01 Introduction
This Privacy Policy ("Policy") describes how c44com ("c44com", "the Platform", "we", "us", "our"), accessible at https://c44com.cam/, collects, uses, stores, processes and protects the personal data of users ("you", "your", "User") who access or use the Platform.
c44com is an English-language online betting and live casino information platform serving users including, but not limited to, individuals based in Pakistan. We are committed to handling personal data responsibly, transparently and in accordance with applicable data protection principles. By registering on or using c44com, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.
This Policy should be read alongside the c44com Terms & Conditions, which govern your use of the Platform as a whole. Where this Policy and the Terms & Conditions overlap, this Policy takes precedence with respect to data protection matters.
Pakistani users: Pakistan's data protection framework continues to evolve. c44com applies data handling practices aligned with internationally recognised data protection principles. We do not claim that our practices are certified or approved by any Pakistani regulatory authority.
02 Definitions
In this Policy, the following terms carry the meanings assigned below:
- "Personal Data" means any information relating to an identified or identifiable natural person, including name, date of birth, contact details, financial information and any identifiers that can reasonably be used to identify an individual.
- "Processing" means any operation performed on Personal Data, including collection, recording, organisation, storage, adaptation, retrieval, use, disclosure, erasure or destruction.
- "Data Controller" means the entity that determines the purposes and means of Processing Personal Data. For the purposes of this Policy, c44com is the Data Controller.
- "Data Processor" means a third party that processes Personal Data on behalf of the Data Controller pursuant to a contractual arrangement.
- "KYC Documents" means identity and verification documents submitted by Users, including CNIC, passport, proof of address and payment method verification materials.
- "Cookies" means small text files placed on your device by the Platform to collect technical usage information.
- "Consent" means a freely given, specific, informed and unambiguous indication of agreement to the Processing of Personal Data for a stated purpose.
03 Personal Data We Collect
c44com collects the following categories of Personal Data, depending on how you interact with the Platform:
3.1 Registration & Account Data
- Full legal name
- Date of birth
- Email address
- Mobile telephone number
- Residential address, including city (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar)
- Username and encrypted password
- Account preferences and settings
3.2 Identity Verification (KYC) Data
- Copy of valid CNIC or passport
- Proof of address documentation (utility bill, bank statement or official letter, where required)
- Selfie or liveness check image as required by the verification process
- Payment method ownership documentation
3.3 Financial & Transaction Data
- Deposit and withdrawal amounts and dates
- Payment method identifiers (wallet reference numbers, masked bank account details)
- Transaction history
- Bet history, game activity and wagering records
3.4 Technical & Usage Data
- IP address and approximate geolocation derived from IP
- Device type, operating system and browser version
- Session duration and navigation path data
- Cookie identifiers and similar tracking technologies
- Platform error logs and crash reports
3.5 Communication Data
- Support chat transcripts and email correspondence
- Feedback and survey responses
- Records of marketing preference updates
KYC document security: KYC documents must be submitted only through the Platform's official HTTPS-secured verification portal. c44com will never request identity documents via email, WhatsApp, Telegram or any other unsecured channel. Requests received through unofficial channels should be treated as fraudulent.
04 How Personal Data Is Collected
Personal Data is collected through the following mechanisms:
- Direct provision: Data you voluntarily provide during registration, KYC submission, deposit or withdrawal requests, support interactions or survey participation.
- Automated collection: Technical data collected automatically when you access the Platform, including IP address, device information, cookies and session data.
- Third-party sources: Identity verification may be supplemented by data from third-party KYC verification service providers, fraud-prevention databases and payment processors, where lawful and necessary.
- Payment processing: Transaction data is collected through the payment rails used for deposits and withdrawals, including references from mobile wallet systems and banking networks.
05 Purposes of Processing
c44com processes Personal Data for the following purposes. The table below maps each purpose to the categories of data used:
| Purpose |
Data Categories Used |
| Account creation and management |
Registration data, technical data |
| Identity and age verification (KYC) |
KYC documents, registration data |
| Processing deposits and withdrawals |
Financial data, KYC documents |
| Fraud prevention and AML compliance |
Financial data, KYC documents, technical data |
| Responsible gambling monitoring |
Bet history, session data, registration data |
| Customer support |
Communication data, account data |
| Platform security and performance |
Technical data, usage data |
| Legal and regulatory compliance |
All categories as required by applicable law |
| Marketing communications (consent-based) |
Registration data, communication preferences |
| Platform improvement and analytics |
Technical data, usage data (aggregated/anonymised where possible) |
06 Legal Basis for Processing
c44com processes Personal Data on the following lawful bases, consistent with internationally recognised data protection principles:
- Contractual necessity: Processing required to perform the contract between c44com and the User — including account management, bet processing, payment handling and KYC verification.
