Privacy Policy

Last updated — 8 November 2026

Pocket Code LLC (“Pocket Code,” “we,” “our,” or “us”) develops and publishes apps and games for Android, iOS, and desktop computers (Windows and macOS) (the “Apps”). We respect your privacy and are committed to protecting the Personal Information you share with us.

This Privacy Policy explains:

1. What information we collect and why
2. How we use, store, and share that information
3. Your choices and rights, including how to delete your account
4. How to contact us

By downloading, installing, or using our Apps or visiting pocketcode.io (the “Site”), you agree to the practices described below. If you do not agree, please do not use our Apps or Site.

1. Information We Collect

Some Apps request access to device features (such as location) through your operating system’s permission prompts. The specific data collected depends on your device settings and the permissions you grant; you can change or revoke these permissions at any time in your device settings.

We do not knowingly collect information that directly identifies you (e.g., full name, postal address) through the Apps. Payments are handled entirely by Apple or Google: we never see your card or payment details.

2. How We Use Information

* Applicable to users in the European Economic Area (EEA), United Kingdom, and Switzerland.

3. Third-Party Services, Ads & Analytics

Our Apps integrate the following third-party services, each of which may collect and process device information and identifiers under its own privacy policy:

We use these services to understand aggregated, anonymous usage trends, diagnose crashes, measure marketing performance, and serve ads. Not every App uses every service: see the App-specific sections below.

On our Site, we use Google Analytics to understand aggregated traffic. Where consent is required (such as the EEA, UK, and Switzerland), analytics cookies are set only after you opt in through our cookie banner. You can change or withdraw your choice at any time via the Cookies link in the footer.

On the Site and on each App’s own website (for example airtuner.app or photoyear.app), we also count visits with our own cookieless statistics. For each page view or click on a store button, our server adds one to a daily counter for that page, the referring website’s domain, the country (derived from the network, not stored), the device type and the language. No cookies or similar technologies are used, and no IP address, identifier or browsing history is stored, so this cannot be used to identify or track you.

Apps designed for children

Some of our Apps are designed for young children and their families (for example, Apps listed in Google Play’s “Designed for Families” program). In those Apps:

• No personal information is collected from children. There are no accounts, no sign-in, no chat, no location, and no access to contacts, camera, or microphone.
• Ads are child-safe and not personalized. Google AdMob is told that the App is directed to children (child-directed treatment and the under-age-of-consent flag), so it shows only contextual ads rated for general audiences and does not use advertising identifiers to build profiles or track the child. Full-screen ads appear only at natural breaks, never in the middle of an activity, and a one-time purchase removes all ads.
• No advertising identifiers. Firebase Analytics runs with advertising-ID collection turned off and without ad personalization. It only records anonymous, aggregated usage (such as app opens and session length) and app-configuration data (Firebase Remote Config). AppsFlyer, the Meta SDK, and NetSignal are not used.
• Content stays on the device. Settings, drawings, and recordings made in the App are stored only on the device. A drawing is saved to the photo gallery or shared only when an adult chooses to do so.
• Grown-ups only. Purchases, sharing, ratings, links that leave the App, and the settings area are behind a parental gate that a young child cannot pass.
• Voices and sounds are played from recordings bundled in the App or generated by the device’s own text-to-speech engine; nothing a child says or does is recorded or sent.

Network performance analytics

Certain Apps integrate the NetSignal SDK by Wavebrook Analytics Ltd to collect pseudonymous data for mobile network analytics. With your consent, the SDK collects information such as device model, approximate or precise location, mobile network signals, and connectivity metrics. This data is shared with Wavebrook and selected network-analytics partners who act as joint controllers under Article 26 UK GDPR.

For the list of partners and the data they receive, see wavebrook.com/partners. For information on the lawful basis, retention, international transfers, and your data-protection rights, see wavebrook.com/privacy. You can withdraw your consent at any time through the App’s privacy settings or by contacting privacy@wavebrook.com.

