c44com Privacy Policy

1 Introduction & Scope

This Privacy Policy ("Policy") describes how c44com ("we", "us", "our") collects, processes, stores, and shares personal data in connection with the c44com Platform available at c44com.org. This Policy applies to all registered players, prospective players who browse the Platform without registering, and any individual who contacts c44com via live chat, email, or any other supported communication channel.

By accessing or using the c44com Platform — whether for cricket betting, live casino, slot games, virtual sports, or any other service — you acknowledge that you have read, understood, and accepted the practices described in this Privacy Policy. This Policy is incorporated by reference into c44com's Terms & Conditions, which together govern your relationship with the Platform.

This Policy is written in English and directed specifically at players based in Pakistan. Where Pakistani data protection norms differ from international standards, c44com applies the more protective standard in all cases.

2 Data Controller

For the purposes of applicable data protection law, c44com is the data controller responsible for the personal data of players registered on c44com.org. As the data controller, c44com determines the purposes and means by which your personal data is processed.

c44com operates under an international gaming licence. Our data protection officer can be contacted at any time via the support channels listed in Section 15 of this Policy. All formal data subject requests — including access, rectification, erasure, and portability requests — should be directed to our support team, which coordinates directly with the data protection officer for timely resolution.

3 Data We Collect

c44com collects only the personal data that is genuinely necessary for the provision of its gaming services, regulatory compliance, and the protection of its players. The categories of data we collect include:

c44com does not collect special category data (such as biometric data, health data, or political opinions) unless specifically required for identity verification under the terms of our gaming licence, in which case it is handled with the highest level of protection and immediately deleted once verification is complete.

4 How We Collect Data

c44com collects personal data through the following channels:

• Direct submission: When you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or participate in a promotion, you provide data directly to c44com.
• Automated collection: When you access the c44com Platform, technical data is collected automatically via server logs, cookies, and session tracking tools. This includes your IP address, device identifiers, and browsing behaviour within the Platform.
• Third-party sources: c44com may receive identity and address verification data from our approved KYC providers, and payment-related data from our payment processing partners (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and cryptocurrency processors).
• Publicly available sources: In limited AML-related circumstances, c44com may cross-reference data against publicly available sanctions lists, politically exposed persons (PEP) databases, and adverse media sources as required by our gaming licence.

5 Why We Use Your Data

c44com processes your personal data for the following specific purposes:

• Account management: Creating and maintaining your player account, verifying your identity, and managing your login credentials securely.
• Service delivery: Processing your bets on cricket, PSL, and other sports markets; providing access to slot games, live casino, and virtual sports; and crediting your account with winnings.
• Payment processing: Facilitating PKR deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and supported cryptocurrency methods.
• Regulatory compliance: Fulfilling our obligations under our international gaming licence, including KYC, AML checks, responsible gaming monitoring, and reporting requirements.
• Responsible gaming: Monitoring gaming behaviour to identify potential problem gambling patterns and applying self-exclusion, deposit limits, and reality-check tools where required.
• Fraud prevention and security: Detecting and preventing unauthorised account access, bonus abuse, money laundering, and match-fixing activity.
• Customer support: Responding to queries, resolving complaints, and maintaining records of support interactions for quality assurance.
• Marketing communications: Sending you promotions, bonus offers, and Platform updates — only where you have given explicit consent, and only via your preferred channel. You may opt out at any time.
• Platform improvement: Analysing aggregated, anonymised usage data to improve the c44com Platform experience for all Pakistani players.

6 Legal Basis for Processing

c44com relies on the following legal bases when processing your personal data:

• Performance of a contract: Processing your account registration data, payment information, and gaming activity data is necessary to deliver the services you have contracted for when you register on c44com.org.
• Legal obligation: KYC verification, AML monitoring, age verification, and regulatory reporting are carried out to comply with the obligations imposed by c44com's international gaming licence and applicable anti-money laundering standards.
• Legitimate interests: Fraud detection, Platform security, responsible gaming monitoring, and service improvement are carried out on the basis of c44com's legitimate interest in operating a secure, fair, and compliant gaming platform. We balance this interest against your privacy rights before processing.
• Consent: Direct marketing communications and optional personalisation features are processed on the basis of your explicit, freely given consent. You may withdraw consent at any time by contacting support or adjusting your account notification preferences.

