Most sites have a link in the footer, which is what I assume they were after.
When I tried the custom hamburger menu links component, I was told that the privacy policy was still not compliant (their email specifically said accessible in one click - the joys of undocumented guidelines). They only stopped giving me grief after I added a link in the footer.
That said Google is not known for consistent enforcement so it may have been an overzealous reviewer for my case.
Yeah I’m aware the guidelines only say it must he “accessible”, but they can and have been obnoxious because they deemed it “not prominent enough”.