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I built a digital color-by-number game for my eight-year-old with three intentions: no ads, no timers, and no sign-up. Those are my claims about the design, not an independent audit of a verified product. They describe what I wanted the experience to feel like; they do not establish what data the game handles, whether it is safe or legally compliant, or whether my child benefits from it.
What I wanted the game to leave out
Color-by-number already gives a child a simple task: find a number, choose its color, and fill the matching space. I wanted the digital version to keep attention on that task rather than add commercial prompts or a countdown.
No ads
My stated design goal was to keep advertising out of the game. That matters because advertising in children’s apps can be hard for young users to recognize. The American Academy of Pediatrics reported in 2020 that an analysis found commercial content—including hidden and incentive ads—in 96% of the most-downloaded free apps for children under five. That finding concerns that specific group of apps and age range; it is not a measure of all children’s apps, apps for eight-year-olds, or this game. AAP’s coverage of digital advertising and children quotes policy co-author Nusheen Ameenuddin, MD, MPH, MPA, FAAP: “Lawmakers, media producers, tech companies all have a duty to start developing a digital environment in which families can navigate to educational and entertaining games, shows and other content that provides opportunities for children, rather than focusing on profits and data collection.”
Do these 3 things before closing this tab:
1Clear out junk files and repair common Windows errors2Fix the driver behind crashes, sound loss and screen glitches3Repair Windows errors before they cause bigger problemsNo timers
I wanted a child to be able to stop, pause, or take as long as they like without a countdown pushing them to finish. That is a design choice, not a claim that all time limits are harmful or that law prohibits timers. The FTC’s January 2025 COPPA amendments did not finalize proposed limits on push notifications; they are not a general ban on engagement features. The FTC’s announcement of the final amendments describes what was adopted.
No sign-up
I intended to make account creation unnecessary to start playing. But “no sign-up” does not mean “no data collection.” A service can collect information or use persistent identifiers without asking a player to create an account. Whether this particular game does so is unknown.
What those design choices do—and do not—tell a parent
“No ads, no timers, no sign-up” describes three visible parts of an experience. It does not answer the separate privacy questions a parent may have: what information is collected, how it is used, whether it is shared, and how long it is retained. A platform, offline behavior, progress storage, telemetry, and privacy notice have not been established for this game, so none should be assumed.
The FTC says COPPA can apply to child-directed websites and online services, including apps, when they collect, use, or disclose personal information from children under 13. It can also apply to a general-audience service that has actual knowledge it is collecting such information from a child under 13. The title or intended player alone does not determine the game’s legal status. The FTC’s audience assessment considers the whole context, including subject matter, visual content, child-oriented activities, language, advertising, intended audience, and empirical audience evidence; no single factor decides the issue. See the FTC’s COPPA FAQs and its guidance on COPPA and parents’ privacy rights.
FTC guidance lists personal information that may include contact details, location, images or audio, government identifiers, and persistent identifiers that can track activity over time. For services covered by COPPA, operators must give parents notice and obtain consent before collecting, using, or disclosing children’s personal information. FTC consumer guidance says parents can review information, withdraw consent, and request deletion. The operator must provide notice in plain language describing what is collected and how it is used, including advertising or disclosures to other companies.
The FTC does not prescribe one consent method for every service. Its guidance says an operator chooses a method reasonably designed, in light of available technology, to ensure that the person consenting is the parent. FTC guidance on verifiable parental consent explains that standard.
What changed in the FTC’s 2025 COPPA amendments
In January 2025, the FTC finalized amendments to COPPA. Among the changes it announced, covered disclosures of children’s personal information to third parties for targeted advertising require separate verifiable parental consent, and the rule sets limits on data retention. These are requirements for covered operators and practices; they do not certify a particular game or establish whether it falls within COPPA. The FTC’s announcement is the primary source for the changes and their implementation details. Check the FTC’s current rule information and announcement for the applicable status and guidance.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What I can responsibly say about this build
This is a personal build story, not a product review or a compliance assessment. The game’s platform, data practices, offline availability, progress storage, and privacy notice are not established here; neither is an independent verification of the three design claims. I can describe the experience I set out to make: a color-by-number activity without ad interruptions, countdown pressure, or a required account. I cannot infer from those choices that the game is safe, improves development, or complies with privacy law.
Quick Recap
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