Privacy Policy

(United Arab Emirates)

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 Privacy Notice complies with UAE Federal Decree Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and associated Executive Regulations.

SUMMARY OF KEY POINTS

  • We collect personal information such as email addresses, usernames, and authentication data, only as needed for our Services.
  • We do not process sensitive personal data unless required by law or with explicit user consent.
  • We may collect data from third parties such as marketing partners, analytics tools, and social media login providers.
  • We process your personal data for the purposes of providing services, improving features, ensuring security, complying with UAE law, and (with consent) sending you marketing.
  • Your personal data may be transferred outside the UAE with adequate safeguards in place.
  • You have the right under the PDPL to access, correct, delete, restrict, and object to the use of your data.
  • If a data breach occurs, we will notify the UAE Data Office and affected users within 72 hours.
  • You can opt out of marketing communications and request data deletion at any time.

1. WHAT INFORMATION DO WE COLLECT?

Personal Information You Provide

We collect information that you voluntarily provide to us, including:

  • Email addresses
  • Usernames
  • Authentication credentials (e.g. login tokens, OAuth data)

We only collect personal data that is adequate, relevant, and necessary for our stated purposes.

Information Automatically Collected

When using our Services, we may automatically collect:

  • Device Information: IP address, device type, operating system
  • Usage Data: In-app activity, gameplay data, preferences
  • Location Data: Approximate location (disabled via device settings)

Children’s Privacy & Parental Consent

  • Our Services are not directed at children under the age of 13 in the UAE without verified parental consent.
  • If we learn that personal data of a child under 13 has been collected without consent, we will delete it immediately.

1A. LEGAL BASIS FOR PROCESSING

We process your data under one or more of the following lawful bases, in accordance with PDPL Article 4:

  • Consent: You provide clear permission for processing.
  • Contractual Necessity: Processing is necessary to fulfill our obligations to provide the Services.
  • Legal Obligation: We process your data to comply with applicable legal and regulatory obligations.
  • Legitimate Interest: We process data to maintain and improve our services, provided your rights do not override those interests.

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your information to:

  • Create and manage user accounts
  • Provide and improve game features
  • Send communications (with opt-out for marketing)
  • Provide technical support
  • Ensure compliance and prevent fraud

If we use automated profiling to personalize game content or ads, you have the right to object by contacting support@echelonprime.com.

3. DATA SHARING & THIRD PARTIES

We may share personal data with:

  • Cloud service providers (e.g., Google Cloud, Azure PlayFab)
  • Analytics platforms (e.g., Google Analytics)
  • Advertising networks (e.g., Unity Ads)
  • Authentication providers (e.g., Google Sign-In)

All vendors are contractually obligated to protect your data and comply with privacy laws. We do not sell personal data.

4. CROSS-BORDER DATA TRANSFERS

Under PDPL Articles 22–24, your data may be transferred outside the UAE with:

  • Adequate protection in the recipient country or
  • Standard Contractual Clauses (SCCs) or similar safeguards.

Users may request transfer details or object by contacting support@echelonprime.com.

5. DATA RETENTION & ERASURE

  • We retain personal data only for as long as necessary to fulfill the purposes outlined or to meet legal obligations.
  • Users may request deletion of their data by contacting support@echelonprime.com.

6. SECURITY MEASURES

We protect your data using:

  • Encryption (in transit and at rest)
  • Access controls
  • Periodic audits and monitoring

7. USER RIGHTS UNDER UAE LAW

Under PDPL, you have the right to:

  • Access your personal data
  • Correct inaccurate data
  • Delete your data (subject to exceptions)
  • Restrict or object to processing
  • Withdraw consent at any time

To exercise your rights, email us at support@echelonprime.com.

8. DATA BREACH RESPONSE

In the event of a serious breach:

  • We will notify the UAE Data Office within 72 hours
  • Affected users will be informed and advised on mitigation

9. MARKETING & COOKIE PREFERENCES

  • You may opt out of marketing emails via unsubscribe links or email request
  • We may use cookies or similar technologies for analytics and ad personalization
  • Users can manage tracking through app or device settings

10. UPDATES TO THIS POLICY

We may update this Policy to reflect legal or service changes. Updates will be published with a new “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 Policy complies with the UAE’s Federal Decree Law No. 45 of 2021 on the Protection of Personal Data (PDPL). We are committed to upholding your rights and protecting your personal information.