Nintendo can update this privacy policy at any time by posting a new version online; users are responsible for checking the page periodically rather than receiving direct notification of every change.
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
Nintendo is not required under this policy to directly notify users of changes via email or in-app alert, which means material changes to data practices could take effect without users being actively informed.
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 →If Nintendo changes how it collects or uses your data, it may update this policy online without sending you a direct notification, so it is worth periodically reviewing the policy at nintendo.com/us/privacy-policy.
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"We may update this Privacy Policy from time to time. When we make changes, we will update the date of this Privacy Policy and post the updated policy on this page. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.— Excerpt from Nintendo's Nintendo Privacy Policy
REGULATORY LANDSCAPE: Unilateral policy update mechanisms are common but may face regulatory scrutiny under GDPR (which requires re-obtaining consent if the basis for processing changes materially) and FTC Act Section 5 (which prohibits retroactive application of materially changed data practices without adequate notice and consent). CCPA requires that changes to the policy accurately reflect current data practices and that users be notified of material changes. Some state laws require affirmative notice of material changes to privacy policies. GOVERNANCE EXPOSURE: Low. Periodic update clauses are standard across the industry. However, if a future update materially expands data collection or sharing without active user notification, this could create regulatory exposure under GDPR (consent must be re-obtained) or CCPA (material changes must be disclosed). JURISDICTION FLAGS: GDPR users may have a stronger claim to affirmative re-consent if material changes affect the lawful basis for processing. California law requires that privacy policies accurately reflect current practices at all times. The adequacy of 'posting on this page' as notice depends on jurisdiction and the materiality of the change. CONTRACT AND VENDOR IMPLICATIONS: Vendor agreements should specify how policy changes affecting data flows are communicated to data processors and service providers, and whether changes require contract amendments or re-execution of data processing agreements. COMPLIANCE CONSIDERATIONS: Legal teams should implement a policy change review process that assesses whether any update constitutes a material change requiring active user notification, re-consent under GDPR, or updated CCPA disclosures. A version history of the policy should be maintained for audit purposes. Consider whether proactive email notification for material changes would reduce regulatory risk.
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Nintendo is not required under this policy to directly notify users of changes via email or in-app alert, which means material changes to data practices could take effect without users being actively informed.
If Nintendo changes how it collects or uses your data, it may update this policy online without sending you a direct notification, so it is worth periodically reviewing the policy at nintendo.com/us/privacy-policy.
ConductAtlas has identified this type of provision across 10 platforms. See the full comparison.
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