c44 Privacy Policy —
How We Handle Your Personal Data

For the purposes of this Privacy Policy, the following terms shall have the meanings set out below:

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, CNIC number, mobile number, email address, IP address, financial data, and gaming activity records.
• "Processing" — any operation or set of operations performed on personal data, including collection, recording, storage, adaptation, retrieval, use, disclosure, and erasure.
• "Data Controller" — c44, the entity that determines the purposes and means of processing personal data collected through the c44 platform.
• "Data Processor" — any third party that processes personal data on behalf of c44 under contractual instruction, including payment processors and KYC verification providers.
• "Consent" — any freely given, specific, informed, and unambiguous indication of a Player's agreement to the processing of their personal data for a stated purpose.
• "KYC" — Know Your Customer identity verification, encompassing CNIC verification, address confirmation, and payment method validation as required by c44's international gaming licence.
• "Cookies" — small data files placed on a Player's device by the c44 platform to enable session management, analytics, and personalisation features.

The Data Controller responsible for your personal data is the operating entity behind the c44 platform at c44.today. c44 is operated under a valid international gaming licence, the conditions of which impose data protection and security obligations that the platform is required to comply with at all times.

All data protection enquiries, access requests, and complaints should be addressed in writing to the c44 Data Protection point of contact at: [email protected]. Please include "Data Protection" in the subject line of your communication to ensure proper routing.

c44 collects the following categories of personal data in connection with the registration and use of the c44 platform:

c44 collects personal data through the following channels and mechanisms:

The majority of personal data c44 holds about you is provided directly by you during the account registration process, KYC verification, payment method setup, customer support interactions, and when you activate responsible gaming controls. This includes your CNIC details, mobile number, and payment account references.

When you access the c44 platform, certain technical data is collected automatically by our servers and analytics systems. This includes your IP address, the type of device and browser you are using, the pages you visit within the c44 platform, and the duration of your session. This data is collected to ensure platform security and performance.

When you deposit or withdraw funds via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, or any other supported payment method, c44 receives transaction confirmation data from the payment processor. This data is used solely to credit your PKR wallet, process withdrawals, and maintain financial records as required by our gaming licence.

c44 may use third-party KYC verification service providers to assist in validating CNIC documents and confirming the authenticity of identity data submitted during registration. These providers act as Data Processors under contract with c44 and are not permitted to use your data for any purpose other than facilitating KYC verification on c44's behalf.

c44 processes personal data under one or more of the following legal bases, depending on the category of data and the purpose of processing:

• Contractual Necessity: Processing is necessary to perform the contract between c44 and the Player — including operating the Player's account, processing deposits and withdrawals in PKR, settling bets, and providing customer support.
• Legal Obligation: Processing is necessary to comply with legal and regulatory obligations under c44's international gaming licence — including KYC/AML requirements, age verification, responsible gaming monitoring, and financial record-keeping.
• Legitimate Interests: Processing is necessary for c44's legitimate business interests, including fraud prevention, platform security, abuse detection, and improving the overall player experience — provided these interests do not override your fundamental privacy rights.
• Consent: Where processing is based on consent — particularly in relation to marketing communications and non-essential cookie placement — c44 will obtain your explicit consent prior to processing and will honour any withdrawal of that consent promptly.

c44 uses the personal data it collects for the following specific purposes:

1. Account Management: Creating, maintaining, and managing your c44 account, including processing your c44 login credentials and account security settings.
2. Payment Processing: Accepting PKR deposits via JazzCash, EasyPaisa, and other supported methods; processing withdrawal requests to verified payment accounts; maintaining transaction records.
3. Identity Verification: Verifying your identity and age through CNIC-based KYC procedures as required by c44's gaming licence.
4. Gaming Services Delivery: Providing access to cricket betting, live casino, slot games, fishing games, and all other c44 platform features to verified, eligible players.
5. Responsible Gaming: Monitoring gaming activity patterns to identify indicators of problem gambling behaviour; enforcing deposit limits, cool-off periods, and self-exclusion controls activated by the Player.
6. Fraud Prevention and Security: Detecting and preventing fraudulent account activity, money laundering, bonus abuse, and unauthorised account access.
7. Customer Support: Responding to support enquiries, complaints, and disputes submitted by Players via email or live chat.
8. Regulatory Compliance: Maintaining records required by gaming regulators, tax authorities, and anti-money laundering obligations under c44's international gaming licence.
9. Platform Improvement: Analysing aggregated, anonymised usage data to improve the c44 platform's performance, user interface, and game offering.
10. Marketing Communications: Where consent has been given, sending promotional emails or notifications about c44 bonuses, PSL betting markets, and other relevant offers. Players may opt out of marketing communications at any time through their account settings or by contacting support.

