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Mobile App Manual Review under COPPA Rule: 'Tap Color Pro: Color by Number'

Mar 16, 2023 12:00:00 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: Tap Color Pro: Color by Number

Likely audience after manual review

Child Directed - Mixed Audience

  • Developer: Tap Color Studio
  • Bundle ID: coloring.color.number.happy.paint.art.drawing.puzzle
  • Privacy Policy
  • Crystal’s Take: Stimulating, colorful game centered on coloring by number using animals, kids, animations, and nature.

COPPA factors used to determine audience

and and

The gameplay screenshots for Tap Color Pro: Color by Number have visual content directed to children. These include coloring pages with images of childlike animals and nature friendly pages that would appeal to children. The subject matter would also appeal to children as well as adults. The app store description says, “Animal: cute dogs & cats, birds, and eagles, all kinds of wild animals you want to color.”

During gameplay, there are numerous ads that are displayed at the bottom of the page while coloring. The ads are, "Pandora and Huggies”. 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. There is no age gate. The app shows evidence that children use the app. In November 2022, a reviewer said, “My grandkids love to click on the butterfly because they like the more complicated pictures that you have.” The coloring pages are visually appealing to a mixed audience.


The developer’s privacy policy was last updated in December 2021. The policy states, “our services are not intended for use by children under the age of sixteen (16). We will not knowingly collect personal information directly from children under the age of sixteen (16) without parental consent.

Screenshots of Tap Color Pro: Color by Number:

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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