Privacy Policy — 22c444

This Privacy Policy ("Policy") is published by 22c444 ("the Platform", "we", "us", "our") and sets out the principles governing our collection, use, disclosure, retention and protection of personal data provided by or collected from users ("you", "User", "Player") of the 22c444 website and associated services (collectively, "the Services").

22c444 is an English-language online casino and sportsbook information platform targeting Pakistani users. We recognise that the privacy and security of personal information is of paramount importance to our users across Pakistan — whether accessing the platform from Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar.

By accessing the Services, creating an Account or otherwise engaging with the 22c444 platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein. Where local data protection law grants you specific rights in relation to your personal data, this Policy outlines how you may exercise those rights.

This Policy should be read in conjunction with our Terms & Conditions, which constitute the broader legal agreement between you and 22c444.

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

• "Personal Data" means any information that identifies or can be used to identify a natural person, directly or indirectly, including but not limited to name, national identity number, contact details, IP address and financial information.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, alteration, transmission or deletion.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this case, 22c444.
• "Data Processor" means a third party that processes Personal Data on behalf of the Data Controller under contractual obligation.
• "Consent" means a freely given, specific, informed and unambiguous indication of agreement to the processing of Personal Data for a stated purpose.
• "Cookies" means small text files stored on your device by the platform to maintain session data, preferences and analytics information.
• "KYC" (Know Your Customer) means the identity and age verification procedures performed to confirm a user's identity, age and account legitimacy.
• "Special Category Data" refers to sensitive categories of personal information — such as health or biometric data — that attract enhanced protection under applicable data protection frameworks.

22c444 collects the following categories of personal data in the course of providing the Services:

22c444 collects personal data through the following means:

• Directly from you: Information you provide during Account registration, KYC verification, deposits, withdrawal requests, support interactions or when completing any form on the platform.
• Automatically: Technical and usage data collected through cookies, server logs, session tracking and similar technologies when you interact with the 22c444 platform.
• From third-party service providers: Verification data from identity verification services, fraud prevention databases and payment processing partners used to authenticate your identity or process transactions.
• From publicly available sources: Where permitted by applicable law, information from official public records or publicly accessible data sources may be used to supplement or verify data already held on your Account.

Where the operator's licensing jurisdiction requires a defined legal basis for each category of personal data processing, 22c444 relies on one or more of the following:

Personal data collected by 22c444 is used for the following purposes:

• Account management: To create, maintain and operate your 22c444 Account, including processing deposits, withdrawals and Account preference changes.
• Identity and age verification: To satisfy KYC requirements, confirm that you meet the minimum age threshold (18+ or higher as required by the operator's license jurisdiction) and verify your identity in accordance with AML obligations.
• Service improvement: To analyse usage patterns, improve the platform interface, optimise game and sportsbook performance and develop new features relevant to Pakistani users.
• Fraud prevention and security: To detect and prevent fraudulent activity, unauthorised account access, money laundering, collusion, bonus abuse and other prohibited conduct as defined in the Terms & Conditions.
• Responsible gambling management: To monitor betting patterns that may indicate problem gambling behaviour, apply voluntary limits and exclusions set by users and flag accounts for responsible gambling review where appropriate.
• Customer support: To respond to Help Centre tickets, Live Chat enquiries and other communications from users.
• Legal and regulatory compliance: To fulfil reporting, record-keeping and disclosure obligations imposed by the operator's licensing authority or other applicable legal requirements.
• Marketing (with consent): To send promotional communications, bonus offers and platform updates where you have opted in to receive such communications. You may withdraw consent at any time through your Account settings.

22c444 does not sell, rent or trade your personal data to third parties. We may share personal data only in the following limited and justified circumstances:

• Service Providers and Data Processors: Third parties engaged to provide services on behalf of 22c444 — including payment processing, identity verification, fraud detection, IT infrastructure and analytics — may access personal data to the extent strictly necessary for their contracted function. All such processors are bound by contractual data protection obligations.
• Regulatory and Licensing Authorities: Where required by the operator's licensing authority, we may disclose account and transaction data to regulators in the exercise of their supervisory powers.
• Law Enforcement: Where legally compelled by a court order, subpoena or equivalent legal process, or where disclosure is necessary to prevent fraud, money laundering or criminal activity, personal data may be disclosed to law enforcement or competent authorities.
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of all or part of the platform's business, personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations being maintained.

In all cases, data sharing is limited to what is necessary and proportionate to the stated purpose. We do not grant third parties access to personal data for their own marketing or commercial use.

As an online platform serving international users including those in Pakistan, 22c444 may process and store personal data on servers or through service providers located outside Pakistan. Where personal data is transferred to jurisdictions that may not provide the same level of data protection as the jurisdiction from which it originates, we implement appropriate safeguards — which may include contractual data protection clauses binding recipient entities — to ensure your data remains adequately protected.

By using the Services, you acknowledge that your personal data may be transferred, processed and stored in jurisdictions outside Pakistan, including jurisdictions where the operator holds a gaming licence. We will not transfer your data to jurisdictions that cannot provide an adequate level of protection without implementing appropriate contractual or technical safeguards.

