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Connected TV (CTV) App Manual Review under COPPA Rule: 'Toy Galaxy'

Nov 30, 2022 3:30:00 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 Connected TV app from the Roku store. 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


This Week’s Reviewer: Emma Burdis

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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: Toy Galaxy

Likely audience after manual review

General Audience_V2

COPPA factors used to determine audience

language

The topics discussed on the videos may well be of interest to some children, but it appears unlikely that children under 13 are the main intended audience. The manner and delivery of the presenter are not typical of children’s tv content, instead favoring a direct approach and using casual, ‘grown up’ vocabulary.

subject-matter

While the name of the app may immediately evoke images of children unwrapping surprise eggs on camera, the focus of Toy Galaxy is on looking closer at popular toys of the 80s, 90s and 2000s. The content is pulled from their YouTube Channel, SecretGalaxyTV, which presents a new show every week. Topics of the videos include several ‘History’ shows, such as “The History of Saturday Morning Cartoons & Why they Disappeared.”

Privacy 

The developer, DREXLS, has a comprehensive Privacy Policy which was last updated in December 2020. DREXLS states that children under 13 should not use or access their service, and they will endeavor to delete any child’s personal information that is obtained. The policy contains contact information for parents to use in order to have their child’s account terminated and personal information deleted.

Screenshots of Toy Galaxy:

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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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