Provision record
Nintendo · Nintendo Privacy Policy · View original document ↗

User Data Rights and Non-Discrimination

Medium severity Medium confidence Explicit document language Unique · 0 of 352 platforms
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Document Record

What it is

The policy states that users have the right to request access, correction, or deletion of their information, and that Nintendo will not discriminate against users for exercising these rights, though some service features may change or become unavailable as a result.

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)

The non-discrimination commitment is consistent with CCPA and CPRA requirements, but the policy's qualification that service features 'may change, or no longer be available' upon exercise of data rights should be evaluated to confirm it reflects operationally necessary limitations rather than practical disincentives to rights exercise.

Interpretive note: Whether the policy's qualification that service features 'may change or no longer be available' upon rights exercise constitutes a permissible operational limitation or a practical deterrent to rights exercise under CCPA and CPRA non-discrimination standards depends on the specific features affected and regulatory interpretation.

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, 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 →
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 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 →
Medium Mar 19, 2026

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 →

Clause Stability Stable

0
Changes
5
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under this provision, users may submit requests to access, correct, or delete their personal information using the instructions provided in the policy. The policy states Nintendo will not discriminate against users who exercise these rights, while noting that certain service features may be affected by data deletion or correction requests.

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.
  • Delete Your Data
    Submit a data access, correction, or deletion request by following the instructions linked in Section 4 of the Nintendo Privacy Policy, or by contacting Nintendo at privacypolicy@noa.nintendo.com or 1-888-977-7627.
  • Export Your Data
    Submit a data access request by following the instructions linked in Section 4 of the Nintendo Privacy Policy or by emailing privacypolicy@noa.nintendo.com. Specify that you are requesting access to your personal information.

Cross-platform context

See how other platforms handle User Data Rights and Non-Discrimination and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
You have the right to request access to, correction, or deletion of your information. For instructions on how to submit such a request go here. We will not discriminate against you for exercising your rights and choices, however some of the functionality and features of our services may change, or no longer be available to you.

Excerpt from Nintendo's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

REGULATORY LANDSCAPE: The non-discrimination requirement for exercising data rights is mandated by CCPA and CPRA, enforced by the California Privacy Protection Agency and California Attorney General.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

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
July 9, 2026
Record ID
CA-P-015918
Document ID
CA-D-00188
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
08c602b01bc20ce68b00c8f8914733f3a8367c9aa9dd499607c67822e3987487
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-015918
Captured: 2026-04-27 13:59:08 UTC
SHA-256: 08c602b01bc20ce6…
URL: https://conductatlas.com/platform/nintendo/nintendo-privacy-policy/provision/CA-P-015918/user-data-rights-and-non-discrimination/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Nintendo's User Data Rights and Non-Discrimination clause do?

The non-discrimination commitment is consistent with CCPA and CPRA requirements, but the policy's qualification that service features 'may change, or no longer be available' upon exercise of data rights should be evaluated to confirm it reflects operationally necessary limitations rather than practical disincentives to rights exercise.

How does this clause affect you?

Under this provision, users may submit requests to access, correct, or delete their personal information using the instructions provided in the policy. The policy states Nintendo will not discriminate against users who exercise these rights, while noting that certain service features may be affected by data deletion or correction requests.

Is ConductAtlas affiliated with Nintendo?

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