22c444 retains personal data for no longer than is necessary for the purpose for which it was collected, or as required by applicable legal, regulatory or contractual obligations. The following general retention principles apply:

• Active Account data: Retained for the duration of your Account and updated as necessary throughout the customer relationship.
• KYC and identity documents: Typically retained for a period of five years following Account closure or the last transaction, in accordance with AML regulatory requirements applicable to the operator's license jurisdiction.
• Transaction records: Retained for a minimum of five years or such longer period as required by applicable financial crime regulation.
• Marketing data: Retained until you withdraw consent or opt out of marketing communications, following which it is deleted or anonymised within a reasonable timeframe.
• Support communications: Retained for a period sufficient to resolve any outstanding dispute and thereafter as may be required for legal or regulatory purposes.

Following the expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised such that it can no longer be attributed to any individual.

10.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They allow the platform to recognise your device across visits, maintain session security, remember your preferences and collect analytics data about how the platform is used.

10.2 Types of Cookies Used

• Strictly Necessary Cookies: Essential for the platform to function. These maintain your login session, apply security controls and ensure core features operate correctly. These cookies cannot be disabled without impacting your ability to use the Services.
• Functional Cookies: Remember your preferences — such as language settings, display options and responsible gambling tool configurations — to personalise your experience.
• Analytics Cookies: Collect aggregated, anonymised data about how users navigate and interact with the platform, enabling us to improve usability and performance. No individually identifiable data is extracted from these cookies.
• Session Cookies: Temporary cookies deleted when you close your browser. Used to maintain session continuity during a single visit.

10.3 Managing Cookies

Non-essential cookies can be managed through your browser settings. Most modern browsers allow you to block or delete cookies, though doing so may impair certain platform functions. Strictly necessary cookies cannot be disabled without affecting your ability to access the Services.

Subject to applicable data protection law and the operator's licensing obligations, you may hold the following rights in respect of your personal data held by 22c444:

• Right of Access: You may request a copy of the personal data held about you, along with information about how it is processed.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data. Where data accuracy affects your Account, updating your profile or contacting support is the standard process.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our retention obligations under AML, licensing and other applicable law. Erasure requests cannot override mandatory retention periods.
• Right to Restrict Processing: You may request that processing of your data be restricted in certain circumstances — for example, while a dispute over its accuracy is being resolved.
• Right to Data Portability: Where technically feasible and legally applicable, you may request your personal data in a structured, machine-readable format.
• Right to Withdraw Consent: Where processing is based on your consent (for example, marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time, and in certain circumstances to processing based on legitimate interests.

To exercise any of the above rights, please submit a request through the Help Centre ticketing system. We will respond within a reasonable timeframe. We may need to verify your identity before processing a data rights request.

The 22c444 platform is strictly for adults aged 18 or above — or the higher minimum age required by the operator's license jurisdiction. The Services are not directed at, designed for or intended to be used by minors. We do not knowingly collect personal data from individuals under the age of 18.

Where we become aware that personal data has been submitted by or in relation to a minor, we will take immediate steps to delete that data and close the associated Account. If you believe a minor has registered an Account or submitted personal data through the platform, please contact the support team immediately via Live Chat or the Help Centre.

22c444 implements a range of technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, loss or destruction. These measures include:

• HTTPS encryption for all data transmitted between your device and the 22c444 platform.
• Access controls limiting internal access to personal data to authorised personnel with a legitimate need.
• Secure storage of KYC documents in encrypted, access-controlled systems with audit trail logging.
• Two-factor authentication (2FA) available to users to protect Account access.
• Regular security reviews and monitoring for unusual access patterns or potential data breaches.

Notwithstanding the above, no data transmission over the internet is completely secure. While we apply industry-standard measures, we cannot guarantee absolute security and you use the Services at your own risk in this regard. In the event of a data breach affecting your rights and freedoms, we will notify you and, where required, the relevant regulatory authority in accordance with applicable obligations.

The 22c444 platform does not contain links to external third-party websites as a matter of policy. Where any third-party technology is embedded within the platform — such as game content from licensed studio providers or payment gateway interfaces — those third parties operate under their own privacy policies. 22c444 is not responsible for the privacy practices of third-party service providers beyond the contractual data processing obligations we impose on them.

Users are encouraged to review the privacy policies of any third-party service they interact with independently of the 22c444 platform.

22c444 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, legal obligations or the Services we offer. Material updates will be communicated to registered users via the contact information held on their Account or through a prominent notice on the platform.

The "Last Updated" date at the top of this page indicates when this Policy was most recently revised. Continued use of the Services following notification of a material update constitutes acceptance of the revised Policy. We recommend reviewing this page periodically to stay informed of any changes.

For any questions, concerns or requests relating to this Privacy Policy or your personal data held by 22c444, please contact our Data Protection team through the following channels:

• Live Chat: Available 24/7 through your Account dashboard for urgent queries including data security concerns.
• Help Centre: Submit a formal data rights request or privacy enquiry through the ticketing system, accessible from the main navigation or Account settings.
• Email (plain text): [email protected]

Please mark any formal data rights request clearly as a "Data Rights Request" in your correspondence. We will acknowledge receipt and respond within a reasonable timeframe, and in any case within the period required by applicable data protection law.