For example, one review says, “very nice and good for kids. My kids love it….” This app has a detailed privacy policy with specific information on how it handles data provided by children.

Privacy 

This app has a detailed privacy policy with specific information on how it handles data provided by children.

Screenshot of My Bakery Empire: Cake & Bake:

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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