The policy states Nintendo does not sell user data, but authorizes third-party service providers to collect user information and deliver targeted advertising based on online activity tracked across different sites, services, and devices over time.
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
This provision authorizes cross-context behavioral advertising by third parties using Nintendo user data, which may meet the CPRA statutory definition of 'sharing' for targeted advertising purposes, potentially requiring a separate opt-out mechanism for California residents regardless of the policy's 'no sale' assertion.
Interpretive note: Whether the described cross-context behavioral advertising arrangements meet the CPRA definition of 'sharing' depends on the specific contractual and operational arrangements with third-party providers, which are not fully disclosed in this document.
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 clause, third-party service providers may collect user data through Nintendo services and use it to deliver targeted advertising across multiple platforms and devices over time. California residents may have the right to opt out of this data sharing for cross-context behavioral advertising under the CPRA, which the policy does not explicitly address.
Cross-platform context
See how other platforms handle Cross-Context Behavioral Advertising by Third-Party Providers and similar clauses.
Compare across platforms →"We do not and will not sell your information to third parties. However, we permit third-party service providers to collect your information, as described here, through some of our services and we share your information with third-party service providers for business purposes as described in this policy, including but not limited to providing advertising on our services and elsewhere based on users' online activities over time and across different sites, services, and devices.Excerpt from Nintendo's Privacy Policy
REGULATORY LANDSCAPE: This provision engages the CCPA and CPRA, enforced by the California Privacy Protection Agency and California Attorney General.
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This provision authorizes cross-context behavioral advertising by third parties using Nintendo user data, which may meet the CPRA statutory definition of 'sharing' for targeted advertising purposes, potentially requiring a separate opt-out mechanism for California residents regardless of the policy's 'no sale' assertion.
Under this clause, third-party service providers may collect user data through Nintendo services and use it to deliver targeted advertising across multiple platforms and devices over time. California residents may have the right to opt out of this data sharing for cross-context behavioral advertising under the CPRA, which the policy does not explicitly address.
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