44pak Privacy Policy —
How We Handle Your Data

01 Who We Are

This Privacy Policy applies to the 44pak online gaming platform, accessible at 44pak.net (the "Platform"). Throughout this document, "44pak", "we", "us", and "our" refer to the operating entity behind the 44pak Platform, which holds an international gaming licence issued by the relevant regulatory authority under whose jurisdiction the Platform operates.

44pak is the data controller in respect of all personal data collected from players registering on or using the Platform. As data controller, 44pak determines the purposes and means of processing your personal data and is responsible for ensuring that processing is carried out lawfully, fairly, and transparently.

If you have any questions about this Privacy Policy or how 44pak handles your personal data, you may contact our Data Protection team via the support email address displayed in the footer of every page on this Platform.

02 Data We Collect

44pak collects personal data from you in the following ways: directly when you provide it during registration or subsequent account activity; automatically when you interact with the Platform; and, in limited cases, from third-party service providers as part of our identity verification and fraud prevention processes.

The categories of personal data we collect include:

03 How We Use Your Data

44pak processes your personal data only for the specific, lawful purposes described below. We do not use your data in ways that are incompatible with these stated purposes.

• Account Creation & Management: To register your account, verify your identity, maintain your player profile, and manage your account preferences and settings.
• Payment Processing: To facilitate deposits and withdrawals via JazzCash, EasyPaisa, Raast, HBL, UBL, Meezan Bank, 1LINK, USDT (TRC20), and cash deposit methods. Financial data is processed in PKR and retained in accordance with applicable financial regulations.
• KYC & Age Verification: To verify that you meet the minimum age requirement of 21 years and to confirm your identity in compliance with our licensing obligations and anti-money laundering (AML) requirements.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, account takeovers, multi-accounting, bonus abuse, and any other prohibited conduct described in our Terms & Conditions.
• Regulatory Compliance: To meet our obligations under applicable gaming regulations, anti-money laundering laws, and any reporting requirements imposed by the regulatory authority under whose jurisdiction 44pak operates.
• Customer Support: To respond to your enquiries, resolve disputes, process complaints, and improve the quality of our support services.
• Responsible Gaming: To monitor gaming patterns and identify players who may be experiencing gambling-related harm, and to administer self-exclusion and account restriction tools effectively.
• Platform Improvement: To analyse aggregated usage data, diagnose technical issues, and improve the performance, security, and features of the 44pak Platform.
• Marketing Communications: Where you have provided explicit consent, to send you promotional emails, SMS notifications, and in-platform messages about 44pak bonuses, events, and new game releases. You may withdraw consent at any time through your account settings.

04 Legal Basis for Processing

Under applicable data protection frameworks, 44pak relies on the following legal bases to process your personal data:

• Contractual Necessity: Processing required to fulfil our contract with you — i.e., to operate your account, process payments, and deliver the gaming services you have requested.
• Legal Obligation: Processing required to comply with our legal and regulatory obligations, including KYC verification, AML reporting, and age verification.
• Legitimate Interests: Processing carried out for our legitimate business interests — such as fraud prevention, platform security, and improving our services — where those interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, informed consent — primarily in the context of direct marketing communications. Where consent is the legal basis, you have the right to withdraw it at any time without affecting the lawfulness of prior processing.

05 Data Sharing & Third Parties

44pak does not sell, rent, or trade your personal data to third parties. We may share your data with carefully selected third-party service providers and in the specific circumstances described below:

• Payment Processors: JazzCash, EasyPaisa, Raast, HBL, UBL, Meezan Bank, 1LINK, and cryptocurrency processing providers receive the minimum financial data necessary to execute your deposit and withdrawal transactions.
• Identity Verification Providers: Third-party KYC and age verification services receive identity documents (CNIC, passport) solely for the purpose of confirming your eligibility to use the Platform.
• Game Software Providers: Third-party game studios and live dealer providers may receive technical session data (e.g., player session tokens) to facilitate gameplay. These providers do not receive your personal identity or financial data.
• IT & Hosting Providers: Cloud infrastructure and data hosting partners who process data on 44pak's behalf under strict data processing agreements that prohibit them from using your data for their own purposes.
• Regulatory Authorities: Where required by law or by a valid regulatory order, 44pak will disclose personal data to the relevant gaming regulator, financial intelligence unit, or law enforcement authority.
• Fraud Prevention Networks: In cases of confirmed fraud or money laundering, 44pak may share relevant data with industry-wide fraud prevention databases and law enforcement agencies.

All third-party processors engaged by 44pak are contractually required to process personal data only on 44pak's documented instructions, to maintain appropriate technical and organisational security measures, and to refrain from disclosing your data to any further parties without prior written authorisation from 44pak.

06 International Data Transfers

The 44pak Platform operates internationally, and some of the third-party service providers we engage may process your personal data in countries outside Pakistan. Where such transfers occur, 44pak takes steps to ensure that your data is afforded an equivalent level of protection to that which it would receive in Pakistan, including through the use of:

• Contractual clauses that impose data protection obligations on the receiving party equivalent to those under applicable data protection standards.
• Transfers only to service providers operating in jurisdictions that the relevant regulatory authority has assessed as providing adequate data protection.
• Technical safeguards including end-to-end encryption for data in transit across international networks.

If you would like further information about the safeguards 44pak applies to international data transfers, please contact our support team.

