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Legal Document

Privacy Policy

Effective: 7 June 2026Last Updated: 7 June 2026

1Introduction

PROCODE (operated at procode.gg) is an AI-powered esports development platform designed to turn raw gaming talent into esports professionals. This Privacy Policy explains how we collect, use, store, and protect your personal information when you use PROCODE's website, platform, applications, and services (collectively, the "Services").

This Privacy Policy applies to all users of the Services. By creating an account or using PROCODE, you acknowledge that you have read and understood how we handle your personal information. This Policy does not apply to third-party websites, games, or services you may access through PROCODE. Please review their privacy policies separately.

2Information We Collect

2.1 Information You Provide

  • Account data: Full name, email address, username, date of birth, and country of residence. Account passwords are stored using industry-standard one-way hashing and are never stored or accessible in plain text.
  • Profile data: Gaming handles, platform IDs (e.g., Riot ID, Steam ID), preferred games, skill level, and coaching goals.
  • Payment information: Billing details and payment method information. Full payment card details are handled by our third-party payment processors. PROCODE does not store raw card numbers.
  • Communications: Support requests, feedback, and any messages you send to our team.

2.2 Information We Collect Automatically

  • Usage data: Pages visited, features used, session duration, coaching interactions, tournament participation history, and protoken activity.
  • Technical data: IP address, browser type and version, device type and identifiers, operating system, and referring URLs.
  • Cookies and tracking technologies: See Section 7.

2.3 Information from Third Parties

  • Game platforms: If you connect a third-party gaming account (e.g., Riot Games, Steam, PlayStation Network), we may receive data such as match history, rank, and in-game statistics, subject to those platforms' own privacy policies.
  • Authentication providers: If you use social sign-in (e.g., Google, Discord), we receive basic profile information from those services, such as your name, email address, and profile picture, as permitted by your settings on those platforms.

3How We Use Your Information

We use the information we collect to:

  • Create and manage your PROCODE account.
  • Deliver coaching sessions, content, and tournament services.
  • Personalize your platform experience and AI-driven coaching recommendations.
  • Process payments and manage your protoken balance.
  • Send service-related notifications, including updates, confirmations, and security alerts.
  • Analyze platform usage to improve features and performance.
  • Facilitate communications between users and coaches.
  • Comply with applicable legal and regulatory obligations.
  • Detect, prevent, and respond to fraud, abuse, and security incidents.

4Legal Basis for Processing

Where applicable under data protection law, we process your personal data on the following legal bases:

  • Contract performance: Processing necessary to provide you with the Services you have signed up for.
  • Legitimate interests: Improving and securing the platform, preventing fraud, and conducting analytics.
  • Consent: Where you have provided explicit consent, including for marketing communications and promotional emails. You may withdraw this consent and unsubscribe at any time using the unsubscribe link in any marketing email or by contacting privacy@procode.gg.
  • Legal obligation: Where processing is required to comply with applicable law.

5Data Storage and Security

Your data is stored on secure cloud infrastructure with the following protections:

  • Encryption of data in transit (TLS) and at rest.
  • Access controls limiting data access to authorized personnel only.
  • Periodic security assessments and monitoring.

PROCODE retains your personal data for as long as your account is active, or as required by law. Upon account closure, your data will be deleted or anonymized within 90 days, except where retention is required by law or for legitimate dispute resolution purposes.

In the event of a security incident that affects your personal data, PROCODE will notify affected users as required by applicable law, without undue delay.

6Third-Party Sharing

We do not sell your personal data. We may share your information with:

  • Payment processors to process transactions. These processors handle payment card data on our behalf and are subject to their own privacy and security obligations.
  • Cloud infrastructure and hosting providers for platform operation.
  • Analytics providers to help us understand platform usage. Where possible, we use anonymized or aggregated data with these providers.
  • Coaches (independent contractors) to the extent necessary to deliver coaching services.
  • Tournament organizers and game publishers where required for event verification and participation.
  • Legal and regulatory authorities where disclosure is required by applicable law or valid legal process.

We work with reputable third-party service providers who maintain appropriate data protection standards through their own published privacy policies, terms of service, and data processing commitments. We select providers on the basis of their security and privacy practices.

7Cookies

PROCODE uses cookies and similar technologies to:

  • Keep you logged in to your account.
  • Remember your preferences and settings.
  • Analyze platform usage and performance.
  • Support platform security.

You can control or disable cookies through your browser settings. Disabling certain cookies may affect the functionality of the platform. We do not use cookies to serve advertising to you.

PROCODE does not currently respond to Do Not Track signals from browsers. If this changes, we will update this Policy accordingly.

8Children's Privacy

PROCODE's Services are intended for users who are at least 13 years of age. Users under 18 are encouraged to use the platform with parental awareness. If you believe a child under 13 has created an account without appropriate consent, please contact us at privacy@procode.gg and we will promptly investigate and delete the account.

9International Data Transfers

PROCODE is incorporated in Delaware, United States, and maintains operations in Bahrain. Data may be processed or stored on servers located in multiple countries. When transferring personal data internationally, we take steps to ensure an appropriate level of data protection is applied, including reliance on recognized transfer mechanisms where required.

10Your Rights

Subject to applicable law in your jurisdiction, you may have the right to:

  • Access your personal data held by PROCODE.
  • Correct inaccurate or incomplete data.
  • Delete your account and associated personal data.
  • Port your data in a machine-readable format.
  • Object to or restrict certain processing activities.
  • Withdraw consent at any time where processing is based on consent.

To exercise any of these rights, contact us at privacy@procode.gg. We will respond within 30 days, or within such other timeframe as required by applicable law.

California Residents (CCPA)

If you are a California resident, the California Consumer Privacy Act grants you the following additional rights:

  • Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you, and how we use and share it.
  • Right to Delete: You may request deletion of your personal information, subject to exceptions permitted by law.
  • Right to Opt Out of Sale: PROCODE does not sell your personal information and does not share it for cross-context behavioral advertising.
  • Right to Non-Discrimination: We will not treat you differently for exercising your CCPA rights.

CCPA requests are responded to within 45 days. Contact: privacy@procode.gg

Saudi Arabia Residents (Saudi PDPL)

If you are a resident of the Kingdom of Saudi Arabia, the Saudi Personal Data Protection Law applies to how we handle your data. In addition to the general rights above:

  • We process your personal data only where we have a lawful basis under the PDPL, including your explicit consent for marketing communications.
  • You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
  • In the event of a personal data breach, we will notify the relevant Saudi authority within 72 hours and affected individuals within 5 days, as required by law.
  • Cross-border transfers of your data are carried out with appropriate safeguards as required by the PDPL.

Contact: privacy@procode.gg

UAE Residents (UAE PDPL)

If you are a resident of the United Arab Emirates, UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection applies. In addition to the general rights above:

  • We obtain your explicit consent before processing your personal data, except where another lawful basis applies under UAE law.
  • You have the right to access, correct, and request deletion of your personal data.
  • Cross-border transfers of your data are made only to countries or recipients providing adequate protection as recognized under UAE law, or pursuant to appropriate contractual safeguards.

Contact: privacy@procode.gg

11Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email or by a prominent notice on the platform at least 14 days before they take effect. Where applicable law requires your affirmative consent before we change how we process your personal data, we will seek that consent. Your continued use of PROCODE after non-material changes take effect constitutes your acknowledgment of the revised Policy.

12Contact Us

PROCODE

Email: privacy@procode.gg

Website: procode.gg