c44 does not sell your personal data. We share personal data with third parties only in the following limited and controlled circumstances:

Your financial data is shared with the payment processors that facilitate your PKR deposits and withdrawals — including JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Allied Bank, SadaPay, and USDT platform providers. Data shared with payment processors is limited to what is strictly necessary to complete the requested transaction.

CNIC identity data may be shared with third-party KYC service providers contracted to assist c44 with identity and age verification. These providers are bound by data processor agreements and may not use your CNIC data for any purpose other than the verification services they provide to c44.

c44 may be legally required to disclose personal data to gaming regulators, financial intelligence authorities, or law enforcement agencies in connection with the investigation of fraud, money laundering, match-fixing, or other criminal conduct. Such disclosures will be made only to the extent required by applicable law or regulatory direction.

c44 uses third-party cloud hosting, cybersecurity, and analytics providers to operate its technical infrastructure. These providers process data only on c44's instruction under contractual data processing agreements and are not permitted to access or use your personal data for their own purposes.

Legal counsel, auditors, and insurers engaged by c44 may have access to personal data on a strictly need-to-know basis in the context of professional services they provide to c44. All such professionals are bound by applicable professional confidentiality obligations.

The c44 platform uses cookies and similar tracking technologies to operate effectively and securely. The following categories of cookies are used by c44:

• Strictly Necessary Cookies: These cookies are essential for the c44 platform to function and cannot be disabled. They are used for session management, maintaining your c44 login state, and enabling the PKR wallet and cashier to operate correctly. These cookies do not require your consent as they are necessary for the contractual delivery of services.
• Performance & Analytics Cookies: These cookies collect anonymised data about how Players use the c44 platform — including which pages are visited most frequently and where errors occur. This data helps c44 improve platform performance. These cookies require your consent where applicable.
• Functionality Cookies: These cookies remember your preferences — such as game lobby display settings and responsible gaming configuration. Disabling functionality cookies may impair certain personalisation features of the c44 platform.
• Security Cookies: c44 uses cookies as part of its fraud detection and account security infrastructure. These cookies help identify unusual login patterns or suspicious session behaviour that may indicate unauthorised account access.

Players using standard web browsers can control cookie behaviour through their browser settings. However, disabling strictly necessary cookies will prevent the c44 platform from functioning correctly. c44 does not use cross-site tracking cookies or third-party advertising cookies.

c44 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Key security measures include:

• TLS Encryption: All data transmitted between your device and the c44 platform is encrypted using Transport Layer Security (TLS). This protects your c44 login credentials, financial data, and personal information in transit.
• Encrypted Data Storage: Sensitive personal data — including CNIC document images and financial transaction records — is stored in encrypted form on secured infrastructure. Encryption keys are managed separately from the encrypted data.
• Access Controls: Access to personal data within c44's systems is restricted to personnel who require it to perform their role. Role-based access controls are in place, and all access is logged for audit purposes.
• Two-Factor Authentication: c44 offers Two-Factor Authentication (2FA) to all Players for their account login and encourages its use as a critical layer of personal account security.
• Security Audits: c44 conducts periodic security assessments of its data processing systems as required by its international gaming licence conditions. Third-party penetration testing is performed on a scheduled basis.
• Incident Response: c44 maintains an incident response plan for data security events. In the event of a data breach that poses a material risk to Players, c44 will notify affected individuals and relevant regulatory authorities in accordance with applicable notification requirements.

c44 retains personal data for no longer than is necessary for the purpose for which it was collected, subject to the following specific retention considerations:

