ch444 Privacy Policy

Introduction

This Privacy Policy ("Policy") describes how ch444 ("ch444", "we", "us", "our"), the operator of the online betting and gaming platform accessible at ch444.cam and any associated subdomains or mobile interfaces (collectively, "the Platform"), collects, processes, stores and protects the personal data of individuals who use, register on or interact with the Platform ("Users", "you", "your").

This Policy applies to all Users globally, including users accessing the Platform from Pakistan. ch444 processes personal data in accordance with the data protection and privacy legislation applicable in its operating jurisdiction. ch444 is not subject to Pakistani data protection law as an overseas operator, but we recognise that our Pakistani users have reasonable expectations of privacy, and we endeavour to meet those expectations through sound data management practices.

By creating an Account or using the Platform in any capacity, you acknowledge that you have read and understood this Policy and that you consent to the collection, processing and use of your personal data as described herein. If you do not agree with any part of this Policy, you should not use the Platform.

Definitions

The following terms have the meanings set out below throughout this Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, date of birth, national identity number, financial information and device identifiers.
• "Processing" means any operation or set of operations performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure or destruction.
• "Data Controller" means ch444 in its capacity as the entity that determines the purposes and means of processing Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of ch444, under a contractual arrangement and subject to data processing obligations.
• "Consent" means a freely given, specific, informed and unambiguous indication of a User's agreement to the processing of their Personal Data for a stated purpose.
• "Cookie" means a small text file stored on a User's device by the Platform's web server, used to retain session information, preferences and analytics data.
• "KYC" means Know Your Customer verification procedures conducted for identity authentication, anti-money laundering compliance and regulatory purposes.

Data We Collect

ch444 collects the following categories of Personal Data from Users, depending on how you interact with the Platform:

3.1 Registration & Identity Data

Collected when you create an Account:

• Full legal name
• Date of birth (to verify you are 18 years of age or older)
• Email address
• Residential address (including city and country — for Pakistani users, this may include cities such as Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar)
• Phone number (optional unless required for verification)
• Username and hashed password

3.2 Identity Verification (KYC) Data

Collected when you complete identity verification or withdraw funds:

• Copy of government-issued identity document (e.g., Pakistani CNIC, passport or driver's licence)
• Proof of address documentation
• Source-of-funds documentation where required by applicable regulations
• Facial or biometric data where required by the KYC verification provider (collected and processed by the provider under their own privacy notice)

3.3 Financial & Transaction Data

Collected in connection with deposits, withdrawals and betting activity:

• Deposit and withdrawal amounts, dates and method identifiers
• Payment method reference details (for example, mobile wallet account references for Easypaisa or JazzCash, or bank account numbers for HBL, UBL, Meezan Bank or Bank Alfalah) — these are stored only to the extent necessary for transaction processing and regulatory compliance
• Transaction history and account balance records
• Betting history, wager amounts, odds accepted and outcomes

3.4 Technical & Device Data

Collected automatically when you access the Platform:

• IP address and approximate geolocation (country and city level)
• Device type, operating system and browser
• Session identifiers and access timestamps
• Pages visited, clicks, scroll depth and navigation patterns

3.5 Communications Data

Collected when you contact us or interact with support:

• Content of live chat transcripts, support emails and complaint correspondence
• Language preference (English, Urdu or other)
• Records of any responsible gambling requests or self-exclusion instructions

How We Collect Your Data

ch444 collects Personal Data through the following channels and methods:

Legal Basis for Processing

ch444 processes Personal Data on the following legal grounds, in accordance with the data protection law applicable in our operating jurisdiction:

• Contractual necessity: Processing that is required to fulfil our obligations under the Terms and Conditions you agree to when registering an Account, including account management, transaction processing, bet settlement and withdrawal handling.
• Legal obligation: Processing required to comply with applicable anti-money laundering (AML), counter-terrorism financing (CTF), KYC and responsible gambling obligations imposed by our licence conditions and the laws of our operating jurisdiction.
• Legitimate interests: Processing carried out for fraud detection, platform security, service improvement, analytics and the prevention of prohibited conduct, where these interests are not overridden by your fundamental rights.
• Consent: Processing of data for optional features, marketing communications or any data use that is not required for contractual or legal purposes, where you have given specific and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

