Nintendo · Nintendo Privacy Policy · View original document ↗

Third-Party Data Sharing with Service Providers and Partners

Medium severity Medium confidence Explicitdocumentlanguage Rare · 7 of 325 platforms
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Document Record

What it is

Nintendo shares your personal data with a range of third-party companies that handle payment processing, data analysis, marketing, hosting, and customer service on its behalf, as well as with business partners for marketing purposes.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

Sharing with business partners for marketing purposes goes beyond operational necessity and means your data may be used by companies outside Nintendo's direct control to market products to you.

Interpretive note: The distinction between service providers and business partners, and whether business partner sharing constitutes a 'sale' under CCPA, requires analysis of specific contractual arrangements not disclosed in the policy.

Recent Activity

This document changed recently

Medium Apr 19, 2026

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, an…

Medium Apr 8, 2026

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 expl…

Consumer impact (what this means for users)

Your personal data including gameplay history, purchase records, and contact information may be shared with Nintendo's service providers and business partners, some of whom may use it for their own marketing purposes, extending the reach of your data beyond Nintendo itself.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Opt Out of Arbitration
    Log in to your Nintendo Account and review marketing and data sharing preferences to opt out of data sharing with business partners for marketing purposes. California residents should also submit an opt-out of sale or sharing request via Nintendo's privacy request page.

How other platforms handle this

HubSpot Medium

We may share your personal data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. We may also share your personal data with advertising partners to display relevant advertising to y...

Ideogram Medium

We may share your personal information with third-party vendors and service providers that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.

Steam Medium

In order to provide you with services, Valve needs to share some data with the publisher or developer of the game (for example to verify your ownership of the game and register your Steam ID with the publisher), or with other third parties that Valve works with to provide services to you. Valve will...

See all platforms with this clause type →

Monitoring

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▸ View Original Clause Language DOCUMENT RECORD
"
We may share your information with third parties that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. We may also share your information with business partners who offer products or services that may be of interest to you.

— Excerpt from Nintendo's Nintendo Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: Data sharing with service providers must comply with CCPA requirements that service providers are contractually prohibited from retaining, using, or disclosing personal information outside the business purpose; sharing with 'business partners' for marketing may qualify as a 'sale' or 'sharing' of personal information under CCPA triggering opt-out rights. GDPR requires that data transfers to third parties have a valid lawful basis and that data processors be bound by appropriate contractual terms (Article 28 agreements). Cross-border data transfers to Nintendo affiliates or service providers outside the EEA require an adequacy decision or appropriate safeguards such as Standard Contractual Clauses. GOVERNANCE EXPOSURE: Medium. The distinction between service providers (who process data only on Nintendo's behalf) and business partners (who may use data for their own marketing) is operationally significant under CCPA and GDPR. If business partner data sharing constitutes a 'sale' or 'sharing' without an adequate opt-out mechanism, this creates direct regulatory risk. JURISDICTION FLAGS: California residents have opt-out rights for any sharing that qualifies under CCPA, and the California Privacy Protection Agency has enforcement authority. EU/EEA users require that any international data transfer be covered by Standard Contractual Clauses or another GDPR-compliant transfer mechanism. Other state privacy laws (Virginia, Colorado, Connecticut) impose similar opt-out rights for data sharing with third parties for advertising. CONTRACT AND VENDOR IMPLICATIONS: The policy does not enumerate specific service providers or business partners, which limits transparency for compliance due diligence. Vendor agreements should clearly distinguish between service provider relationships (with data processing agreements) and business partner relationships (which require opt-out mechanisms). Procurement teams should assess whether existing vendor agreements meet updated CCPA and GDPR contractual requirements. COMPLIANCE CONSIDERATIONS: Legal teams should maintain an up-to-date list of all third-party data recipients, categorized as service providers versus business partners, with the legal basis and contractual framework for each sharing relationship documented. The opt-out mechanism for business partner data sharing should be tested to verify it functions correctly and that opt-out signals are passed through to all relevant partners.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC enforces consumer protection standards for data sharing disclosures and unfair or deceptive practices related to third-party data sharing.
    File a complaint →

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
COPPA
United States Federal
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Nintendo Privacy Policy
Entity
Nintendo
Document last updated
May 5, 2026
Tracking information
First tracked
April 27, 2026
Last verified
May 9, 2026
Record ID
CA-P-007768
Document ID
CA-D-00188
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
94a38174c3b24f4e3380e9d872d771e4dd3afb1ae90c825712e208f67bca9dc6
Analysis generated
April 27, 2026 13:59 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Nintendo
Document: Nintendo Privacy Policy
Record ID: CA-P-007768
Captured: 2026-04-27 13:59:08 UTC
SHA-256: 94a38174c3b24f4e…
URL: https://conductatlas.com/platform/nintendo/nintendo-privacy-policy/third-party-data-sharing-with-service-providers-and-partners/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Nintendo's Third-Party Data Sharing with Service Providers and Partners clause do?

Sharing with business partners for marketing purposes goes beyond operational necessity and means your data may be used by companies outside Nintendo's direct control to market products to you.

How does this clause affect you?

Your personal data including gameplay history, purchase records, and contact information may be shared with Nintendo's service providers and business partners, some of whom may use it for their own marketing purposes, extending the reach of your data beyond Nintendo itself.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 7 platforms. See the full comparison.

Is ConductAtlas affiliated with Nintendo?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Nintendo.