The policy discloses that Nintendo participates in the CARU Privacy Certified Program, which subjects covered Nintendo websites to independent audits and enforcement mechanisms administered by CARU.
This analysis describes what Nintendo's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
CARU certification creates an independent accountability mechanism for child-directed data practices on covered Nintendo websites, with audit and enforcement obligations that supplement statutory COPPA requirements and provide a non-governmental complaint channel for parents and guardians.
Nintendo now explicitly discloses that it collects persistent identifiers (IP addresses, device IDs) from child users for operational, security, fraud prevention, and service improvement purposes, and states that contractual restrictions limit how service providers can use this data. Parents gain enhanced transparency by being able to view a named list of third-party games and applications authorized to access their child's account, rather than just managing access through settings. The policy also clarifies that location information may be used for check-ins at Nintendo locations and events in addition to location-based games. You can review and manage which third-party apps have access to your child's account through your Nintendo Account profile settings.
View change record →Nintendo now discloses that it uses location data not only for location-based games and friend connections, but also to enable check-ins at specific events and Nintendo locations, which is a new explicit use case. The policy now details how child user data including persistent identifiers like IP addresses and device IDs are collected and retained, with commitments to delete or de-identify data based on sensitivity and account activity. Parents can now see which third-party apps have been authorized to access their child's account before deciding whether to allow continued access, giving more visibility into connected applications.
View change record →The revised policy simplifies how Nintendo describes data retention, now stating information is retained only as long as reasonably necessary in accordance with applicable law, without prior detail about sensitivity-based retention practices. For child users, the policy no longer explicitly lists persistent identifiers (IP addresses, device identifiers) that Nintendo and service providers collect, removing specific disclosure language that previously detailed collection purposes for child accounts. The policy now indicates it collects error information from both users and devices, broadening the prior language focused on device errors only. The privacy certification body changed from CARU to ESRB, meaning independent audits and enforcement are now administered by the Entertainment Software Rating Board rather than the Children's Advertising Review Unit.
View change record →Under this provision, Nintendo's covered websites are subject to periodic independent audits by CARU and must meet CARU's established standards for online information collection and use. Parents and guardians may submit complaints to CARU Privacy Certified at InfoCaru@bbbnp.org or through the CARU website as an additional accountability mechanism.
Cross-platform context
See how other platforms handle CARU Privacy Certified Program Participation and similar clauses.
Compare across platforms →"This privacy policy and the certification seal located on our websites that link to this policy confirms that we are a valid licensee, and participating member, of the Children's Advertising Review Unit's Privacy Certified Program. To help protect your privacy, we have voluntarily undertaken this privacy initiative. As a licensee in this privacy certification program, we are subject to frequent audits of our websites and other enforcement and accountability mechanisms administered independently by the CARU. All of our sites containing the CARU certification seal have been reviewed, and certified, by CARU to meet established online information collection and use practices.Excerpt from Nintendo's Privacy Policy
REGULATORY LANDSCAPE: CARU operates under the umbrella of BBB National Programs and its Privacy Certified Program is recognized by the FTC as a safe harbor program under COPPA.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Get the research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.
CARU certification creates an independent accountability mechanism for child-directed data practices on covered Nintendo websites, with audit and enforcement obligations that supplement statutory COPPA requirements and provide a non-governmental complaint channel for parents and guardians.
Under this provision, Nintendo's covered websites are subject to periodic independent audits by CARU and must meet CARU's established standards for online information collection and use. Parents and guardians may submit complaints to CARU Privacy Certified at InfoCaru@bbbnp.org or through the CARU website as an additional accountability mechanism.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Nintendo.