Privacy Policy

(Ghana)

PRIVACY POLICY

Last updated March 2, 2025

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

  • Downloading and using our mobile application (Nova Nerds)
  • Interacting with us through support, feedback, or promotional activities

This Policy is written in compliance with the Ghana Data Protection Act, 2012 (Act 843).

SUMMARY OF KEY POINTS

  • We collect and process only necessary data for service provision.
  • Parental consent is required for users under age 18.
  • Users have all rights guaranteed under Act 843.
  • Cross-border transfers are managed under Section 44 of the DPA.
  • Profiling and marketing preferences can be controlled by the user.
  • In the event of a breach, users and regulators will be notified as required.

1. WHAT INFORMATION DO WE COLLECT?

Personal Information You Provide

We collect the following types of data:

  • Email address
  • Username or display name
  • Authentication tokens or credentials (e.g., Google/Apple login)

Automatically Collected Data

We collect technical and usage data such as:

  • Device information (model, OS, IP address)
  • In-game actions, user preferences, and performance metrics
  • Approximate location (based on IP, disabled via device settings)

Children’s Data & Parental Consent

Users under 18 must obtain verified parental consent. We do not knowingly process data from minors without such consent. Parents may request deletion of a child’s data via support@echelonprime.com.

1A. LEGAL BASIS FOR PROCESSING

In accordance with Ghana’s DPA and international best practice, we process personal data based on one or more of the following legal bases:

  • Consent: Where you have voluntarily provided permission
  • Contractual Necessity: To provide the Nova Nerds game and its features
  • Legal Obligation: When required to comply with Ghanaian law
  • Legitimate Interest: For purposes such as improving service performance and ensuring security, provided such processing does not override your fundamental rights

2. HOW DO WE USE YOUR DATA?

Your data is used for the following purposes:

  • Account setup and login functionality
  • Delivery of gameplay, updates, and player support
  • Enhancing app performance and personalizing game content
  • Sending administrative notices (e.g., account alerts)
  • With consent, sending promotional offers or updates

We may use automated tools to recommend in-game content or personalize features. You may object to such profiling by contacting support@echelonprime.com.

3. SHARING YOUR DATA

We only share your data with trusted service providers:

  • Cloud infrastructure (e.g., Google Cloud, Azure PlayFab)
  • Ad networks (e.g., Unity Ads)
  • Analytics platforms (e.g., Google Analytics)
  • Authentication providers (e.g., Google Sign-In)

All vendors are required to comply with strict data protection and confidentiality obligations. We do not sell your data.

4. CROSS-BORDER DATA TRANSFERS

Your data may be stored or processed outside Ghana. Pursuant to Section 44 of the DPA, we ensure:

  • Transfers only occur to countries with adequate data protection
  • Standard contractual safeguards are in place

You may request further information about such transfers by contacting us.

5. DATA RETENTION

We retain personal data:

  • While your account is active
  • As required to fulfill our legal or contractual obligations

Data from inactive accounts may be deleted after 12 months. You can request deletion at any time.

6. SECURITY MEASURES

We protect your data using:

  • Encryption (in transit and at rest)
  • Access controls and password protection
  • Monitoring and audit logs

7. YOUR RIGHTS UNDER GHANA LAW

Under Act 843, you have the right to:

  • Access your data
  • Correct inaccuracies
  • Request deletion of your data
  • Object to or restrict processing
  • Withdraw your consent
  • Request data portability
  • Object to profiling and automated decision-making

To exercise any of these rights, email us at support@echelonprime.com.

8. BREACH NOTIFICATION

In case of a data breach, we will:

  • Notify affected users as soon as practicable
  • Report the breach to the Data Protection Commission as required by Act 843
  • Provide users with remedial steps and updates on the resolution

9. MARKETING & TRACKING TECHNOLOGIES

  • You can opt out of marketing emails via unsubscribe links or by emailing us
  • Cookies or SDKs may be used for analytics and ads
  • Users may opt out of tracking via device privacy settings

10. UPDATES TO THIS POLICY

We may revise this policy from time to time. Any updates will be reflected with a new "last updated" date at the top of this document.

11. CONTACT INFORMATION

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

Email: support@echelonprime.com

Data Protection Officer: dpo@echelonprime.com

This Privacy Policy complies with the Ghana Data Protection Act, 2012 (Act 843) and represents our commitment to responsible data stewardship.