The policy states that personal information is retained only as long as reasonably necessary for the purposes for which it was collected, after which it is deleted or de-identified, with retention period determined by data sensitivity, account activity, and applicable law.
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
The policy does not specify concrete retention periods for any data category, instead relying on the standard 'reasonably necessary' formulation; this may create a compliance evaluation point under GDPR's storage limitation principle and CCPA's retention disclosure requirements, which may require more specific retention period disclosures.
Interpretive note: Whether the 'reasonably necessary' retention standard satisfies GDPR Article 13/14 and CPRA retention disclosure requirements depends on regulatory interpretation and supervisory authority guidance in the applicable jurisdictions.
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, the duration for which Nintendo retains specific categories of personal data is not disclosed as fixed periods but is described as determined by data sensitivity, account activity, and applicable law. Users who close accounts or request deletion may find that some data is retained for additional periods based on these undisclosed retention criteria.
Cross-platform context
See how other platforms handle Data Retention Practices and similar clauses.
Compare across platforms →"We retain personal information only for as long as reasonably necessary for the purposes for which it was collected as set out in this privacy policy, after which time it is deleted, or de-identified in accordance with our retention practices based on the sensitivity of the data, account activity, features or services used and applicable law.Excerpt from Nintendo's Privacy Policy
REGULATORY LANDSCAPE: GDPR's storage limitation principle (Article 5(1)(e)) requires that personal data be kept no longer than necessary for its purpose and that retention periods or criteria for determining retention periods be disclosed to data …
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The policy does not specify concrete retention periods for any data category, instead relying on the standard 'reasonably necessary' formulation; this may create a compliance evaluation point under GDPR's storage limitation principle and CCPA's retention disclosure requirements, which may require more specific retention period disclosures.
Under this provision, the duration for which Nintendo retains specific categories of personal data is not disclosed as fixed periods but is described as determined by data sensitivity, account activity, and applicable law. Users who close accounts or request deletion may find that some data is retained for additional periods based on these undisclosed retention criteria.
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