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Mobile App Manual Review under COPPA Rule: ‘Talking Pocoyo'

Apr 27, 2023 4:00:00 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 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: Talking Pocoyo

Likely audience after manual review

COPPA factors used to determine audience

and and and

The gameplay screenshots for Talking Pocoyo include images of child aged animated models that gives the player a virtual best friend that entertains the user through fun music and games. The music and sounds are that of a child playing and whimsical music. The app store description says, “Children will always want to be around their favorite character.  Try it now, you won’t forget your children’s faces of excitement.”

During gameplay, there are lots of ads that are displayed in order to open either music, dancing or play. The ads are, "My Talking Tom 2, Slim Art, and Cash Giraffe”. This advertising would appeal to children.

This game is rated E for Everyone in the Google Play Store and 4+ in the Apple store. There is no age gate or parental control. The app shows evidence that children use the app. In January of  2019, a reviewer said, “Brilliant game and my 2 year old cousin likes playing with him.”  The review was by an adult relative. In November of 2020, a reviewer stated, “My kids love this.” The review was from a parent but no ages were specified.

Privacy:

The developer’s privacy policy was last updated in May 2021. The policy states, “ ZINKIA may send you commercial communications with information regarding offers and promotions related to third parties’ products/services aimed at children. “ The app's terms of use states, “ If you are a minor, please notify your father, mother or guardian…. To understand the conditions.”

Screenshots of Talking Pocoyo:

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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