- Legal obligation: Processing required to comply with applicable legal requirements, including anti-money laundering obligations, age verification duties and data retention laws.
- Legitimate interests: Processing carried out for c44com's legitimate business interests, including fraud prevention, platform security and service improvement, provided such interests are not overridden by Users' data protection rights.
- Consent: Processing for purposes such as marketing communications, where specific opt-in consent has been obtained from the User. Consent may be withdrawn at any time without affecting prior processing or the User's account standing.
07 Data Sharing & Disclosure
c44com does not sell your Personal Data. We share Personal Data only in the following circumstances and only to the extent necessary for the specified purpose:
- KYC and identity verification providers: Third-party providers contracted to perform identity and age verification processes. These providers act as Data Processors under binding data processing agreements.
- Payment processors: Processing entities involved in facilitating deposits and withdrawals. References to payment rails familiar to Pakistani users — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — reflect commonly used payment infrastructure only. Their mention does not imply endorsement of gambling or a confirmed integration.
- Fraud and AML compliance tools: Third-party fraud detection and anti-money laundering screening services used to protect the Platform and comply with regulatory obligations.
- IT and hosting providers: Cloud infrastructure, security and technical support providers who process data on our behalf under contractual obligations.
- Legal and regulatory authorities: Where required by applicable law, court order or regulatory direction, c44com may be obliged to disclose Personal Data to law enforcement agencies or regulatory bodies.
- Business transfers: In the event of a merger, acquisition or sale of all or part of c44com's business, Personal Data may be transferred to the acquiring entity as part of that transaction, subject to equivalent privacy protections.
Third-party processors: All third-party service providers with access to Personal Data are subject to contractual obligations that restrict them to processing data solely for the purposes specified by c44com. They are prohibited from using your data for their own commercial purposes.
08 Data Retention
c44com retains Personal Data for as long as necessary to fulfil the purposes outlined in this Policy, subject to applicable legal retention requirements. The following general retention principles apply:
- Account data: Retained for the duration of the account relationship and for a defined period after account closure as required by AML, fraud prevention and regulatory record-keeping obligations. This period is typically five (5) years from the date of account closure, subject to applicable law.
- KYC documents: Retained for the period required by applicable AML and identity verification regulations, which typically extends for a minimum of five (5) years following the end of the business relationship.
- Financial records: Transaction and bet history records are retained for the period required by applicable financial regulation, typically a minimum of five (5) years.
- Technical and usage data: Retained for operational and security purposes for a shorter period, typically up to two (2) years, or as required for ongoing compliance investigations.
- Marketing preferences: Retained until consent is withdrawn and for a reasonable period thereafter to evidence the history of marketing consent and opt-out.
Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in a manner that prevents re-identification.
09 Data Security
c44com implements and maintains appropriate technical and organisational security measures to protect Personal Data against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include:
- Encryption of data in transit using TLS/HTTPS protocols across all Platform communications.
- Encryption of sensitive data at rest, including KYC documents and financial records.
- Access controls restricting Personal Data access to authorised personnel on a need-to-know basis.
- Regular security assessments and vulnerability testing of platform infrastructure.
- Incident response procedures for detecting, investigating and notifying affected parties of data breaches where required.
- Staff training on data protection obligations and secure data handling practices.
Your role in security: While c44com maintains robust security measures, you also play an important part. Use a strong, unique password for your account. Do not share your login credentials with any third party. If you suspect unauthorised account access, contact our support team immediately.
No data transmission over the internet can be guaranteed as completely secure. While c44com takes every reasonable precaution, we cannot warrant absolute security of data transmitted to or from the Platform.
10 Cookies & Tracking Technologies
c44com uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain session continuity, analyse usage patterns and, where consent is given, deliver relevant marketing content.
- Strictly Necessary Cookies: Essential for the Platform to function. These enable login sessions, cashier operations and security features. They cannot be disabled without impairing Platform functionality.
- Analytical Cookies: Used to understand how Users navigate the Platform, which pages are visited most frequently and where technical issues occur. Data is aggregated and used to improve the Platform.
