Privacy Policy

(Uganda)

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 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 Uganda, with safeguards in place to ensure compliance with the Data Protection and Privacy Act (DPPA), 2019.
  • You have the right to access, correct, delete, or object to processing of your data.
  • If a data breach occurs, we will notify the Personal Data Protection Office (PDPO) under NITA-U and affected users within 72 hours.
  • You can opt out of marketing communications by updating your preferences or emailing us.

1. WHAT INFORMATION DO WE COLLECT?

Personal Information You Provide

  • Email addresses
  • Usernames
  • Authentication data

All information must be accurate and up to date.

Information Automatically Collected

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

Children’s Privacy & Parental Consent

  • Our Services are not intended for children under 18 without verified parental consent.
  • If we learn that we have collected data from a minor without consent, we will promptly delete it.
  • Parents may contact support@echelonprime.com to manage or delete their child’s data.

1A. LEGAL BASIS FOR PROCESSING

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

  • Consent: When you explicitly permit us to process your data.
  • Contractual Necessity: When processing is required to fulfill a service contract.
  • Legal Obligation: Where data is processed to comply with laws.
  • Legitimate Interest: To improve, secure, and operate our Services responsibly.

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your information to:

  • Create and manage your user account
  • Deliver, maintain, and improve the Services
  • Respond to user inquiries and offer customer support
  • Send administrative and promotional messages (you may opt out)
  • Protect against unauthorized activity or fraud

3. DATA SHARING & THIRD PARTIES

We may share personal data with:

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

All third-party partners are contractually required to apply appropriate security and privacy safeguards. Your data is never sold.

4. CROSS-BORDER DATA TRANSFERS

Your personal data may be transferred to servers outside Uganda, including to the United States and the Philippines. In compliance with DPPA, 2019:

  • We only transfer to countries with adequate protection or
  • Apply Standard Contractual Clauses (SCCs) and other binding agreements to ensure lawful and secure data transfers.
  • You may request more information or opt out by contacting support@echelonprime.com.

5. DATA RETENTION & DELETION

We retain personal data only as long as necessary to fulfill the purposes outlined in this policy:

  • Most data is retained for up to 3 months after account closure.
  • Users can request immediate deletion of their data.
  • Some anonymized data may be kept for analytics.

6. SECURITY MEASURES

We use appropriate technical and organizational measures to protect your personal information:

  • Encryption in storage and transit
  • Access controls and monitoring
  • Routine audits and compliance checks

7. USER RIGHTS UNDER UGANDA’S DPPA

You have the right to:

  • Access your personal data
  • Request correction of inaccurate data
  • Request deletion of your data
  • Object to certain types of processing
  • Withdraw consent at any time
  • Request data portability (receive your data in a readable format)

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

8. DATA BREACH NOTIFICATION

In the event of a serious data breach:

  • We will notify the PDPO under NITA-U within 72 hours.
  • Affected users will be informed and guided on protective measures.
  • We maintain internal records of all security incidents.

9. MARKETING & TRACKING

You may opt in to receive marketing communications.

You may opt out anytime via unsubscribe links or settings.

Our Services may use cookies or tracking tools to:

  • Analyze app usage
  • Deliver personalized content
  • Provide in-game analytics or advertising

Tracking can be adjusted in your mobile device settings.

10. UPDATES TO THIS POLICY

This Privacy Policy may be updated to reflect changes in law or our Services. Any updates will be posted with a revised “last updated” date.

11. CONTACT INFORMATION

If you have any questions about this Privacy Policy or your personal data:

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

Email: support@echelonprime.com

Data Protection Officer (DPO): dpo@echelonprime.com

This Privacy Policy is in compliance with Uganda’s Data Protection and Privacy Act, 2019. If you have any concerns, you may also contact the Personal Data Protection Office (PDPO) under NITA-U.

Visit PDPO Website