Privacy Policy

(Trinidad & Tobago)

PRIVACY POLICY

Last updated April 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 only collect data necessary for delivering our services.
  • We do not process sensitive personal data without a legal basis or explicit consent.
  • We may collect data from third-party sources like analytics providers, authentication services, and advertising platforms.
  • We process data in accordance with the Data Protection Act, 2011 of Trinidad & Tobago.
  • You have the right to access, correct, restrict, and request deletion of your personal data.
  • In case of a breach, we maintain internal records and may voluntarily notify TT-CSIRT or MPA.
  • Cross-border transfers follow appropriate safeguards.
  • You may opt out of marketing communications at any time.

1. WHAT INFORMATION DO WE COLLECT?

Personal Information You Provide

We collect personal information that you voluntarily provide, including:

  • Email address
  • Username
  • Authentication data

We only collect what is necessary for the operation and improvement of our services.

Information Automatically Collected

  • Device Information: IP address, operating system, device model
  • Usage Data: In-game behavior, features accessed, and analytics events
  • Location Data: Approximate location (disabled via device settings)

Children’s Privacy & Parental Consent

  • Users under 18 must have verifiable parental consent.
  • If unauthorized data from a minor is discovered, we delete it immediately.
  • Parents may contact us to review or delete their child’s data.

1A. LEGAL BASIS FOR PROCESSING

We process your data under the following lawful bases:

  • Consent: You have given us clear permission to process your personal data.
  • Contractual necessity: Processing is necessary to deliver services you’ve requested.
  • Legal obligation: We process your data when required by applicable laws.
  • Legitimate interest: To ensure service functionality, performance, and security.

2. HOW WE USE YOUR INFORMATION

We use your information to:

  • Create and manage your account
  • Improve user experience and game performance
  • Provide support and respond to inquiries
  • Send service and marketing communications (optional)
  • Prevent fraud and maintain service integrity

3. DATA SHARING & THIRD PARTIES

We may share limited user data with:

  • Cloud storage (e.g., Google Cloud, PlayFab)
  • Ad networks (e.g., Unity Ads)
  • Analytics providers (e.g., Google Analytics)
  • Authentication platforms (e.g., Google Sign-In, Apple Game Center)

All third-party partners are contractually obligated to follow data protection practices. Your data will not be sold.

4. CROSS-BORDER DATA TRANSFERS

Your personal data may be transferred outside of Trinidad & Tobago, including to the United States or the Philippines. These transfers are protected by:

  • Standard Contractual Clauses (SCCs) or other binding mechanisms
  • Transfers only to jurisdictions with adequate data protection levels

Users may request details or opt out by contacting support@echelonprime.com.

5. DATA RETENTION & DELETION

We retain your personal information:

  • Only for as long as required for legal or operational purposes
  • Typically for up to three months after account termination

You may request deletion anytime via support@echelonprime.com.

6. SECURITY MEASURES

To protect your data, we implement:

  • Encryption in storage and transmission
  • Access controls and data isolation
  • Regular internal security audits

7. YOUR RIGHTS UNDER TRINIDAD & TOBAGO LAW

You have the right to:

  • Access your personal data
  • Correct or update inaccurate information
  • Delete your data upon request
  • Restrict or object to data processing
  • Withdraw consent where applicable

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

8. DATA BREACH NOTIFICATION & RESPONSE

If a breach affects your data:

  • We will notify you promptly with mitigation steps
  • We voluntarily notify TT-CSIRT or MPA where appropriate
  • All incidents are recorded in an internal breach log, and we follow a defined incident response protocol

9. COOKIES & TRACKING TECHNOLOGIES

Our app may use cookies, SDKs, or tracking tools to:

  • Monitor in-game analytics
  • Personalize ads or recommendations
  • Improve app performance

Tracking can be controlled via device privacy settings or app preferences.

11. CONTACT INFORMATION

If you have questions about this Privacy Policy or wish to exercise your rights:

Echelon Prime, Inc
1860 Chicago Ave Ste G20
Riverside, CA 92507, United States

Email: support@echelonprime.com
Protection Officer: dpo@echelonprime.com

This Privacy Policy is compliant with the Data Protection Act, 2011 of Trinidad & Tobago. If you have further concerns, contact the Office of the Information Commissioner or TT-CSIRT for guidance on data privacy practices.