Last Updated: December 4, 2019


New Code Inc. (“Newcode,” “Company,” “we,” or “us”) designs, develops, and maintains a interactive applications Pocket7Games that respects your privacy and is committed to protecting it through our compliance with this Privacy Policy (this “Policy). Pocket7Games collects information about you when you use the functionalities, features, and services provided by the Pocket7Games SDK (the “Services”). This Policy describes our practices for collecting, using, maintaining, protecting, and disclosing your personal information in connection with your access and/or use of the Services. 

Please read this Policy carefully. By downloading an application that utilizes the Pocket7Games and accessing or using the Services, you expressly agree to all terms of this Policy. We reserve the right to modify or update this Policy from time to time in our sole discretion. It is your responsibility to review it periodically for changes. Your continued use of the Services after we make changes is deemed to be acceptance of such changes. IF YOU DO NOT AGREE WITH ANY TERMS OF THIS POLICY, PLEASE DO NOT DOWNLOAD ANY APPLICATION THAT UTILIZES THE Pocket7Games SDK AND DO NOT ACCESS OR USE THE SERVICES. 

I. Scope and Application

This Policy applies to your use of our Services. Except as otherwise expressly provided herein, this Policy does not govern information we collect offline, or through any other means, including on or through any other website, mobile application, or any interaction you may have with Pocket7Games by telephone or postal mail; nor does this Policy apply to information collected by third parties, including through any application, website, or content (including promotional content) that may link to or be accessible from the Services. These third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

II. Collection of Information

a. Personal Information You Provide to Us

We collect information from you when you voluntarily provide it to us or expressly authorize us to access or use it on or through the Applications and/or Services, including without limitation:

1.     Registration Information: Information provided when you register to access, inquire about, or use our Services, including without limitation: your username, name, password, e-mail address, date of birth, telephone number associated with your account.

2.     Transaction and Payment Information: Information provided when you participate in Pocket7Games cash tournaments, including without limitation: credit card information, bank account information, Paypal user name, your first and last name, residential address, and Social Security Number. Note that Pocket7Games will use third party payment processing companies to process your transactions. When using a third party processing company, Pocket7Games will not have access to your payment information. Without limiting the foregoing, Pocket7Games will not share your payment information unless necessary for verifying or processing your payments or as required by law.

3.     Service Request Information: Information provided when you request any services or assistance, including without limitation: questions or comments sent to our support team or report a problem in connection with your access to or use of the Services.

4.     Other Personally Identifiable Information: Other information by which you may be personally identified or contacted.

b. Non-Personal Information Collected Through Your Use of the Services
We may also collect certain information in connection with your access to or use of the Applications and/or Services and which cannot be used in itself to specifically identify you, including without limitation:

1.     Usage and Preference Information: Information about your access to and/or use of the Applications and/or Services, including traffic data, the date and time of your visit to the Applications and/or Services, the features of the Applications and/or Services accessed, web pages and sites viewed, advertisement(s) served, length of time advertisements are viewed, your preferences, and other communication data and resources in connection with your access to and/or use of the Applications and/or Services. Under Certain circumstances, we do this through the use of cookies, transparent gifs, frames, server log analysis and other technologies as they are developed.

2.     Device Information: Information about your device on which you access or use the Applications and/or Services, including the unique device identification number of your device, device make and model, IP address, operating system or platform, browser type and version, cookie information.

3.     Location Information: Real-time information about the location of your device. You may withdraw your consent to our collection of your location information at any time, provided that you are not participating in cash competitions. If you choose to participate in a cash competition, you may not opt out of the collection of this type of geolocation data.

4.     Error Information: Any error reporting information if the Services crash or hang up for the sole purposes of investigating and remedying the errors and improving the Services. Such error reports contain information about the type and version of your device and browser, the device identifier, and time, features being used, and the state of the Services when the error occurs.

5.     Feedback. We also collect information about ratings, reviews and feedback you provide on the Applications and/or Services.

c. Information We Collect from Other Sources

We may receive additional information about you from other sources (such as public databases, joint marketing partners, social media platforms, as well as from other third parties), including information about your preferences provided by third party analytics tools, and we may combine it with other information we have collected and maintained about you.

d. Exclusions

This Policy does not apply to information made available to other Pocket7Games users while you participate in tournaments and public forums, including your username, personal profile populated with your username, any content you voluntarily add to your profile, and your personal image; nor does this Policy apply to any information posted, transmitted or otherwise made available on any mobile applications or websites owned and operated by third parties, or other users of the Services (“User Contributions”). The User Contributions are treated as non-confidential and are posted or transmitted to others at your own risk. 