How We Use Your Data

ch444 uses your Personal Data for the following purposes:

• Account creation and management: Registering your Account, authenticating your login, managing your profile and processing Account closure or suspension requests.
• Transaction processing: Processing deposits, withdrawals, bet placements and bonus credits in PKR and in accordance with the payment method you select.
• Identity and age verification: Confirming that you meet the minimum age requirement (18 years or older) and verifying your identity for KYC compliance purposes.
• Regulatory compliance: Meeting our obligations under the AML, CTF, responsible gambling and data protection requirements of our licence jurisdiction.
• Fraud prevention and security: Detecting and investigating suspicious activity, unauthorised account access and prohibited conduct as described in our Terms and Conditions.
• Customer support: Responding to your enquiries, resolving complaints and providing account assistance in English (and Urdu during PKT business hours).
• Platform improvement: Analysing usage patterns and technical performance data to improve the platform experience, with a particular focus on mobile optimisation for Pakistani users.
• Responsible gambling: Monitoring account activity to identify potentially problematic gambling behaviour and administering self-exclusion, deposit limits and other responsible gambling controls.
• Legal proceedings: Defending, bringing or responding to legal claims, regulatory investigations or law enforcement requests.

Data Sharing & Disclosure

ch444 does not sell your Personal Data to third parties. We may share your Personal Data with the following categories of recipients only where necessary and for specified purposes:

• Payment processors and financial service providers: To process deposits and withdrawals through the payment methods available in the cashier. Payment providers handle your financial data under their own privacy policies and data security obligations.
• KYC and identity verification providers: Third-party services engaged to verify your identity, age and address as part of our regulatory compliance obligations. These providers process data on our behalf under data processing agreements.
• Game and platform technology suppliers: Software providers whose games and platform components are integrated into ch444 may receive limited technical data (such as session tokens and game outcomes) as operationally required. Personal identity data is not shared with game suppliers without specific justification.
• Fraud detection and security services: Third-party providers engaged to identify suspicious account activity, bot behaviour or attempted fraud on the Platform.
• Legal and regulatory authorities: Competent authorities, regulators, law enforcement bodies or courts where disclosure is required by law, court order or regulatory mandate. ch444 complies with lawful disclosure obligations while protecting User rights to the extent possible.
• Professional advisers: Legal, accounting or auditing professionals engaged to advise ch444 on its obligations, where disclosure is subject to applicable professional confidentiality obligations.

International Data Transfers

ch444 operates internationally, and your Personal Data may be transferred to, stored and processed in countries other than Pakistan and other than the country in which you reside. This includes the jurisdiction in which ch444 holds its operating licence, as well as the jurisdictions in which our technology providers, KYC partners and payment processors operate their infrastructure.

Where Personal Data is transferred internationally, ch444 takes reasonable steps to ensure that appropriate safeguards are in place, consistent with the data protection standards of our operating jurisdiction. These safeguards may include contractual data protection clauses in agreements with Data Processors and the application of technical security controls equivalent to those applied to data processed within our primary jurisdiction.

By using the ch444 Platform, you acknowledge and consent to the transfer of your Personal Data across international borders for the purposes described in this Policy.

Data Retention

ch444 retains Personal Data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable legal, regulatory or audit obligations. The following general retention principles apply:

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be attributed to an identifiable individual.

Cookies & Tracking Technologies

ch444 uses cookies and similar tracking technologies to operate the Platform, maintain session state, analyse usage and improve the user experience. The following categories of cookies may be used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies, security tokens and load-balancing cookies. They cannot be disabled without impairing Platform functionality.
• Functional Cookies: Used to remember your preferences, language settings and display options between sessions. For example, retaining your preference for English-language navigation.
• Analytics Cookies: Used to collect aggregated, anonymised data about how Users navigate the Platform, which pages are visited most frequently and where technical issues occur. This helps us improve Platform performance, including mobile optimisation for users in Pakistan.
• Session Cookies: Temporary cookies that are deleted when you close your browser, used to maintain your logged-in state during a single session.