07 Data Retention

44pak retains your personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following retention periods apply:

• Account & Identity Data: Retained for the duration of your account relationship with 44pak, plus a minimum of five (5) years following account closure, in compliance with AML and gaming regulatory requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required under applicable financial record-keeping regulations.
• Support Communications: Retained for three (3) years from the date of the interaction, for quality assurance and dispute resolution purposes.
• Technical & Usage Logs: Retained for twelve (12) months from the date of collection, after which they are anonymised or deleted.
• Marketing Consent Records: Retained for the duration of your consent, plus three (3) years following withdrawal of consent, to demonstrate compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with 44pak's data destruction procedures.

08 Cookies & Tracking Technologies

44pak uses cookies and similar tracking technologies on the Platform. A cookie is a small text file placed on your device when you visit a website. The following types of cookies are used on 44pak:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies, security tokens, and load balancing cookies. These cannot be disabled without breaking core platform functionality.
• Performance & Analytics Cookies: Used to collect anonymised data about how players interact with the Platform, including pages visited, time spent, and error occurrences. This data is used solely to improve the Platform and is not linked to your personal identity.
• Functional Cookies: Used to remember your preferences, such as language settings and game display preferences, to provide a more personalised experience.

44pak does not use third-party advertising cookies or cross-site tracking technologies. You can control cookie settings through your browser preferences. Please note that disabling strictly necessary cookies may impair your ability to log in or use core Platform features.

09 Your Privacy Rights

As a 44pak player, you have the following rights in respect of your personal data. To exercise any of these rights, please contact our support team. We will respond to all valid requests within 30 days of receipt.

• Right of Access: You have the right to request a copy of all personal data 44pak holds about you, together with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations.
• Right to Restriction of Processing: You have the right to request that 44pak restricts the processing of your data in certain circumstances, for example while a dispute is being investigated.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another data controller.
• Right to Object: You have the right to object to processing based on our legitimate interests. You may also object to receiving direct marketing communications at any time.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

10 Children & Minors

The 44pak Platform is strictly intended for individuals aged 21 years and older. 44pak does not knowingly collect personal data from anyone under the age of 21. Age verification is conducted as part of the account registration process, and all accounts are subject to mandatory KYC verification prior to first withdrawal.

If 44pak becomes aware that personal data has been collected from an individual under 21 years of age, the following steps will be taken immediately:

• The account will be suspended pending investigation.
• All funds in the account, including deposits and any winnings, will be forfeited in accordance with our Terms & Conditions.
• All personal data associated with the underage account will be securely deleted from our systems.
• The incident will be reported to the relevant regulatory authority where required by law.

If you believe that a minor may have registered on the 44pak Platform, please contact our support team immediately so that we can investigate and take appropriate action without delay.

11 Security Measures

44pak implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS Encryption: All data in transit between your device and our servers is encrypted using industry-standard SSL/TLS protocols.
• Data Encryption at Rest: Sensitive personal and financial data stored on our servers is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data within 44pak's systems is restricted to authorised personnel on a strictly need-to-know basis. All internal access is logged and audited.
• Two-Factor Authentication: 44pak supports two-factor authentication (2FA) for player accounts and mandates it for all internal administrative access to player data systems.
• Regular Security Audits: Our platform undergoes regular penetration testing and third-party security audits to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: 44pak maintains a documented data breach response procedure. In the event of a breach affecting your personal data, we will notify the relevant regulatory authority and affected players in accordance with applicable legal timeframes.

While 44pak takes all reasonable precautions to protect your data, no digital system is completely immune to security risks. You are responsible for maintaining the security of your own account credentials and for notifying us promptly of any suspected unauthorised access.

12 Marketing Communications

44pak may send you promotional emails, SMS messages, and in-platform notifications about bonuses, new games, PSL betting markets, special events, and other offers — but only where you have provided explicit consent to receive such communications during registration or through your account settings.

You can opt out of marketing communications at any time through any of the following methods:

• Clicking the "unsubscribe" link included in any promotional email.
• Replying "STOP" to any promotional SMS message.
• Updating your marketing preferences in your 44pak account settings.
• Contacting the 44pak support team and requesting removal from all marketing lists.

Please note that opting out of marketing communications does not affect transactional communications — such as deposit confirmations, withdrawal notifications, security alerts, and account verification messages — which are sent as part of the essential operation of your account.

13 Changes to This Policy

44pak reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Where changes are material, 44pak will notify registered players via email or an in-platform notification at least seven (7) days before the updated policy takes effect.

The "Last Updated" date displayed at the top of this page reflects the date of the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how 44pak protects your personal data.

Your continued use of the 44pak Platform following the effective date of any amendment to this Privacy Policy constitutes your acknowledgement of the revised policy. If you do not agree with the revised policy, you should cease using the Platform and may request account closure in accordance with our Terms & Conditions.

14 Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise any of your privacy rights, or have a concern about how 44pak has handled your personal data, please contact our Data Protection team in the first instance. Our support contact email is displayed as plain text in the footer of every page on the 44pak Platform.

When submitting a privacy-related request or complaint, please include the following information to help us respond promptly:

• Your full name and registered 44pak username.
• Your registered email address or mobile number.
• A clear description of your request or complaint and the specific data it relates to.
• The right you wish to exercise, if applicable (e.g., access, erasure, rectification).

44pak will acknowledge your request within 48 hours and will aim to resolve it within 30 calendar days. Where a request is complex or involves a large volume of data, we may extend this period by up to an additional 60 days, in which case we will notify you of the extension and the reason for it.