Privacy Policy

(Pakistan)

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 asemail addresses, usernames, and authentication data.
  • We do not process sensitive personal information 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 Pakistan, with safeguards in place to ensure compliance with the Personal Data Protection Bill (PDPB) (Draft), Prevention of Electronic Crimes Act (PECA), 2016, and international best practices.
  • You have the right to access, correct, or request deletion of your data.
  • If a data breach occurs, we will notify the National Commission for Personal Data Protection (NCPDP) 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 legal grounds:

  • Consent: When you provide explicit permission to process your data.
  • Contractual Necessity: When processing is required to fulfill our service agreement with you.
  • Legal Obligation: When required to comply with applicable laws.
  • Legitimate Interest: For purposes like security, customer support, or service improvement.

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 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 device settings).

Children’s Privacy & Parental Consent

  • Our Services are not intended for users under 18 without verified parental consent.
  • If we learn that we’ve collected data from a child under 18 without consent, we will delete it immediately.
  • Parents may contact us to review or delete their child’s data.

3. HOW DO WE PROCESS YOUR INFORMATION?

We use your information to:

  • Create and manage your account.
  • Deliver, maintain, and improve our Services.
  • Provide customer service and respond to inquiries.
  • Send administrative and promotional messages (with opt-out options).
  • Ensure service security and prevent abuse or fraud.

4. DATA SHARING & THIRD PARTIES

We may share your personal data with:

  • Cloud storage providers (Google Cloud, Azure PlayFab)
  • Analytics services (Google Analytics)
  • Advertising networks (Unity Ads)
  • Login authentication (Google Sign-In, Apple Game Center)

All third-party partners are required to comply with strict data protection agreements. We do not sell your personal information.

5. CROSS-BORDER DATA TRANSFERS

Your data may be stored or processed in countries outside Pakistan, including the United States and the Philippines. We implement the following safeguards:

  • Ensure that recipient countries have adequate data protection regulations or
  • Use Standard Contractual Clauses (SCCs) and data processing agreements to protect your data.
  • You can request more information or opt out of cross-border processing by contacting support@echelonprime.com.

6. DATA RETENTION & DELETION

We retain your data only for as long as needed for:

  • Providing our services
  • Fulfilling legal or contractual obligations
  • Improving platform performance

Typically, your data is retained for up to 3 months after account closure, after which it is securely deleted. You can also request deletion at any time.

7. SECURITY MEASURES

We take your data security seriously and employ:

  • Encryption during storage and transmission
  • Access controls and multi-factor authentication
  • Routine security audits and system reviews

8. USER RIGHTS UNDER PAKISTANI LAW

Under the PDPB and PECA (as applicable), you have the right to:

  • Access your personal data
  • Correct or update your personal data
  • Request deletion of your personal data
  • Object to certain processing types (e.g. marketing)
  • Withdraw consent where applicable
  • Request data portability (receive a copy in machine-readable format)

To exercise any of the above rights, contact support@echelonprime.com.

9. DATA BREACH NOTIFICATION

In the event of a breach:

  • We will notify the National Commission for Personal Data Protection (NCPDP) and affected users within 72 hours.
  • Breach records will be maintained internally.
  • You will be provided with instructions on protective measures.

10. MARKETING & OPT-OUT OPTIONS

  • Marketing emails are only sent with your opt-in consent.
  • You can unsubscribe at any time by clicking the link in our messages.
  • Preferences can also be adjusted in your account settings or by contacting support.

11. COOKIES & TRACKING TECHNOLOGIES

Our mobile app may use cookies or device identifiers to:

  • Enhance user experience
  • Track in-game behavior for improvement
  • Deliver personalized ads

You can manage cookie and tracking permissions in your device settings.

12. DATA PROTECTION OFFICER (DPO)

For any inquiries related to data protection, you may contact our appointed Data Protection Officer:
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 aligns with the Personal Data Protection Bill (Draft) and PECA, 2016. We will update this policy as needed when the PDPB is formally enacted. You may also contact the National Commission for Personal Data Protection (NCPDP) for complaints.

Visit NCPDP (Pakistan)