Digital Product Privacy Policy (Fire Emblem Shadows)

Version 09.2025 (EN-EU)

Nintendo Co., Ltd., 11-1 Hokotate-cho, Kamitoba, Minami-ku Kyoto, 601-8501, Japan, fire-emblem-shadows-support@nintendo.co.jp(“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 Fire Emblem Shadows (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. You can further provide us with feedback on the Digital Product in the comments section of the store page or by participating in user surveys. If you address such enquiry or opinion to us, we process your email address, nickname, player ID 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 Transactions

If you use the Digital Product to make any transactions, we collect and process information about these transactions, such as the registration of licences, purchase of items, date and time of the purchase, total amount charged, use of items, payments and other related activities.

1.4 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 nickname, appearance and profile of the character representing you in the Digital Product, alphanumeric codes assigned to your Digital Product, friends and favourites that you registered, other users you played with, User-Generated Content that you uploaded, posted or otherwise made available via the Digital Product, your online presence information, details on your character and items, battle and matchmaking statistics, season pass information, activities related to the trading of items and other data specific to the features of the Digital Product that you use.

We may also collect your activity history data such as which features of the Digital Product you used, at what times you played, which orders you made, items you traded, and challenges you completed, your level, score, story and scenario progress and in-game location. With your consent, we may also collect and process crash reports to further improve the game.

1.5 Linking to Your Nintendo Account

You can create and/or link a Nintendo Account in the Digital Product. You do not need a Nintendo Account to start or use the Digital Product, but it may be required to use certain features of the Digital Product. If you link your Nintendo Account to the Digital Product, Nintendo may collect and combine information related to your use of both the Digital Product and your Nintendo Account. Any opt-in or opt-out settings you have chosen in your Digital Product continue to apply to your use of the Digital Product. The Nintendo Account Privacy Policy applies to the processing of your information in connection with your Nintendo Account. The Nintendo Account Privacy Policy is available at https://accounts.nintendo.com/termchooser/privacypolicy.

1.6 Cookies and Similar Technologies

1.6.1 General Information

The Digital Product may use cookies and similar technologies (collectively "Cookies"). Cookies are small files downloaded to your device. Cookies do not contain viruses or otherwise harmful software. They collect and store information related to your device or to your use of the Digital Product, including certain information mentioned above. Cookies help us to ensure the safety and smooth functionality of our services (strictly necessary Cookies; see below), as well as to create crash reports for fixing errors and improving the Digital Product, and to display recommendations in the Digital Product (optional Cookies; see below).

Cookies may be set by us as the provider of the Digital Product (first-party Cookies) or by third parties whose services are integrated on the Digital Product (third-party Cookies). The Cookies are either deleted after the session when the Digital Product is closed (session Cookies) or after a certain period of time (permanent Cookies), but no later than two years.

You can choose which types of Cookies shall be allowed on your device. With the exception of strictly necessary Cookies that are required for the operation of the Digital Product (more information below), Cookies will only be activated if you explicitly allow it. See below for more information.

1.6.2 Strictly Necessary Cookies

Nintendo uses security and session Cookies that are strictly necessary to provide you with the services you have requested. For example, session Cookies are used to maintain your online session or to ensure the security and safety of the Digital Product. The legal basis for storing and accessing such strictly necessary Cookies on your device is the provision of the service you have requested. Any subsequent processing of your information is based on the performance of the contract with you (Art. 6 para. 1 (b) GDPR).

1.6.3 Optional Cookies (including New Relic)

With your consent, we collect information on your usage of the Digital Product, including technical information related to errors or crashes (crash reports), as well as information on the features, services, and content you are interested in when using the Digital Product. This information helps us to improve our products and services and to provide you with customised content and recommendations via the Digital Product.

The Digital Product uses New Relic, a web analysis service of New Relic, Inc. (188 Spear St., Suite 1000, San Francisco, California 94105, USA, “New Relic”) to collect information related to errors or crashes (crash reports). New Relic uses optional Cookies that are stored on your device and facilitate the analysis of your use of our services in the case of an error or crash. Any information generated by these Cookies may be transmitted to and stored by New Relic on servers located outside of the European Union, including servers in the United States. New Relic is certified under the EU-U.S. Data Privacy Framework and is also entered in the list maintained by the U.S. Department of Commerce (Data Privacy Framework List). Therefore, data transfers to the United States are based on the European Commission's adequacy decision (Art. 45 para. 1 GDPR). On our behalf, New Relic will use the transmitted information to compile crash reports for us, which help us to improve our products and services. You can find more information on the data processing by New Relic at New Relic Services Notices.

The legal basis for the collection of this information is your consent. We only activate New Relic and use optional Cookies when you have given us your consent to the collection of this information. You can freely withdraw your consent at any time with effect for the future in the settings of the Digital Product.

2 How Information Is Used – Purposes of Processing

2.1 Providing the Service

We collect and further process the information in order to:

Set up the connection of your device with Nintendo servers,
Register and/or link your Nintendo Account,
Enable your use of the Digital Product,
Provide you with content, services and features via the Digital Product, and to
Process requests that you make via the Digital Product, including customer support services.

If you use the Digital Product for making transactions, we process the information about the transactions you make to the extent necessary to process your orders, to provide you with the transaction history and to meet our financial and legal obligations.

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 Communication via the Digital Product

We may collect and process the information to provide you with the online features of the Digital Product, which enable you to play online with other users or to participate in online rankings as part of the Digital Product. If you choose to use such features, your user name, game character you use, game status and/or other gameplay and ranking data are shared with other users to enable you to play online with others and to participate in online rankings. 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).

