Digital Product Privacy Policy (Pictonico!)

Version 05.2026 (EN-EU)

Nintendo Co., Ltd., 11-1 Hokotate-cho, Kamitoba, Minami-ku Kyoto, 601-8501, Japan, pictonico@support.nintendo.com (“Nintendo”) respects the privacy rights of its users and recognises the importance of protecting their personal data. This Digital Product Privacy Policy (the “Privacy Policy”) provides information relating to the collection, processing, use and privacy of information that is collected when using Pictonico! (the "Digital Product") or that you submit through or in relation to the Digital Product, such as when you address any inquiries or opinions about the Digital Product to us.

Nintendo is the controller of your personal information within the meaning of the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 – “GDPR”).

Words and expressions in this Privacy Policy have the same meaning as in the End User License Agreement for the Digital Product.

1    What Information We Collect and Process

1.1    Information about Your Person

If you have any inquiries or opinions about the Digital Product, you can contact us via our general support email address specified on the store page of the Digital Product or in this Privacy Policy. If you address such enquiry to us, we process your email address and any other personal data you submit to us to be able to answer to your enquiry or opinion.

1.2    Information about the Device You Use

When the device on which your Digital Product is used is connected to Nintendo servers, we may collect and process technical information related to your device, such as MAC address, IP address, serial number or other alphanumeric codes assigned to your device, device name, OS version, network type, or user agent, as well as technical information related to the Digital Product you use, such as the client type and version. 

We may also collect and process information about the settings of the device you use which help us to optimise your experience, such as country settings, language settings.

1.3    Information Related to Your Use of the Digital Product

In order to use the Digital Product, you may need to provide the preferred language, the country of residence and other preferences you wish to set for your user experience. The provision of this information is necessary to set the Digital Product according to your preferences and to provide you with language- and country-specific content.

To enable you to enjoy all features of your Digital Product, we process the data related to your activities, such as the alphanumeric codes assigned to your Digital Product and other data specific to the features of the Digital Product that you use. 

2    How Information Is Used – Purposes of Processing

2.1    Providing the Service

We collect and further process the information in order to:

The legal basis for the processing referred to in this Section 2.1 is the provision of the service you have requested and the performance of the contract with you (Art. 6 para. 1 (b) GDPR).

2.2    Fraud Prevention and Prevention of Other Illegal Activities

We may process the collected information relating to the use of the Digital Product to prevent fraud, potentially illegal or offensive activities or to enforce our rights or the rights of other users. This includes ensuring the confidentiality of our users' personal data, preventing unauthorised access to or modifications of the Digital Product, our systems or networks, and maintaining the security of personal data. Suspicious activities can lead to accounts being reported and blocked.

The legal basis for this processing is Art. 6 para. 1 (f) GDPR. The legitimate interest we pursue is the prevention of fraudulent and illegal activities, the protection of our systems and networks, of our services and of our users and the enforcement of our legitimate rights and rights of our users.

You have the right to object, on grounds relating to your particular situation, at any time to such processing. To exercise this right you may at any time contact us as provided in Section 7 of this Privacy Policy.

2.3    Provision of the service

We process the Usage Information for the provision of the service of the Digital Product described in Section 2.1, including its content, services and features. The legal basis for the processing referred to in this Section 2.3 is the provision of the service you have requested and the performance of the contract with you (Art. 6 para. 1 (b) GDPR).

“Usage Information” as referred to in this Section 2.3 includes all information submitted through the Digital Product as well as all information collected and processed when using the Digital Product.

2.4    Push Notifications

The Digital Product may offer a service to send you push notifications to your device. We need your consent before we can send you push notifications. The push notifications may include the latest game information, news, customised recommendations, offers or other game-related content. 

The legal basis for the processing of your information for providing you with push notifications is your consent (Art. 6 para. 1 (a) GDPR).

You can withdraw your consent to this processing of your information and the push notification service at any time by deactivating the authorisation you gave us in the settings of your device.

3    User Communications

When you send an email or other communication to Nintendo (which includes contacting us with any enquiries or opinions via the store page), we use those communications in order to process your inquiries and respond to your requests.

The legal basis for this processing is the provision of the service you have requested and the performance of the contract with you (Art. 6 para. 1 (b) GDPR). If you have not entered into a contract with us when you contact us, the legal basis for this processing is our legitimate interests in properly handling and replying to your enquiry (Art. 6 para. 1 (f) GDPR). 

4    Who Has Access to Your Information

Nintendo may share your information with other entities of the Nintendo group to be used in accordance with this Privacy Policy; in particular, with:

If Nintendo shares your information with Nintendo of America Inc. or with Nintendo Australia Pty Limited appropriate safeguards for an adequate level of data protection are provided for by standard data protection clauses that have been adopted by the European Commission and that have been entered into between Nintendo and Nintendo of America Inc. or Nintendo Australia Pty Limited.

The legal basis for Nintendo sharing your information with other entities of the Nintendo group is Art. 6 para. 1 (f) GDPR. We have a legitimate interest in sharing your information for internal administrative purposes, in particular to offer the Digital Product and to deal with any inquiries in an efficient and high-quality manner. You have the right to object, on grounds relating to your particular situation, at any time to such sharing. To exercise this right you may at any time contact us as provided in Section 7 of this Privacy Policy.

In compliance with applicable data protection requirements, Nintendo may also use third-party data processors and may share your information with such third-party data processors acting on Nintendo’s behalf to provide services in connection with the Digital Product. Where such third-party processors are located outside the European Union or the European Economic Area, such third-party processors are either located in a third country where the European Commission has decided that this country ensures an adequate level or appropriate safeguards for an adequate level of data protection are provided for in compliance with GDPR, such as standard data protection clauses that have been adopted by the European Commission and that have been entered into between Nintendo and the third-party data processor.

5    Storage Time

We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or – where the applicable law provides for longer storage and retention periods – for the storage and retention period required by law. After that your personal data will be deleted.

In particular:

6    Your rights under GDPR

In particular, but without limitation, you may have the following rights under applicable European data protection law:

7    Nintendo’s European Representative and Contact

If you have any questions about this Privacy Policy and Nintendo’s data processing activities or if you want to exercise any of your rights under GDPR, please contact:

Nintendo’s European representative Nintendo of Europe SE, Attn.: Legal Department, Goldsteinstrasse 235, D-60528 Frankfurt am Main, Germany, or via email at privacyinquiry.ncl@nintendo.de.

8    Nintendo’s Data Protection Officer:

Nintendo Co., Ltd., Attn.: Data Protection Officer, 11-1 Hokotate-cho, Kamitoba, Minami-ku, Kyoto, 601-8501, Japan, or via email at dataprotectionofficer@nintendo.co.jp.

9    Updates to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes of our data processing activities. Therefore, please make sure that you always read the most recent version.