ENHANCE EXPERIENCE, INC.
Last Updated: January 31, 2024
Enhance Experience Inc. (“Enhance,” “we,” “us,” or “our”) welcomes you to the website (https://tetriseffect.game) (the “Site”) for our game, Tetris Effect: Connected, (the “Game”). Through the Site, we provide sales and marketing information about our company, our products, and our technologies (such information, together with the Site and the Game, the “Services”).
This policy DOES NOT apply to information that you provide to or is collected by any third party, or which is collected outside of the Services (see “Third-Party Information Collection”).
- DATA CONTROLLER
Email: Click here to e-mail us
Enhance Experience Inc.
100 Moffett Blvd, Suite B301,
Mountain View, CA 94043 USA
Our Services is not directed to or intended for children who are under the age of 16. Enhance does not knowingly collect Personal Data from children under the age of 16. If we learn we have collected or received Personal Data from a child under 16 without verification of parental consent, we will delete that information. If you have reason to believe that a child under the age of 16 has provided Personal Data to Enhance through the Services please contact us and we will endeavor to delete that information from our databases. This in compliance with the Children’s Online Privacy Protection Act and Article 6(1)(c) of the GDPR.
- PERSONAL DATA WE COLLECT
We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Data”) as follows:
Personal Data You Provide. We collect Personal Data from you when you provide them to us, for example in connection with our game tournaments, request a demo, apply for a job, make a press inquiry, download an application for your console, ask for help when using our Services, fill out our Influencer Application Form, or contact us. This Personal Data consists of the information that you choose to input into the Services and may include your first name, last name, email address, resume, work history, social networking handle, country, gaming platform. It is currently not possible for you to actively input personal information into the Game.
Automatically Collected Information. When you visit, use, and interact with the Services, we may receive certain information about your visit, use, or interactions.
- Log Data: Information that your browser automatically sends whenever you visit the Site. Log Data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Services.
- Usage Data: We collect information about how you use our Services, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.
- Location Data: We derive a rough estimate of your location from your IP address.
On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:
Information Collected Automatically Through the Game. We collect limited information passively through the Game such as your unique in-game ID, your platform ID, username, and usage details such as information about the resources you have used, your in-game friends, scores and the stages that you have cleared within the Game. Additionally, some of the features of the Game are serviced by Third Party Services (defined below). When you use the Game, these Third-Party Services may use automatic information collection technologies to collect information about you or your device.
Please see the list of Third-Party Services below:
Third Party Information Collection Through the Game:
- Epic Games analytics provides us with analytics information such as user demographics, user engagement, and information about revenue and refunds related to sales of the Game.
- Meta provides us with analytics information such as user demographics, user engagement, crash analytics, performance analytics and information about revenue and refunds related to sales of the Game.
- Microsoft analytics provides us with sales metrics, user demographics and content performance information.
- Nintendo analytics provides us with sales metrics and user engagement.
- Sony Analytics provides us with sales metrics, user demographics and content performance information.
- Valve (Steam) Analytics provides us with revenue and refund information related to sales of the Game, sales metrics, user statistics, and aggregated information about user hardware for the purpose of optimizing the Game.
- Amazon Luna analytics provides us with user engagement information.
Third Party Information Collection Through the Site:
- Google Analytics provides us with analytics information related to the Site including number of unique visitors, their source, pages visited, and resources used, session and campaign data.
- Our Legal Bases For Processing Your Information (For Residents of the UK/EU)
When we collect or otherwise process any of your Personal Data, we do so in reliance on the following legal bases:
- Your consent. If you have provided us with your consent to process your information for a specific purpose we will do so based on your consent. You may withdraw your consent at any time by following the instructions provided below in the “Your Rights and Choices” section below.
- Performance of a Contract with You. When the processing of your Personal Data is necessary in order for us to perform a contract with you, such as the EULA or Terms of Services associated with Game or the Site, or when you request that we process your information prior to entering into a contract with you, we will do so on this basis.
- Our Legitimate Interests. When we believe the processing of your Personal Data is reasonably necessary in order for us to achieve our legitimate interests in conducting and managing our business and our relationship with you, we will do so on this basis, including the legitimate interest we have in:
- personalizing, enhancing, modifying or otherwise improving the services and/or the communications that we provide to you;
- retaining and engaging you and our other users;
- detecting and preventing fraud and operating a safe and lawful business; and
- improving the security and optimization of our network, sites and services.
When we use your information for our legitimate interests, we take into account any potential impact that such use may have on you by balancing our legitimate interests against your interests, rights and freedoms. We will not use your information if there is a less intrusive way for us to achieve our legitimate interests or if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation).
- Our Legal Obligations. When we believe that the processing of your information is necessary in order for us to comply with our legal obligations (such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved) we will do so on this basis.
- Vital Interests. When we believe that the processing of your information is necessary in order to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person, we will do so on this basis.
- HOW WE USE PERSONAL DATA
We may use Personal Data for the following purposes:
- To provide, support and maintain the Services and their contents, and any other information, or services that you request from us.
- To optimize, develop, and improve the Services.
- To track sales.
- To analyze how you interact with our Services.
- To provide you with customer support.
- To communicate about promotions, upcoming events, and other news about our games and services with your consent.
- To respond to your inquiries, comments, feedback, or questions regarding the Services.
- To evaluate potential candidates for employment.
- To send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies.
- To evaluate whether or not to include you in our influencer program.
- To respond to you if you contact us.
- To fulfill any other purpose for which you provide it.
- To develop new products and services.