Apart from the aforementioned features, parts of the Digital Product may support further communication between users and the exchange of User-Generated Content. If you choose to use such parts of the Digital Product, other users may be able to see some information about you, such as your nickname, the appearance and profile of any character representing you in the Digital Product and any User-Generated Content you submit. Depending on the features you use, your player history, your ranking and status may be shared between users or published online to enable the requested interaction. 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 set up a friend list or a black list for the Digital Product, this information may be processed to make sure that your choices are respected. 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).

By linking your Digital Product with the Nintendo Account offered by Nintendo (see Section 1.5.1 above), the friend list (with the nick names of your friends) registered with your Digital Product may be synchronised with any friend list registered with the Nintendo Account offered by Nintendo. The same applies if you are listed on the friend lists or black lists of other users of the Digital Product. 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).

2.4 Usage Information

“Usage Information” as referred to in this Section 2.4 includes all information submitted through the Digital Product as well as all information collected and processed when using the Digital Product.

2.4.1 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 2.4.1 is the provision of the service you have requested and the performance of the contract with you (Art. 6 para. 1 (b) GDPR).

2.4.2 Product and Service Improvement

We process the Usage Information to perform analytics and statistics of the usage of the Digital Product in order to improve and optimise the Digital Product, including technical performance, and our products and services.
The legal basis for this processing is Art. 6 para. 1 (f) GDPR. The legitimate interest we pursue is the improvement and optimization of the Digital Product and its performances which is to the benefit of the 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 opt out in the “Data Collection” settings of your Digital Product.

2.4.3 Customised Content and Recommendations

We may also process the Usage Information for purposes of customised marketing, so that content and services can be tailored to meet your needs and to enable customised recommendations and offers displayed to you via the Digital Product. More specifically, the information is used to recommend content, such as items offered by other users, in the in-game bazaar of the Digital Product. Customised recommendations have an increased relevance of the user and thus improve the online experience for the benefit of the user. The legal basis for this processing is Art. 6 para. 1 (a) GDPR. You can freely withdraw your consent at any time with effect for the future in the settings of the Digital Product

2.5 Linking to Your Nintendo Account

The linkage of the Digital Product with your Nintendo Account referred to in Section 1.5 is not necessary to start and use the Digital Product. However, you can choose to link your Nintendo Account, to benefit from certain features such as transferring or sharing of save data to another device. If you choose to link your Nintendo Account, the legal basis for the relevant processing of your information is the provision of the service you have requested and the performance of the contract (Art. 6 para. 1 (b) GDPR).

2.6 Cookies and Similar Technologies

The legal basis for using strictly necessary Cookies as explained in Section 1.6.2 above is the provision of the service you have requested. These Cookies help us to ensure the safety and smooth functionality of the Digital Product.

The legal basis for using optional Cookies as explained in Section 1.6.3 above is your consent. You can freely withdraw your consent and deactivate the collection of this data at any time with effect for the future in the settings of the Digital Product.

2.7 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).

When you participate in surveys relating to the Digital Product, we evaluate your feedback internally. This helps us improve our Digital Product, services and processes. Any survey you participate in is on a voluntary basis and not required to start or use the Digital Product. The results of the survey are anonymized prior to its evaluation. The legal basis for this processing is our legitimate interest in processing any feedback that you choose to provide on a voluntary basis, in order to improve and optimise the Digital Product for all users (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:

its European affiliate Nintendo of Europe SE and its branches in France, the Netherlands, Belgium, Italy, Germany, Austria, Switzerland, Portugal, Spain and the United Kingdom;
Nintendo of America Inc., located in the United States and Nintendo Australia Pty Limited, located in Australia. The level of data protection provided under the US and Australian law is lower than the level provided in the European Community.

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:

If you withdraw a consent on which a processing of your personal data is based, we will delete your personal data without undue delay to the extent that the collection and processing of the personal data was based on the withdrawn consent.
If you exercise a right to object to the processing of your personal data, we will delete your personal data that we processed for the purpose to which you objected without undue delay, unless another legal basis for processing and retaining this data exists or unless applicable law requires us to retain the data.

6 Your rights under GDPR

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

Right of access: You have the right to obtain confirmation from us as to whether or not we process personal data from you and you also have the right to at any time obtain access to your personal data stored by us. To exercise this right you may at any time contact us as provided in Section 7 of this Privacy Policy. You can also access the information you provided in the settings of your Digital Product.
Right to rectification of your personal data: If we process your personal data, we shall endeavour to ensure by implementing suitable measures that your personal data is accurate and up-to-date for the purposes for which we collected your personal data. If your personal data is inaccurate or incomplete, you have the right to obtain the rectification of such data. To exercise this right, you may at any time contact us as provided in Section 7 of this Privacy Policy. You can also change the information you provided in the settings of your Digital Product.
Right to erasure of your personal data or right to restriction of processing: You may have the right to obtain the erasure of your personal data or the restriction of processing of your personal data. To exercise this right you may at any time contact us as provided in Section 7 of this Privacy Policy.
Right to withdraw your consent: If you have given your consent to the processing of your personal data, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on the consent before the withdrawal. To exercise this right, you may at any time contact us as provided in Section 7 of this Privacy Policy.
Right to data portability: You may have the right to receive the personal data concerning you and which you have provided to us, in a structured, commonly used and machine-readable format or to transmit those data to another controller. To exercise this right, you may at any time contact us as provided in Section 7 of this Privacy Policy.
Right to object: You may have the right to object to the processing of your personal data as further specified in this Privacy Policy.
Right to lodge a complaint with supervisory authority: You have the right to lodge a complaint with a data protection supervisory authority located in the European Union. You may contact the Hesse Data Protection Supervisor.

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, 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.