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Mobile App Manual Review under COPPA Rule: ‘Zoo - Happy Animals'

Jun 7, 2023 2:00:00 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 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).

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: Emma Burdis


Manual Review: Zoo - Happy Animals

Likely audience after manual review

  • Developer: SayGames Ltd (Google), SayGames LTD (Apple)
  • Google Bundle ID: su.canoe.zoo.elephant
  • Apple Bundle ID: 1579693904
  • Privacy Policy
  • 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.


The Privacy Policy states that users must be at least 16 years old to access the game. However, in another section of the Policy, the developers state that:

“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.

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