If you visit, publish, or share your information on any applications or websites owned and operated by third parties, the use of such information shall be governed by the privacy policies of the applicable third party sites. We do not accept any responsibility or liability for those policies or any information you may share or transmit on a third party site. Additionally, we cannot control the actions of any users of the Services or other third-party mobile applications or websites with whom you choose to share your User Contributions. Therefore, we are not responsible for any use or misuse of such information that might result from your disclosure of such information.

III. Use of Information

We use your personal information primarily for internal business purposes to deliver better and more personalized services as well as to improve the content and functionality of the Services, including without limitation:

1.     to verify your identity;

2.     to verify that you can legally participate in cash tournaments and withdraw funds;

3.     to perform and improve the Services;

4.     to provide you with the information, products and services that you request from us;

5.     to communicate with you and send you important notices on our services, including without limitation, notices on changes to our Services and software updates;

6.     to personalize and improve the Services according to your individual interests, and provide or recommend features, content, social connections, advertisements, and other goods and services;

7.     to solicit information from you, including to invite you to participate in surveys;

8.     to contact, or permit third parties to contact, you via e-mail, SMS, or otherwise for the marketing and advertising purposes, including for the purposes of introducing new products, features, services, promotions, or events offered by us or third parties (you may opt-out by following the instructions on such communications);

9.     to enforce our rights arising from any contracts between you and us, such as for billing and collection purposes;

10.  to administer and for internal operations, including without limitation, to troubleshoot software bugs and operational problems, to conduct data analysis, testing, and research, and to monitor and analyze usage and activity trends;

11.  to monitor, investigate, or prevent illegal, abusive, fraudulent, or suspected illegal activities and content;

12.  to fulfill any other purpose for which you provide it; and/or

13.  for any other purpose with your consent.

We may use aggregated or non-personally identifiable information for any lawful purposes without restrictions.

IV. Information Disclosure

Unless otherwise provided in this Policy, you agree that we have the right to share your personal information as described in this Policy or as described at the time of collection or sharing, including without limitation, sharing your information:

1.     with our subsidiaries and affiliates;

2.     with vendors, consultants, marketing partners, service providers, and other third parties who need access to such information to support the Services and who are bound by contractual obligations to keep your personal information confidential and use it only for the purposes for which we disclose it to them;

3.     in response to facially valid subpoenas, search warrants, any court order, any law or legal process, or any government or regulatory request, so long as we have a good faith belief that such legal process or law enforcement requires disclosure;

4.     to exercise our legal rights, resolve disputes, protect and defend the property or safety of the Company, the Services, or our customers, or enforce other agreements, including for billing and collection purposes;

5.     with buyers or other successors in the event of a merger, acquisition, consolidation or restructuring, dissolution or other sale or transfer of all or a portion of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about you is among the assets transferred;

6.     to fulfill any other purpose for which you provide it; and/or

7.     with your consent.

We may disclose aggregated or anonymous information which cannot be used to identify you or any users personally for any lawful purposes without restriction.

V. Your Access to and Control Over Information

You may review, correct, or change your account information at any time by logging into your account. If you wish to cancel your account, please login to your account and follow the account closure process or e-mail us at 

We will make reasonable efforts to ensure that all of your personal information stored in databases we actively use to operate the Services will be updated, corrected, changed, or deleted as appropriate and as soon as reasonably practicable. However, we reserve the right to retain in our archival files any information we remove from or change in our active databases. We may retain such information to resolve disputes, troubleshoot problems, and enforce our user agreements and policies, including Terms of Service. In addition, it may not be technologically possible to remove every record of the information you have previously provided us, as a copy may exist in a non-erasable form that will be difficult or impossible for us to locate.

VI. Data Security

We take precautions to protect your personal information. All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. 

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password which enables you to access our Services, you are responsible for keeping this password confidential. We ask you not to share it with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to us; any transmission is at your own risk. We are not responsible for circumvention of any privacy settings or security measures incorporated on the Services.

VII. Ad Serving Technology

The Services may employ proprietary or third party ad serving technologies that use cookies, clear GIFs, web beacons, or other technologies to collect information as a result of ad serving through the Services. Pocket7Games or third parties operating the ad serving technology (each, a “Third Party Ad Server”) may use demographic and location information, as well as information logged from your hardware or device to ensure that appropriate advertising is presented within the Services and to calculate or control the number of unique and repeat views of a given ad, and/or deliver ads that relate to your interests and measure the effectiveness of ad campaigns. We or Third Party Ad Servers may collect data for this purpose, including your IP address, information about your software, applications and hardware, advertisement(s) served, in game location, length of time an advertisement is visible, other Internet and website usage information, domain type, size of the advertisement, advertisement response (if any), and angle of view. Note that if you click on an ad that appears on the Services, you acknowledge and agree as a result of how that technology works, your name or other identifying characteristics may be revealed to the advertiser (or the applicable Third Party Ad Server) through referrer headers (the URL transmitted by publishers when users click on ads).