7 Data Sharing

c44com does not sell, rent, or trade your personal data to unaffiliated third parties for their own marketing or commercial purposes. We share data only in the following limited and controlled circumstances:

• KYC and identity verification partners: Approved third-party providers who verify your identity documents and age as part of the account registration and ongoing compliance process. These providers are bound by strict data processing agreements.
• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and cryptocurrency processing partners receive the minimum necessary financial data to process your transactions. Each is an independent data controller subject to their own privacy policies for their own processing activities.
• Fraud and AML screening providers: Specialist third-party tools that help c44com identify suspicious betting patterns, account manipulation, and potential money laundering activity.
• Responsible gaming platform providers: Organisations that maintain cross-operator self-exclusion registers, to which c44com may be required to report a self-excluded player's details under its licence conditions.
• Regulatory authorities and law enforcement: Where legally required by our gaming regulator, a court order, or a law enforcement agency request, c44com will disclose personal data. We will notify you of such disclosure where legally permitted to do so.
• Business transfers: In the event of a merger, acquisition, or sale of c44com's business or assets, player data may be transferred to the acquiring entity, subject to equivalent privacy protections being maintained.

8 Cookies & Tracking Technologies

c44com uses cookies and similar tracking technologies on the c44com.org Platform. Cookies are small text files stored on your device that help us provide a functional, secure, and personalised gaming experience. The types of cookies we use are as follows:

• Strictly necessary cookies: Essential for Platform operation. These include session authentication cookies, CSRF protection tokens, and load-balancing cookies. These cannot be disabled without affecting Platform functionality.
• Performance cookies: Collect anonymised information about how players navigate the Platform — which games are most popular, which pages generate errors, and how long sessions last. All data is aggregated and non-identifiable.
• Functional cookies: Remember your preferences such as language settings, preferred game categories, and notification choices to personalise your experience on return visits.
• Security cookies: Help detect and prevent fraudulent activity, bot access, and brute-force login attempts by tracking anomalous request patterns.

c44com does not use third-party advertising cookies, cross-site tracking pixels, or social media tracking scripts. Your gaming activity on c44com.org is not shared with any advertising network.

You can manage cookie preferences through your browser settings at any time. Please note that disabling strictly necessary cookies will prevent you from logging in or using core Platform features. Disabling performance or functional cookies will not affect your access to games or your account balance.

9 Data Retention

c44com retains personal data only for as long as is necessary for the purpose for which it was collected, subject to the following minimum retention periods mandated by our gaming licence and applicable law:

• Account and identity data: Retained for a minimum of 5 years from the date of account closure to satisfy AML regulatory requirements.
• Transaction and financial records: Retained for a minimum of 5 years from the date of each transaction for accounting and AML audit purposes.
• Betting and gaming logs: Retained for a minimum of 3 years from the date of each wager to support dispute resolution and regulatory inspection obligations.
• Support communications: Retained for 2 years from the date of the final interaction, unless the communication relates to an unresolved formal complaint, in which case it is retained until the complaint is closed plus 2 years.
• Marketing consent records: Retained for the duration of your marketing subscription plus 3 years thereafter as evidence of consent.
• Self-exclusion records: Retained permanently to prevent re-registration in breach of a permanent self-exclusion agreement.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised. Anonymised data — from which no individual can be identified — may be retained indefinitely for statistical analysis and Platform improvement purposes.

10 Your Rights

As a data subject, you have the following rights in relation to the personal data c44com holds about you. To exercise any of these rights, contact c44com support via live chat or at [email protected] with the subject line "Data Rights Request".

c44com will respond to all data rights requests within 30 calendar days. Where a request is complex or numerous, we may extend this period by a further 60 days, in which case we will notify you of the extension and the reason for it within the initial 30-day window.

