Privacy Policy

(Sri Lanka)

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 Protection Act, No. 9 of 2022 (PDPA) of Sri Lanka.

SUMMARY OF KEY POINTS

  • We collect personal information such as email addresses, usernames, and authentication data.
  • We process your 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 providers or social login services.
  • Your data may be transferred outside Sri Lanka under PDPA safeguards.
  • You have the right to access, correct, delete, restrict, and object to the processing of your data.
  • We notify affected users and authorities of breaches where required.
  • You can opt out of tracking and marketing communications.

1. WHAT INFORMATION DO WE COLLECT?

Personal Information You Provide

We collect personal information you voluntarily submit:

  • Email addresses
  • Usernames
  • Authentication tokens (e.g., Google or Apple login)

We collect only the data needed for the services we provide.

Automatically Collected Data

We collect data such as:

  • Device details: IP address, OS, hardware model
  • Usage Data: In-game actions, levels completed, interaction logs
  • Location Data: Approximate IP-based location (can be disabled in settings)

Children’s Privacy

Our Services are not intended for users under 18 without verified parental consent. If we learn of a child’s data collected without such consent, it will be deleted.

1A. LEGAL BASIS FOR PROCESSING

In compliance with PDPA Section 5, we process your personal data based on:

  • Consent: Where you explicitly allow us to process your data.
  • Contractual Necessity: To fulfill our obligations in providing Nova Nerds.
  • Legal Obligation: When processing is necessary for compliance with applicable laws.
  • Legitimate Interest: For product improvement, security, and customer service, provided it does not override your rights.

2. HOW DO WE USE YOUR INFORMATION?

We process your data to:

  • Create and manage accounts
  • Improve gameplay and features
  • Provide technical support
  • Send communications (opt-in for marketing)
  • Enforce policies and prevent fraud

We may use profiling or analytics to personalize gameplay or display in-game content. You may object by contacting support@echelonprime.com.

3. DATA SHARING & THIRD PARTIES

We may share personal data with:

  • Cloud hosting services (e.g., Google Cloud, PlayFab)
  • Analytics providers (e.g., Google Analytics)
  • Ad platforms (e.g., Unity Ads)
  • Authentication providers (e.g., Google or Apple Sign-In)

Third parties are contractually obligated to comply with security and privacy standards. We do not sell personal data.

4. CROSS-BORDER DATA TRANSFERS

Your data may be transferred to countries outside Sri Lanka. In line with PDPA Part VI, such transfers occur only where:

  • The receiving country offers adequate protection, or
  • We use binding contractual clauses (e.g., SCCs) to ensure protection.

You may contact us to learn more or to object to international transfers.

5. DATA RETENTION & DELETION

We retain personal data only as long as:

  • Needed for service delivery
  • Required by law

Inactive accounts may be deleted after 12 months. You may request deletion at any time.

6. SECURITY MEASURES

We implement industry-standard measures, including:

  • Encryption (data in transit and at rest)
  • Access restrictions and logging
  • Routine security testing

7. YOUR RIGHTS UNDER SRI LANKA LAW

You have the right to:

  • Access your data
  • Correct errors or outdated data
  • Delete your data
  • Object to processing (e.g., for profiling or marketing)
  • Withdraw consent at any time
  • Request portability (a copy of your data in a common format)

To exercise these rights, email support@echelonprime.com.

8. BREACH NOTIFICATION

  • If a breach occurs that poses a risk to your rights, we will:
  • Notify you without undue delay
  • Contact the Data Protection Authority of Sri Lanka (if required)
  • Take immediate action to limit impact and restore data security

9. MARKETING & TRACKING

  • You can opt out of marketing emails by clicking unsubscribe or contacting us.
  • Our Services may use cookies, SDKs, or tracking tools.
  • Tracking preferences can be managed via device or in-app settings.

10. CHANGES TO THIS POLICY

This policy may be updated for regulatory or service changes. Updates will appear 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 Protection Act, No. 9 of 2022 (PDPA) of Sri Lanka and reflects our commitment to data transparency and user rights.