You recognize and agree that the Third Party Ad Servers who deliver ads for Pocket7Games may combine the information collected with other information they have independently collected from other services or products. These companies collect and use information under their own privacy policies. These ad serving technologies may be integrated into the Services.

In addition, Pocket7Games uses pixels, or transparent GIF files, to help manage online advertising. These GIF files are provided by our ad management partners (each, a “Management Partner”). These files enable our Management Partners to recognize a unique cookie on your web browser. The cookie was placed by us, or by another advertiser who works with the applicable Management Partner. The Management Partner may set and access its own cookies on your web browser in order to serve ads it believes may be of interest to you based on the profile information you provided to us at registration (e.g., demographic information) as well as information collected about you by the applicable Management Partner elsewhere. Management Partners may use information about you gathered from the Services (including your demographic information provided to us upon registration as well as your browsing behavior) to serve third party ads to you elsewhere on the Internet. For more information about how cookies work, please visit the Network Advertising Initiative’s homepage at 

After you use the Services, our advertising partners may deliver Pocket7Games ads to your browser when you visit other sites on the Internet. These ads are delivered based on cookies that are set by us or by our third party advertising network partners when you visit or use the Services, and that are recognized by these companies when you visit other sites. 

VIII. Use of Cookies and Cache Data

We use cookies, cache, and similar technologies to improve your user experience and the overall quality of our Services. Most browsers and applications are initially set up to accept such data. If you prefer, you can program your device so that it does not store this information while utilizing the Application. Certain Application features may only be available through the collection of such data. We may use such data to assist in data collection and to track Application usage and trends to help us better serve you. We also permit third parties who have entered into confidentiality agreements to access such data to help us monitor use of the Application for fraud or any other activity that does not comply with applicable laws.

Some of our business partners (e.g., analytical tracking software providers) use cookies and tracking technologies on the Application. We have no access to or control over these cookies or tracking technologies. This Policy covers the use of cookies and cache data on the Application and by us only and does not cover the use of cookies or tracking technologies by any such business partner.

IX. Social Networking

The Services may incorporate links or references to third party social networking sites, such as Facebook and Twitter (each, a “Social Networking Site”). By allowing Pocket7Games to connect with your accounts on such Social Networking Sites, you consent to Pocket7Games’s accessing the information in those accounts, which information may include personally identifiable information. You likewise consent to Pocket7Games’s publishing on the Services any such information or actions you take on such Social Networking Sites. Any information accessed or published from your account on a Social Networking Site on the Services is subject to Pocket7Games’s Terms of Service. It is your choice whether to use any such Social Networking Site, and you understand that in some instances such Social Networking Sites may request to access and publish information about you or your friends that is included in your Pocket7Games account.

X. Special Notice Regarding Minors Under 18 Years of Age

The Services are not directed towards minors under the age of 18. We do not knowingly collect personal information from minors under 18. If you are under 18, do not use our Services, make any purchases through the Applications and/or Services, or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name.

Pocket7Games is intent on complying with applicable laws and regulations regarding minors, including the United States Children’s Online Privacy Protection Act. If you believe we might have any information from or about a minor under 18, please contact us at 

XI. Changes to the Policy

We may change this Policy from time to time in our sole discretion. Your continued use of the Services after we make changes constitutes your consent to the changes. We encourage you to periodically review this Policy for the latest information on our privacy practices. If you do not agree with any revised version of this Policy, please do not continue to use the Services.

XII. Governing Law

This Policy is governed by the laws of California without giving effect to any principles of conflict of law. Please note this Policy governs the use of our Services from and within the United States. The United States and other countries have not harmonized their privacy regulations. Because Pocket7Games and its servers are located in the United States, Pocket7Games has written this Policy to satisfy United States regulations and the users of the Services agree to that level of privacy protection. We ask that individuals residing outside of the United States refrain from downloading any Application that utilizes the Pocket7Games SDK or using the Services.


XIII. Contact Us

If you have any questions or comments about this Policy or our compliance with this Policy, please contact us at  or at the following mailing address: 2586 Wyandotte Street, Unit 2B. Mountain View CA 94043

© 2019 New Code Inc.