Privacy Policy

(Israel)

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:

  • Downloading and using our mobile application (Nova Nerds) or any other app linking to this Privacy Notice.
  • Interacting with us through customer service, feedback, or marketing.

We are committed to protecting your personal information in compliance with Israel’s Protection of Privacy Law, 1981 (PPL), and relevant regulations including the Privacy Protection Regulations (Transfer of Data Abroad), 2001.

SUMMARY OF KEY POINTS

  • We collect minimal personal data (e.g., email, login credentials, usage data).
  • We process this data to operate and improve Nova Nerds and its related services.
  • We do not process sensitive personal information unless legally required or with explicit consent.
  • Parental consent is required for users under 18.
  • We use lawful safeguards for data transfers outside Israel.
  • Users have the right to access, correct, delete, object to processing, and request data portability under Section 7 of the PPL.
  • In case of a breach, we notify users and the Privacy Protection Authority (PPA) where required.

1. WHAT INFORMATION DO WE COLLECT?

Data You Provide

  • Email address
  • Username
  • Authentication credentials (such as Google or Apple login tokens)

Automatically Collected Data

  • Device Data: IP address, OS, device model
  • Usage Data: In-app behavior, clicks, game interactions
  • Location Data: IP-based approximate location (disabled in device settings if desired)

Children’s Privacy & Parental Consent

Users under 18 must have verifiable parental consent. Data submitted by minors without this consent will be deleted. Parents can review and delete such data by contacting us at support@echelonprime.com.

1A. LEGAL BASIS FOR PROCESSING

While not explicitly required under the PPL, we disclose our legal basis for transparency. We process your data on one or more of the following grounds:

  • Consent: When you voluntarily provide permission.
  • Contractual necessity: To deliver Nova Nerds services.
  • Legal obligation: For regulatory and compliance purposes.
  • Legitimate interest: To operate, secure, and enhance our app while balancing your rights.

2. HOW WE PROCESS YOUR INFORMATION

We process personal data to:

  • Create and maintain user accounts
  • Enhance game features and gameplay experience
  • Provide support and respond to inquiries
  • Deliver administrative and (with consent) marketing communications
  • Prevent fraud or misuse of services

We may use automated tools to personalize gameplay, show relevant offers, or adjust content. You may object to this processing by contacting support@echelonprime.com.

3. DATA SHARING

We share personal data with trusted processors only:

  • Hosting providers (e.g., Google Cloud, Microsoft PlayFab)
  • Analytics services (e.g., Google Analytics)
  • Ad networks (e.g., Unity Ads)
  • Authentication tools (e.g., Google/Apple Sign-In)

Each third party is bound by contractual obligations to protect user privacy and comply with applicable Israeli and international data protection standards. We do not sell personal data.

4. CROSS-BORDER DATA TRANSFERS

In line with the Privacy Protection Regulations (Transfer of Data Abroad), 2001, your personal data may be transferred to countries that:

  • Have data protection standards equivalent to those in Israel, or
  • Are subject to enforceable contractual clauses (e.g., Standard Contractual Clauses or SCCs) ensuring adequate protection

You may contact us to obtain more information or object to cross-border transfers.

5. DATA RETENTION

We retain personal data only for:

  • The duration of your account’s activity
  • The fulfillment of legal or contractual obligations

If your account is inactive for 12 months, your data may be deleted unless otherwise required.

6. SECURITY SAFEGUARDS

We use appropriate security technologies and organizational safeguards, including:

  • Encryption during data transmission and storage
  • Access control and monitoring
  • Regular internal audits and updates to system security

7. YOUR RIGHTS UNDER ISRAELI LAW

Under Section 7 of the Protection of Privacy Law, you may:

  • Access your data held by us
  • Correct inaccurate personal information
  • Delete personal data
  • Object to processing, including profiling and automated decision-making
  • Request data portability (in a structured, machine-readable format)

Requests may be made by contacting support@echelonprime.com.

8. DATA BREACH POLICY

If a breach involving your data occurs:

  • We will assess the severity immediately
  • If required, notify the Privacy Protection Authority (PPA) and affected individuals promptly
  • Implement remediation and mitigation measures

9. COOKIES & TRACKING

Our services may use cookies and SDK-based tracking technologies to:

  • Operate game functions
  • Monitor usage trends
  • Deliver in-app or interest-based ads

You can control these in your device settings.

10. CHANGES TO THIS POLICY

We may update this policy from time to time. Changes will be reflected with a revised “Last updated” date. Material changes will be notified to users through the app or by email.

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 Protection of Privacy Law, 1981 and related Israeli privacy regulations. For complaints or escalations, you may also contact the Privacy Protection Authority (PPA) in Israel.