Privacy Policy

(Nigeria)

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.

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 data 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 Nigeria, with appropriate safeguards to ensure compliance with the Nigeria Data Protection Act (NDPA), 2023.
  • You have the right to access, correct, or request deletion of your data under NDPA.
  • If a data breach occurs, we will notify the Nigeria Data Protection Commission (NDPC) and affected users within 72 hours.
  • You can opt out of marketing communications by updating your preferences or emailing us.

1. LEGAL BASIS FOR PROCESSING

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

  • Consent: When you provide us clear permission to process your data.
  • Contractual necessity: When processing is necessary for the performance of a contract.
  • Legal obligation: To comply with legal and regulatory obligations.
  • Legitimate interest: For purposes such as improving our services and ensuring data security.

2. 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 kept up to date.

Information Automatically Collected

When you use our Services, we may automatically collect:

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

Children’s Privacy & Parental Consent

  • Our Services are not intended for children under the age of 18 without verified parental consent.
  • If we become aware of data collected from a minor without consent, we will delete the information.
  • Parents may request data deletion by contacting support@echelonprime.com.

3. HOW DO WE PROCESS YOUR INFORMATION?

We process your information to:

  • Create and manage user accounts.
  • Provide, improve, and secure our Services.
  • Deliver customer support.
  • Send administrative and promotional communications (with opt-out options).
  • Comply with legal obligations and enforce our terms.

4. DATA SHARING & THIRD PARTIES

We may share your data with trusted third parties, including:

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

We do not sell personal data. Shared data is anonymized whenever possible.

5. CROSS-BORDER DATA TRANSFERS

Your personal data may be transferred outside Nigeria, including to the United States or the Philippines. In accordance with NDPA Section 41:

  • We ensure that the recipient country has adequate data protection laws.
  • Where adequacy is not established, we use Standard Contractual Clauses (SCCs) and other binding agreements.
  • You may request further details or opt out of international transfers by contacting support@echelonprime.com.

6. DATA RETENTION & ERASURE POLICY

  • We retain personal information only as long as necessary for the purposes stated or to comply with legal obligations.
  • Typically, data is retained for 3 months after account closure.
  • Users can request immediate data deletion by contacting support@echelonprime.com.

7. SECURITY MEASURES

We implement appropriate safeguards to protect your data:

  • Encryption of data in transit and at rest.
  • Access controls and user authentication.
  • Regular audits and vulnerability assessments

8. USER RIGHTS UNDER THE NDPA

You have the following rights under Nigeria’s Data Protection Act:

  • Access: Obtain a copy of your personal data.
  • Correction: Rectify incorrect or outdated data.
  • Erasure: Request deletion of your data.
  • Objection: Object to certain processing such as direct marketing.
  • Portability: Receive your data in a machine-readable format.
  • Withdraw Consent: Where processing is based on consent.

To exercise these rights, contact us at support@echelonprime.com.

9. DATA BREACH NOTIFICATION

If a serious data breach occurs:

  • We will notify the Nigeria Data Protection Commission (NDPC) within 72 hours.
  • Affected users will be informed of the breach and protective steps to take.
  • Records of all breaches are maintained as per regulatory guidelines.

10. MARKETING & OPT-OUT OPTIONS

  • Users must opt in to receive marketing emails.
  • You may unsubscribe via the link in our emails or by emailing support@echelonprime.com.
  • In-app marketing preferences may be adjusted in the settings menu.

11. COOKIES & TRACKING TECHNOLOGIES

Our mobile application may use cookies or similar technologies to enhance user experience. You may control cookies via your device settings or application preferences.

12. DATA PROTECTION OFFICER (DPO)

If you have questions about your personal data, please contact our Data Protection Officer at:
Email: dpo@echelonprime.com

13. 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 is compliant with Nigeria’s Data Protection Act, 2023 (NDPA). You may file a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your rights have been violated.

Visit NDPC Website