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 atratings.pixalate.com.
This post takes a look at a game which is available 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).
Emma’s Take: Simple mini games based around looking after zoo animals.
COPPA factors used to determine audience
Zoo: Happy Animals has a strong feel of a game that is well suited to young children, perhaps even older toddlers. The cartoon imagery of friendly animals and caring for them is exactly the type of thing that young children like to do. The game presents the user with lots of mini-games that involve feeding the animals, washing them, shaving their coats, preparing their food, etc. Each game lasts less than a minute, some much less than that if you get the hang of it straight away. Unfortunately, each game is followed by a lengthy advert. This balance of gameplay to adverts is likely to frustrate any older or adult players.
The written instructions in this game are limited, instead using more visual prompts and hints to show the player what to do. These are all intuitive and children are likely to be able to follow them easily. For example, one game wants the user to draw a path with their finger to connect the food with the animal. The desired path is shown with a dotted line for the player to draw over. There is very little in the way of puzzles to work out and most games are straightforward enough for the youngest player.
“Log-, device-, usage-, and consumption information are being processed: … to provide children (as this term is construed under GDPR in EU, COPPA in the US and the relevant applicable legislation in other jurisdictions) with reasonable contextual advertisements in the App.”
These two statements are at odds with each other. In any case, there is no age gate on the app to determine the age of the user.
Screenshots of Zoo - Happy Animals
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.
Disclaimer: The content of this page reflects Pixalate’s opinions with respect to the factors that Pixalate believes can be useful to the digital media industry. Any proprietary data shared is grounded in Pixalate’s proprietary technology and analytics, which Pixalate is continuously evaluating and updating. Any references to outside sources should not be construed as endorsements. Pixalate’s opinions are just that - opinion, not facts or guarantees.
Per the MRC,
“'Fraud' is not intended to represent fraud as defined in various laws, statutes and ordinances or as conventionally used in U.S. Court or other
legal proceedings, but rather a custom definition strictly for advertising measurement purposes. Also per the MRC,
“‘Invalid Traffic’ is defined generally as traffic
that does not meet certain ad serving quality or completeness criteria, or otherwise does not represent legitimate ad traffic that should be included in measurement counts.
Among the reasons why ad traffic may be deemed invalid is it is a result of non-human traffic (spiders, bots, etc.), or activity designed to produce fraudulent traffic.”