11 Data Security

c44com implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• TLS 1.3 / 256-bit SSL encryption on all data in transit between your device and c44com's servers.
• AES-256 encryption at rest for all databases storing personal and financial data.
• Multi-factor authentication (MFA) options for all player accounts and mandatory MFA for all c44com administrative access.
• Penetration testing conducted at least annually by an independent cybersecurity firm, with critical findings remediated within 30 days.
• Role-based access controls (RBAC) ensuring that c44com staff can only access the personal data necessary for their specific job function.
• Automated intrusion detection systems (IDS) monitoring for anomalous access patterns, brute-force attempts, and data exfiltration indicators around the clock.
• Secure data destruction protocols for all physical and digital media containing personal data that is no longer required.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, c44com will notify affected players without undue delay — and in any case within 72 hours of becoming aware of the breach — via the email address registered on your account, and will provide details of the nature of the breach, the data affected, and the steps c44com has taken in response.

12 Children & Minors

c44com operates a strict 21+ age policy. The Platform is not intended for, directed at, or accessible to individuals under the age of 21. c44com does not knowingly collect personal data from anyone under 21 years of age.

Age verification is mandatory for all new accounts. c44com employs both self-declaration at registration and documentary verification (via CNIC or equivalent) to confirm that all players meet the minimum age requirement before any real-money activity is permitted.

If c44com discovers or has reasonable grounds to suspect that a player is under 21 years of age, the account will be suspended immediately. Any deposits made by an underage player will be refunded to the originating payment method. Any winnings generated by an underage player will be forfeited. All personal data associated with the underage account will be deleted once the investigation and refund process is complete, except where retention is required for legal or regulatory reasons.

13 International Data Transfers

c44com's primary data processing infrastructure is located within the jurisdiction of its international gaming licence. As a Platform serving Pakistani players, some personal data may be transferred to, stored in, or processed in countries outside of Pakistan. Such transfers occur in the following circumstances:

• Transfer to our licensed jurisdiction's servers for primary account and transaction processing.
• Transfer to KYC verification providers operating verification platforms in their own jurisdictions.
• Transfer to cloud infrastructure providers who may replicate data across multiple geographic regions for redundancy and disaster recovery purposes.

Where data is transferred internationally, c44com ensures that appropriate safeguards are in place, including: contractual obligations on the recipient that mirror the protections afforded under this Policy; technical safeguards including end-to-end encryption for all data in transit; and, where applicable, binding corporate rules or standard contractual clauses recognised by the relevant data protection authority.

c44com will never transfer your personal data to a country that does not provide adequate protection for personal data without implementing the safeguards described above.

14 Policy Amendments

c44com may update this Privacy Policy from time to time to reflect changes in our data practices, changes to applicable law or our gaming licence conditions, or improvements in our security infrastructure. The date of the most recent revision is displayed at the top of this Policy and in your account notification history.

Where changes to this Policy are material — meaning they significantly affect how we process your data or the rights available to you — c44com will notify all registered players via email at least 14 days before the changes take effect. For non-material clarifications or administrative updates, the revised Policy will take effect upon publication to c44com.org.

Your continued use of the c44com Platform after the effective date of any Policy revision constitutes your acceptance of the updated Privacy Policy. If you do not accept the revised Policy, you should cease using the Platform and request account closure in accordance with our Terms & Conditions.

15 Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or want to raise a complaint about how c44com has handled your personal data, please contact us through any of the following channels:

• Live Chat: Available 24/7 on the c44com Platform — the fastest channel for urgent data matters.
• Email: [email protected] — use the subject line "Privacy Request" or "Data Complaint" as appropriate.
• Support Languages: English and Urdu — all support agents are fully bilingual.

c44com will acknowledge all privacy-related enquiries within 24 hours and aim to resolve them within 30 calendar days. If you are not satisfied with c44com's response to a data complaint, you have the right to escalate the matter to the data protection supervisory authority in the jurisdiction of c44com's gaming licence, or to seek independent legal advice.