You can manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform, including your ability to log in or place bets. ch444 does not use third-party advertising cookies for retargeting purposes.

User Rights

Subject to the data protection law applicable in ch444's operating jurisdiction and any overriding legal obligations (such as AML retention requirements), you may have the following rights with respect to your Personal Data:

To exercise any of the above rights, please contact ch444's support team via Live Chat or by email at the address set out in Section 16. We will acknowledge your request within a reasonable period and respond fully within the timeframe required by applicable law. We may need to verify your identity before fulfilling any data subject request.

Children's Privacy

The ch444 Platform is strictly intended for adults. We do not knowingly collect or process the Personal Data of individuals under the age of eighteen (18), or under the higher minimum age required by the applicable licence jurisdiction.

If we become aware that an Account has been registered by or on behalf of a minor, we will suspend that Account immediately, void any associated bets and return any real-money balance to the source payment method following identity confirmation. Any Personal Data collected in connection with such an Account will be deleted as soon as it is no longer required for the purposes of the investigation and any regulatory reporting obligations.

If you believe that a person under the minimum age has accessed ch444, please contact our support team immediately so we can take appropriate action.

Data Security

ch444 implements a range of technical and organisational security measures to protect Personal Data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include:

• Transport Layer Security (TLS): All data transmitted between your device and the Platform is encrypted using TLS protocols to prevent interception.
• At-rest encryption: Sensitive Personal Data stored in our databases is encrypted using industry-standard encryption algorithms.
• Access controls: Access to Personal Data is restricted to authorised personnel on a need-to-know basis, governed by role-based access control policies.
• Hashed passwords: User passwords are stored as one-way cryptographic hashes and are never accessible in plain text, including to ch444 staff.
• Security monitoring: Platform systems are monitored for anomalous access patterns, intrusion attempts and data breach indicators on an ongoing basis.
• Vendor due diligence: Third-party Data Processors engaged by ch444 are subject to contractual security obligations and, where applicable, regular security assessments.

Despite these measures, no online platform can guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights, ch444 will notify affected Users and relevant regulatory authorities in accordance with applicable breach notification obligations.

Third-Party Links & Services

The ch444 Platform may contain references to payment providers, game categories or other contextual information that involves third-party brands. Where the Platform contains links to third-party websites or services (which ch444 keeps to a minimum), those websites operate under their own independent privacy policies. ch444 is not responsible for the privacy practices, data collection methods or content of any third-party website.

The mention of payment brand names such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah on this Platform is for contextual reference only. Interactions with those providers — including any data they collect when you initiate a payment transaction — are governed by those providers' own privacy policies and terms of service. ch444 receives only the data necessary to confirm transaction completion and to maintain financial records.

Policy Amendments

ch444 reserves the right to amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, regulatory requirements or Platform functionality. Where amendments are material, we will notify Users via a Platform notification or email to the registered address, and the updated Policy will be published with a revised "Last reviewed" date.

Continued use of the Platform following the publication of an amended Policy constitutes acceptance of the revised terms. We encourage Users to review this Policy periodically to remain informed of how their Personal Data is being handled.

Contact Us

If you have any questions about this Privacy Policy, wish to exercise your data subject rights or want to raise a concern about how ch444 handles your Personal Data, please contact us through the following channels:

• Live Chat: Available 24/7 on the Platform. English-language agents are available at all times; Urdu-speaking agents are available during Pakistan Standard Time (PKT) business hours.
• Help Centre: Our searchable knowledge base includes articles on data access requests, account verification and privacy-related topics.
• Email (plain text — not a clickable link): [email protected]

We aim to acknowledge all privacy-related requests promptly and to provide a substantive response within the timeframe required under applicable law. Where a request cannot be fulfilled — for example due to overriding legal retention obligations — we will explain the reason clearly.