• Active Account Data: Personal data associated with an active c44 account is retained for the duration of the account relationship plus a post-closure retention period as specified below.
• Post-Closure Retention: Following the closure of a c44 account, personal data — including KYC documents, financial transaction records, and gaming activity logs — is retained for a minimum period of five (5) years, as required by anti-money laundering regulations applicable under c44's international gaming licence.
• Legal Hold: Where personal data is relevant to a pending legal dispute, regulatory investigation, or law enforcement request, c44 may retain that data beyond its standard retention period until the matter is fully resolved.
• Marketing Data: Where a Player withdraws consent for marketing communications, c44 will retain a suppression record of that opt-out decision to ensure the Player is not contacted again. The underlying contact data will be removed from active marketing lists within 30 days of the opt-out request.
• Technical Logs: Server and access logs containing IP addresses and session data are retained for up to 12 months for security and fraud investigation purposes, after which they are deleted or anonymised.

As an internationally licensed gaming platform, c44 may process and store personal data on infrastructure located outside of Pakistan. Where personal data is transferred to jurisdictions outside of Pakistan, c44 takes the following steps to ensure your data remains protected:

• Transfers are made only to jurisdictions that provide an adequate level of data protection as determined by recognised international standards, or to entities that have agreed to contractual data protection clauses that impose equivalent obligations to those described in this Policy.
• Third-party data processors to whom data is transferred internationally are contractually required to implement security measures equivalent to those maintained by c44 and to process data only for the purposes specified in their processor agreement.
• CNIC documents and other identity verification materials provided by Pakistani players are processed through KYC service providers whose data handling practices are subject to contractual audit rights held by c44.

As a c44 Player, you have the following rights in relation to the personal data we hold about you. To exercise any of these rights, submit a written request to [email protected] with the subject line "Privacy Rights Request" and your registered account details for identity verification.

The c44 platform is strictly prohibited for use by persons under the age of 21 years. c44 does not knowingly collect personal data from individuals under 21. CNIC-based age verification is applied to all new account registrations to prevent underage access to the platform.

If c44 becomes aware that personal data has been collected from an individual who is under 21 years of age, that data will be deleted immediately and the associated account will be permanently closed. Any funds deposited by an underage player will be returned to the payment method used for deposit following an investigation period.

The c44 platform may incorporate game content from third-party licensed studio providers — including live dealer casino operators and slot game developers. These studio providers operate their own privacy practices in relation to the game software they deliver, which may include separate data processing activities for game integrity and audit purposes. c44 ensures that all third-party game studio contracts include appropriate data protection provisions.

c44 is not responsible for the privacy practices of any third-party payment processor or service provider accessed during the course of a transaction on the c44 platform. Players are encouraged to review the privacy policies of their chosen payment methods — including JazzCash and EasyPaisa — in relation to the data those providers collect and process in connection with transactions made to and from their c44 account.

c44 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, gaming licence requirements, data processing practices, or operational changes to the platform. Material amendments will be communicated to registered Players by email to their registered address, with the revised Policy taking effect no sooner than seven (7) days following notification.

The "Last Reviewed" date at the top of this page will be updated whenever the Policy is revised. Players are encouraged to review this Policy periodically. Continued use of the c44 platform following any revision constitutes acceptance of the updated Policy. If you do not accept the revised Policy, please close your c44 account and withdraw any available funds before the new Policy takes effect.

If you have any questions, concerns, or complaints regarding the way c44 handles your personal data, please contact us at:

• Data Protection Enquiries: [email protected] — please include "Privacy Policy" or "Data Protection" in your subject line
• Response Commitment: c44 aims to acknowledge all privacy-related enquiries within 5 business days and to provide a substantive response within 30 days
• Escalation: If you are not satisfied with c44's response to a privacy complaint, you may refer the matter to the data protection supervisory authority relevant to c44's licensing jurisdiction, or to the dispute resolution body specified in c44's Terms & Conditions

Pakistani players with specific concerns about their CNIC data, PKR transaction records, or account-related personal data may request a direct data audit by submitting a formal written request to c44 support. c44 will verify your identity before disclosing any personal data in response to such requests.