The policy states that Nintendo will notify users of material changes to data collection, use, retention, or sharing practices by email to the address on file or by posting notice on covered services.
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 notification mechanism for material changes relies on the email address last provided by the user, which may not reach users with outdated contact information; the alternative of 'posting notice on the services' may not satisfy affirmative notification requirements under certain privacy regulations.
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, users will receive notification of material policy changes via email or on-service posting. Users whose email addresses on file are outdated may not receive email notifications and would need to rely on posted notices within Nintendo services to become aware of changes.
Cross-platform context
See how other platforms handle Material Policy Change Notification and similar clauses.
Compare across platforms →"If we make material changes in the way we collect, use, retain or share your information, we will notify you by sending you an email at the last email address that you provided us, or by posting notice of the changes on the services covered by this privacy policy.Excerpt from Nintendo's Privacy Policy
REGULATORY LANDSCAPE: GDPR requires that data subjects be informed of material changes to processing practices in a timely manner, and regulatory guidance in various EU member states has addressed the adequacy of different notification mechanisms.
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The notification mechanism for material changes relies on the email address last provided by the user, which may not reach users with outdated contact information; the alternative of 'posting notice on the services' may not satisfy affirmative notification requirements under certain privacy regulations.
Under this provision, users will receive notification of material policy changes via email or on-service posting. Users whose email addresses on file are outdated may not receive email notifications and would need to rely on posted notices within Nintendo services to become aware of changes.
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