Privacy Policy

(Bangladesh)

PRIVACY POLICY

Last updated April 2, 2025

This Privacy Notice for Echelon Prime, Inc ("we," "us," or "our") describes how we collect, store, use, and share ("process") your personal information when you use our services ("Services"), including when you:

  • Download and use our mobile application (Nova Nerds) or any other application that links to this Privacy Notice.
  • Engage with us through customer support, marketing, or events.

Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies, please refrain from using our Services. If you have questions, contact us at support@echelonprime.com.

SUMMARY OF KEY POINTS

  • We collect personal information such as email addresses, usernames, and authentication data.
  • We do not process sensitive personal information unless required by law or with explicit user consent.
  • We may collect data from third-party sources like marketing partners, social media platforms, and analytics services.
  • We process your information to provide services, improve functionality, ensure security, and comply with legal obligations.
  • Your personal data may be transferred outside Bangladesh, with safeguards in place to ensure compliance with privacy laws.
  • You have the right to access, correct, or request deletion of your data.
  • If a data breach occurs, we follow an internal protocol to notify affected users promptly.
  • You can opt out of marketing communications by updating your preferences or emailing us.

1. WHAT INFORMATION DO WE COLLECT?

Personal Information You Provide

We collect personal information that you voluntarily provide, including:

  • Email addresses
  • Usernames
  • Authentication data

All information must be accurate and updated.

Information Automatically Collected

When you use our Services, we may automatically collect:

  • Device Information: IP address, operating system, and device type.
  • Usage Data: Features accessed, in-game actions, and interactions.
  • Location Data: Approximate geographic location (you may opt out in device settings).

Children’s Privacy & Parental Consent

  • Under our policy and anticipated law, children under 18 years old require verifiable parental consent.
  • Parents can provide consent through email verification, government ID, or a nominal credit card charge.
  • If we collect data from a minor without consent, we will immediately delete the data.
  • Parents may request data deletion via support@echelonprime.com.

1A. LEGAL BASIS FOR PROCESSING

We process personal data based on one or more of the following lawful grounds:

  • Consent: When you voluntarily agree to the processing.
  • Contractual necessity: When processing is necessary to fulfill our agreement with you.
  • Legal obligation: To comply with laws or regulations.
  • Legitimate interest: For operating and improving our Services in a secure and lawful manner.

2. HOW DO WE PROCESS YOUR INFORMATION?

We use your data to:

  • Create and manage user accounts.
  • Deliver, maintain, and improve our Services.
  • Provide customer support and resolve inquiries.
  • Send administrative and promotional communications (with opt-out options provided).
  • Ensure security and prevent fraud.

3. DATA SHARING & THIRD PARTIES

We may share data with trusted third parties such as:

  • Cloud services (Google Cloud, Azure PlayFab)
  • Analytics providers (Google Analytics)
  • Advertising platforms (Unity Ads)
  • Authentication services (Google Sign-In)

All third-party service providers are contractually obligated to protect user data and use it only for agreed purposes. We do not sell personal data.

4. CROSS-BORDER DATA TRANSFERS

Your personal data may be stored and processed outside Bangladesh, including in the United States and the Philippines. We ensure that:

  • Transfers are made only to countries with adequate protections, or
  • We use Standard Contractual Clauses (SCCs) and other legally binding instruments.

Users may request details or opt out of transfers by emailing support@echelonprime.com.

5. DATA RETENTION & DELETION

  • We retain personal information only as long as necessary for our business and legal obligations.
  • Typically, data is retained for up to three months after account termination.
  • You can request immediate data deletion at support@echelonprime.com.

6. SECURITY MEASURES

We implement technical and organizational safeguards including:

  • Encryption of data in transit and at rest.
  • Access control and audit logging.
  • Routine vulnerability assessments.

7. USER RIGHTS UNDER BANGLADESH LAW

Subject to applicable data laws, you have the right to:

  • Access your personal data
  • Correct inaccurate or outdated information
  • Request deletion of your data
  • Withdraw consent
  • Object to certain processing types (e.g. marketing)
  • Request a copy of your data in machine-readable format

To exercise your rights, contact support@echelonprime.com.

8. DATA BREACH NOTIFICATION

In the event of a serious breach:

  • We will notify affected users as soon as possible.
  • While Bangladesh does not yet have a formal data protection authority, we maintain an internal data breach register and follow a documented incident response plan.

9. MARKETING & TRACKING TECHNOLOGIES

  • You may opt out of receiving marketing messages anytime.
  • Our app may use cookies or similar tracking tools for:
    • App performance analytics
    • In-game behavior tracking
    • Targeted advertising and personalization

You may control these in your device or in-app settings.

10. UPDATES TO THIS POLICY

This Privacy Policy may be updated periodically. Any changes will be posted with a new last updated date. We encourage users to review it regularly.

11. CONTACT INFORMATION

If you have questions about this Privacy Policy or wish to exercise your rights:

Echelon Prime, Inc
1860 Chicago Ave Ste G20
Riverside, CA 92507, United States

Email: support@echelonprime.com
Protection Officer: dpo@echelonprime.com

This Privacy Policy aligns with the current regulatory framework in Bangladesh and anticipates forthcoming obligations under the Data Protection Act, 2023. We are committed to updating our practices in line with national regulatory guidance as it becomes available.