Nintendo · Nintendo Privacy Policy · View original document ↗

Children's Data and Parental Consent (COPPA)

High severity Unique · 0 of 325 platforms
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Document Record

What it is

Nintendo requires verifiable parental consent before collecting personal information from children under 13, and provides parents with tools to review, modify, or delete their child's data.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

The provision creates a dual framework: it restricts general data collection from children pending parental authorization while carving out an exception permitting collection of technical identifiers required for service operation. This operational structure addresses COPPA compliance requirements while maintaining necessary infrastructure functionality.

Recent Activity

This document changed recently

Medium Apr 19, 2026

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 →
Medium Apr 8, 2026

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 →
Medium Mar 19, 2026

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 →

Consumer impact (what this means for users)

Parents have the right to review, limit, or delete their child's personal data held by Nintendo, and Nintendo cannot collect or share children's data without parental approval.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Visit Nintendo's privacy policy page and use the privacy request form to submit a request to review or delete your child's personal data. Parents may also use the Nintendo Switch Parental Controls app to manage account-level settings.

How other platforms handle this

Duolingo Medium

The Services are not directed to children under 13. If you learn that your child under 13 has created an account on Duolingo, please contact us at privacy@duolingo.com. We do not knowingly collect personally identifiable information from children under the age of 13. Parents or guardians can create ...

Mistral AI Medium

Customer will not, and will not permit any other person (including any End User) to: ... (c) include any personal information of children under 13 or the applicable age of digital consent as Customer Data or allow minors to use the Mistral AI Products without legally adequate consent from their pare...

Microsoft Copilot Medium

By creating a Microsoft account or using the Services, you accept and agree to be bound by these Terms and represent that you have either reached the age of "majority" where you live or your parent or legal guardian agrees to be bound by these Terms on your behalf. If you are the parent or legal gua...

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▸ View Original Clause Language DOCUMENT RECORD
"
We do not knowingly collect, use or share information from children under a certain age without parental consent or as permitted by law (e.g., a "child" is under the age of 13 in the United States, under the age of 14 in Quebec, etc.). However, please note that we collect, and we permit our service providers to collect, persistent identifiers, such as IP addresses, device identifiers and other unique identifiers from such child users, solely for purposes necessary to support the internal operations of our services.

— Excerpt from Nintendo's Nintendo Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

This provision engages COPPA (15 U.S.C. § 6501 et seq.) and FTC enforcement authority. Non-compliance with parental consent requirements and data minimization obligations for minors represents significant regulatory exposure, including FTC enforcement action and civil penalties.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC enforces COPPA and investigates violations of children's online privacy protections, including failures to obtain verifiable parental consent.
    File a complaint →

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
COPPA
United States Federal
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Nintendo Privacy Policy
Entity
Nintendo
Document last updated
May 5, 2026
Tracking information
First tracked
March 20, 2026
Last verified
March 20, 2026
Record ID
CA-P-000996
Document ID
CA-D-00188
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
e9e1453fe17a8f71498b81f4e20583738f8dd4a4e1ccbb53a5e4c6ebf441f62d
Analysis generated
March 20, 2026 04:12 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Nintendo
Document: Nintendo Privacy Policy
Record ID: CA-P-000996
Captured: 2026-03-20 04:12:16 UTC
SHA-256: e9e1453fe17a8f71…
URL: https://conductatlas.com/platform/nintendo/nintendo-privacy-policy/childrens-data-and-parental-consent-coppa/
Accessed: May 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

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Frequently Asked Questions

What does Nintendo's Children's Data and Parental Consent (COPPA) clause do?

The provision creates a dual framework: it restricts general data collection from children pending parental authorization while carving out an exception permitting collection of technical identifiers required for service operation. This operational structure addresses COPPA compliance requirements while maintaining necessary infrastructure functionality.

How does this clause affect you?

Parents have the right to review, limit, or delete their child's personal data held by Nintendo, and Nintendo cannot collect or share children's data without parental approval.

Is ConductAtlas affiliated with Nintendo?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Nintendo.