Privacy Policy

(Hong Kong)

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 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.

This policy complies with the Personal Data (Privacy) Ordinance (PDPO) of Hong Kong.

SUMMARY OF KEY POINTS

  • We collect personal information such as email addresses, usernames, and authentication data.
  • We process data to operate, improve, and secure our Services.
  • We do not process sensitive personal data without your explicit consent.
  • We may collect data from third parties such as analytics and social login providers.
  • Your data may be transferred outside Hong Kong with appropriate safeguards.
  • You have the right to access, correct, delete, and object to the use of your data.
  • If a data breach occurs, we will notify affected users and cooperate with the Office of the Privacy Commissioner for Personal Data (PCPD) as appropriate.

1. WHAT INFORMATION DO WE COLLECT?

Personal Information You Provide

We collect data you provide directly to us:

  • Email addresses
  • Usernames
  • Authentication tokens (e.g., OAuth logins)

We only collect data that is adequate, relevant, and limited to what is necessary for our Services.

Information Automatically Collected

  • Device Information: IP address, operating system, device model
  • Usage Data: In-app behavior, preferences, and session length
  • Location Data: Approximate location based on IP (optional and may be disabled)

Children’s Privacy

Our Services are not directed at children under 13. Parental consent is required where applicable. If we learn that a child has provided data without proper authorization, we will delete it.

1A. LEGAL BASIS FOR PROCESSING

Although not required by the PDPO, for transparency, we disclose that we process your personal data based on one or more of the following legal bases:

  • Consent: You explicitly permit us to process your data.
  • Contractual Necessity: We process data to fulfill our agreement with you.
  • Legal Obligation: To comply with applicable laws.
  • Legitimate Interest: To improve, maintain, and secure our Services, provided such interests do not override your rights.

2. HOW DO WE PROCESS YOUR INFORMATION?

We use your data to:

  • Create and manage accounts (including user profile setup)
  • Operate and improve game features
  • Provide technical support
  • Send communications (including marketing if consented)
  • Ensure legal compliance and prevent abuse

If we use profiling to customize content or ads, you may object to this by contacting support@echelonprime.com.

3. DATA SHARING & THIRD PARTIES

We may share your data with:

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

All third parties must implement adequate data protection measures. We do not sell personal data.

4. CROSS-BORDER TRANSFERS

Data may be transferred to and stored in countries outside Hong Kong. Although Section 33 of the PDPO on cross-border data transfer is not yet in force, we apply the following safeguards:

  • Transfer to jurisdictions with comparable privacy protections, or
  • Use of Standard Contractual Clauses (SCCs) or other protective agreements.

5. DATA RETENTION & DELETION

Data is retained only as long as necessary for service delivery or legal compliance.

You may request deletion at any time by emailing support@echelonprime.com.

6. SECURITY MEASURES

We implement safeguards to protect personal data, including:

  • Encryption (data in transit and at rest)
  • Access controls and audit logs
  • Regular vulnerability checks

7. YOUR RIGHTS UNDER HONG KONG LAW

You may:

  • Access your data
  • Correct inaccurate data
  • Request deletion (subject to legal exceptions)
  • Object or restrict data processing

We respond to valid requests within the PDPO’s statutory timeframes.

8. DATA BREACH NOTIFICATION

If a data breach occurs:

  • We will notify affected users without delay
  • We may notify the PCPD depending on severity and risk
  • We will provide steps users can take to protect themselves

9. COOKIES & TRACKING

Our Services may use cookies or similar tracking tools to:

  • Provide functionality
  • Analyze usage
  • Serve contextual or personalized ads

Users can disable tracking via device or app settings.

10. UPDATES TO THIS POLICY

This Policy may be updated periodically. Updates will be posted here with a revised “last updated” date.

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 Personal Data (Privacy) Ordinance (PDPO) of Hong Kong and reflects our commitment to safeguarding your personal data.