- To prevent fraud, criminal activity, or misuses of our Services.
- To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.
- For any reason that we described to you when collecting your Personal Data or for any reason for which you’ve provided us with your consent.
- To help maintain the safety, security, and integrity of the Services, our IT systems, architecture, networks, databases and other technology assets.
- To protect the rights, interests, and safety of us, you, and any third parties, and to exercise and defend our rights.
The usage information we collect helps us to improve our Services and to deliver a better and more personalized experience by enabling us to:
- Recognize you when you use the Services.
- Estimate our audience size, demographics and usage patterns.
- Store your preferences, consents and other user settings locally on your device.
- Comply with your consents.
- Understand how well Services features are working and whether users are having issues.
- Identify and correct software defects.
- Prevent fraud and illegal behavior by detecting behavior patterns that indicate such activity.
- SHARING AND DISCLOSURE OF PERSONAL DATA
In certain circumstances we may share the categories of Personal Data described above without further notice to you, unless required by the law, with the following categories of third parties:
- Vendors and Services Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Data in the course of performing their duties to us.
- Business Transfers: We may disclose your information to our subsidiaries and affiliates. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
- Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a court order, regulatory request or other legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services, or the public, or (v) protect against legal liability.
- Enforcing our Rights: We may disclose your information as necessary to enforce our rights arising from any contracts entered into between you and us, such as our EULA.
- Necessary for Purpose: We may disclose your information as necessary to fulfill the purpose for which you provided it.
- With Your Consent: We may disclose your information with your consent.
- Other purposes: We may disclose your information for any other purpose disclosed by us and accepted by you when you provide the information.
- WHERE, HOW AND HOW LONG WE STORE YOUR INFORMATION
Information that we collect through the Game is stored in Japan and all other information that we collect is stored in the US. We store all Personal Data securely using third-party vendors who implement industry standard security measures. By using the Services, you authorize us to receive, process, transfer, and store your information in and to Japan or the United States, as applicable.
We keep your information only for the length of time necessary to fulfill the purposes for which the information was collected. For example, if you have an account with us, we will retain the Personal Data associated with your account for the lifetime of your account and for a reasonable period of time thereafter if necessary. If applicable laws require us to store your information for a longer period, then we will keep your information for the period required by law. When it is no longer necessary or required for us to retain your data, we will delete it.
Cross-border Data Transfers: Where cross-border transfers of data are necessary, we will take reasonable steps to safeguard the privacy of your Personal Data. These steps may include implementing standard contractual clauses where recognized by law, obtaining your consent, or other lawful means of transferring Personal Data.
- DATA SECURITY
We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure by partnering with third parties who use industry standard security measures to protect your information.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through our Services. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
- YOUR RIGHTS AND CHOICES
In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Services, you may be unable to use those features.
We strive to provide you with choices regarding the Personal Data you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures over your information.
- Disabling Cookies: You can limit cookie collection by disabling cookies in your browser settings. Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.
- If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.
- Updating or correcting your information: Please click here to e-mail us a request if you need to change or correct your Personal Data.
- Promotion by us: If you have opted in to receiving email communications from us and you want us to discontinue using your email address to promote our own or third parties’ products or services, you can opt-out by clicking the unsubscribe link at the bottom of our emails and following the instructions provided.
- Deleting Your Personal Data: We provide all of our data subjects with the Right to be Forgotten (also known as the Right to the Deletion of your Personal Data ), whether or not you reside or are a citizen of the European Union or the United Kingdom. Please click here to e-mail us a request if you would like us to delete your Personal Data.
Please note however that the Right to be Forgotten is not an absolute right. The Right to be Forgotten only applies to the following types of Personal Data that are held by us at the time of the request:
- Personal Data that was processed on the basis of consent,
- Personal Data that was processed on the basis of legitimate interests,
- Personal Data processed on a basis other than consent or legitimate interests that is no longer required for the purpose for which it was original collected or processed,
- Personal Data that was processed unlawfully,
- Personal Data that must be deleted in order to comply with a legal obligation, or
- Personal Data of a child.
- Third parties: We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.
For more information about the third parties that collect data through the Services, see the “Third Party Information Collection” section above to understand which third parties have access to your Personal Data through the Services. You can consult their privacy policies to see if they offer additional options for limiting collection.
Data Rights of European Residents: The laws of the United Kingdom and the European Economic Area and other territories provide their residents with certain data protection rights. If you are resident of the United Kingdom or the European Economic Area, these are your rights:
- The right to access – You have the right to request Enhance provide you with copies of your personal data. We may charge you a small fee for this service.
- The right to rectification – You have the right to request that Enhance correct any information you believe is inaccurate. You also have the right to request Enhance to complete information you believe is incomplete.
- The right to be forgotten – You have the right to request that Enhance erase certain types of personal data (see Deleting Your Personal Data above).
- The right to restrict processing – You have the right to request that Enhance restrict the processing of your personal data, under certain conditions.
- The right to object to processing – You have the right to object to Enhance’ processing of your personal data, under certain conditions.
- The right to data portability – You have the right to request that Enhance transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please click here to e-mail us.
Personal Information Rights for California Residents:
Shine the Light. Under California Civil Code Section 1798.83, ( the “Shine The Light” law), California residents who use the Services may request and obtain from us, once a year and free of charge, information about categories of Personal Data (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared Personal Data in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
Minors. California residents who have an account with us and who are under 18 years of age have the right to request deletion of any data that such users post on the Services, if any. To request deletion of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
- CONTACT US