- Preference Cookies: Store your Platform settings and preferences, such as language selection and display configurations.
- Marketing Cookies: Used, with your consent, to deliver content and promotions relevant to your interests. You may opt out of marketing cookies at any time through your browser settings or by contacting support.
Most web browsers allow you to control cookie settings. Disabling certain cookies may affect Platform functionality. Refer to your browser's help documentation for instructions on managing cookie preferences.
11 International Data Transfers
c44com may transfer Personal Data to third-party service providers located in jurisdictions outside Pakistan. Where such transfers occur, c44com ensures that appropriate safeguards are in place to protect your Personal Data, including contractual data processing agreements that impose obligations equivalent to those required under applicable data protection principles.
c44com does not transfer Personal Data to jurisdictions that do not maintain an adequate level of data protection without putting in place appropriate safeguards as described above.
12 Minors
c44com is strictly an adults-only platform. We do not knowingly collect Personal Data from individuals below the minimum eligible age of 18 years, or the higher minimum required by the operator's licence jurisdiction.
Underage access is prohibited. If we become aware that Personal Data has been collected from an individual below the minimum eligible age, we will take immediate steps to delete that data and close the associated account. Parents and guardians are encouraged to use parental control software to prevent minors from accessing gambling platforms.
13 Your Data Subject Rights
Subject to applicable law and the specific circumstances of your request, you hold the following rights with respect to your Personal Data held by c44com:
You have the right to request a copy of the Personal Data c44com holds about you, along with information on how it is processed. Requests will be responded to within a reasonable timeframe consistent with applicable law.
You have the right to request correction of inaccurate or incomplete Personal Data held by c44com. Some corrections may require supporting documentation to verify the accuracy of the updated information.
You may request deletion of your Personal Data in certain circumstances — for example, where it is no longer necessary for the purpose for which it was collected. This right is subject to overriding legal obligations, such as AML and financial record-keeping requirements that mandate retention for a specified minimum period.
You may request that c44com restrict Processing of your Personal Data in specific circumstances — for example, while the accuracy of the data is being contested, or where Processing is unlawful but you prefer restriction over deletion.
Where Processing is based on consent or contractual necessity and is carried out by automated means, you may request that your Personal Data be provided to you in a structured, commonly used and machine-readable format.
You have the right to object to the Processing of your Personal Data where it is based on legitimate interests. You also have an unconditional right to object to Processing of your data for direct marketing purposes at any time.
Where Processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of Processing carried out prior to withdrawal. To withdraw consent, contact our support team or use the opt-out mechanism in your account settings.
Exercising your rights: To submit a data subject rights request, contact c44com at
[email protected] (plain text — not a clickable link). Include your full name, registered email address and a clear description of your request. We may request identity verification before processing your request to prevent unauthorised disclosures.
14 Marketing Communications
c44com may send you marketing communications — including promotional offers, bonus notifications and platform updates — where you have provided explicit consent to receive such communications. Marketing consent is opt-in only and is collected separately from the general account registration process.
You may withdraw consent and opt out of marketing communications at any time by:
- Updating your marketing preferences in your Account settings;
- Using the unsubscribe mechanism included in any email marketing message; or
- Contacting our support team and requesting removal from marketing lists.
Opting out of marketing communications has no effect on your account status or your ability to use the Platform's services. You will continue to receive transactional and account-related communications (such as deposit confirmations, withdrawal notifications and security alerts) regardless of your marketing preferences.
15 Third-Party Links & Services
c44com does not include external links to third-party websites within its platform pages. However, certain integrated services — such as payment processing and identity verification — involve third-party providers. Each of these providers operates under its own privacy policy and data protection practices.
c44com is not responsible for the privacy practices of third-party service providers. We select providers that maintain appropriate data protection standards and contractually bind them to handle your data in accordance with our requirements.
16 Amendments to This Policy
c44com reserves the right to update this Privacy Policy at any time. Where amendments are material — for example, changes to the categories of data collected, the purposes for which it is used or the rights available to you — we will provide reasonable advance notice, such as a prominent notice on the Platform or an email to your registered address.
The date of the most recent revision is displayed at the top of this page. We encourage you to review this Policy periodically. Continued use of c44com following a Policy update constitutes your acceptance of the revised version. If you do not accept a material change, you may request account closure in accordance with the Terms & Conditions.