Football Club XI

Our football management game Football Club XI (Android, iOS, Windows, and macOS) has no ads and does not use advertising identifiers, location, AdMob, Firebase, AppsFlyer, the Meta SDK, or NetSignal. It uses only Unity Gaming Services and, on phones and tablets, RevenueCat:

• Crash reports (Unity Diagnostics): when the game crashes or hits an error, a report with the device model, OS version, game version, and the technical details of the error is sent so we can fix it. It does not include your saved games.
• Usage data (Unity Analytics): collected only if you agree when the game asks. You can change your answer at any time in Options, and ask Unity to erase the usage data it holds with Delete my usage data.
• Account and cloud saves (Unity Authentication and Cloud Save): optional. If you sign in (with Apple, Google, or a Unity account), we store a user ID and the games you save to the cloud, so you can continue your career on your other devices.
• Purchases (RevenueCat): the full game is a one-time in-app purchase made through the App Store or Google Play. RevenueCat validates it and keeps the purchase with an anonymous ID or, if you signed in, with your account, so the full game unlocks on all your devices. Device identifier collection is turned off.

Your saved games are stored on your device and only leave it if you turn on cloud saves.

4. Sharing of Information

We do not sell or rent your Personal Information. We share data only:

• With service providers who perform services on our behalf (e.g., crash reporting, analytics, cloud saves, purchase validation, ad serving) and are bound to protect it
• For legal reasons – to comply with court orders, enforce our terms, or protect the rights, property, or safety of Pocket Code LLC, our users, or others
• In a business transfer – if we merge with, are acquired by, or sell assets to another company, your information may transfer as part of that transaction

5. International Transfers

We are a U.S.-based company. By using our Apps or Site, you acknowledge that your information may be processed and stored in the United States and other countries where our partners operate, which may have data-protection laws that differ from those of your jurisdiction.

6. Data Retention

We retain Personal Information only as long as necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (e.g., tax, accounting, or legal obligations). In particular:

• Accounts and cloud saves are kept while your account exists and are deleted when you delete it (see below).
• Crash reports and usage data are kept by our providers for their standard retention periods, and then deleted or anonymized.
• Purchase records are kept as long as tax and accounting law requires, and so that a purchase you made can be restored.

7. Security

We use commercially reasonable administrative, technical, and physical safeguards to protect information. Data the Apps send to our providers is encrypted in transit. No method of transmission or storage is 100 % secure, so we cannot guarantee absolute security.

8. Children’s Privacy

Except for the Apps designed for children described in Apps designed for children, our Apps and Site are not directed to children under 13 (or the equivalent minimum age in your jurisdiction).

We do not knowingly collect Personal Information from children, in any App. Our Apps designed for children are built to comply with the U.S. Children’s Online Privacy Protection Act (COPPA), the GDPR rules on children’s data, and the Google Play Families Policy: they collect no personal information from children, and the third-party services they include are configured for child-directed use.

If you are a parent or guardian and believe your child has provided us with Personal Information, contact us at help@pocketcode.io and we will delete it.

9. Deleting Your Account and Data

This section applies to every App by Pocket Code LLC that offers an account, including Football Club XI.

In the App. In Football Club XI, go to Options › Account and cloud › Delete account. Your account and every game saved in the cloud are deleted at once and for good. The saved games on your device are kept.

Without the App. Email help@pocketcode.io with the subject “Delete my account”, from the email address of your account if you have one, and tell us the App and the sign-in provider you used (Apple, Google, or a Unity account). We will confirm your request and delete your account and its data within 30 days.

What is deleted: your user ID, your cloud saves, and the link between your account and your purchases. What is kept: the purchase records the law requires us to keep, and the records Apple and Google keep of purchases made in their stores. Usage data can be erased separately with Delete my usage data in the App’s Options, or by asking us by email.

10. Your Choices and Rights

• Ad choices.
  • Android — reset or opt out of personalized ads in Settings › Google › Ads
  • iOS — control ad tracking in Settings › Privacy › Tracking
• Usage data. Where an App asks for your consent, you can change your answer at any time in its settings.
• Marketing emails. If you receive emails from us, you may unsubscribe at any time using the link in the message.
• EEA/UK/Swiss users. You have the right to access, correct, delete, or restrict processing of your Personal Information, to object to processing, and to request portability. Email help@pocketcode.io to exercise these rights.
• California residents. You have certain rights under the California Consumer Privacy Act (CCPA). We do not sell your Personal Information, but you may still submit verifiable requests by emailing us.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date at the top. Material changes will be posted in-app or on the Site and, where required, we’ll seek your consent.

12. Contact Us

Pocket Code LLC 30 N Gould St Ste N Sheridan, WY 82801 USA

Support and privacy requests: help@pocketcode.io Other matters: admin@pocketcode.io