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 establishes an outer bound on how long Nintendo holds personal data, grounded in the 'reasonably necessary' standard rather than an indefinite retention period.
Interpretive note: The canonical claim captures the primary retention rule. The factors determining whether data is deleted versus de-identified are recorded in omitted_material.
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 →Personal data will not be held indefinitely; Nintendo's retention is limited to what is reasonably necessary, after which data is deleted or de-identified.
How other platforms handle this
We collect and keep personal data only as needed or allowed for the purposes set out in this Statement, based on the reason we collected the personal data in the first instance and what is permitted under the laws that apply to the processing.
we will only retain your personal information for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements...
We may retain your Personal Data for a period of time consistent with the original purpose of collection...or as long as required to fulfill our legal and/or regulatory obligations.
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"We retain personal information only for as long as reasonably necessary for the purposes for which it was collected...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 Nintendo Privacy Policy
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This establishes an outer bound on how long Nintendo holds personal data, grounded in the 'reasonably necessary' standard rather than an indefinite retention period.
Personal data will not be held indefinitely; Nintendo's retention is limited to what is reasonably necessary, after which data is deleted or de-identified.
ConductAtlas has identified this type of provision across 273 platforms. See the full comparison.
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