Privacy Policy

This Privacy Policy ("Policy") is published by 444p ("we", "us", "our"), the operator of the website accessible at https://444p.cam (the "Platform"). It describes how we collect, use, disclose, retain and protect personal data obtained from individuals ("Users", "you") who access or interact with the Platform.

444p is an independent, English-language information and comparison platform providing guides, odds context, payment education and responsible gambling resources to Pakistani users. We do not operate a sportsbook or casino, and we do not process gambling transactions or hold player funds.

By accessing and using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, please discontinue use of the Platform immediately.

The following definitions apply throughout this Privacy Policy:

For the purposes of this Privacy Policy, 444p is the Data Controller responsible for personal data collected through the Platform. All data collected is processed by or on behalf of 444p in accordance with the purposes set out in this Policy.

Where third-party service providers act as Data Processors on our behalf — for example, analytics providers or infrastructure hosting companies — they do so under contractual obligations that require them to process data only on our instructions and to maintain appropriate security standards.

If you have any questions about how your data is processed, or wish to exercise any of your rights described in this Policy, you may contact us using the details provided in Section 17 (Contact Us) below.

444p collects two categories of data: data you provide voluntarily and data collected automatically when you use the Platform.

4.1 Data You Provide Voluntarily

If you contact 444p through a support channel or email, you may provide:

• Your name or preferred username;
• Your email address;
• The content of your message or enquiry;
• Any additional information you choose to include in your communication.

444p does not operate account registration, login or deposit functionality. We do not collect passwords, payment card data, bank account numbers, National Identity Card (CNIC) numbers or any other sensitive financial or government-issued credentials.

4.2 Data Collected Automatically

When you access the Platform, certain technical and behavioural data is collected automatically, including:

This automatically collected data is processed in aggregate or pseudonymised form wherever possible. We do not use it to build individual behavioural profiles for marketing purposes, and we do not sell it to third parties.

Where applicable data protection law requires a legal basis for processing personal data, 444p relies on the following bases:

• Legitimate Interests: The majority of automatically collected data (device data, usage analytics, IP logging) is processed on the basis of 444p's legitimate interests in operating a secure, functional and improved platform. We have assessed that these interests are not overridden by Users' data protection rights for this category of processing.
• Consent: Non-essential cookies and third-party analytics tools are deployed on the basis of your consent, obtained via our cookie notice on your first visit. You may withdraw consent at any time by adjusting your browser settings.
• Contractual Necessity: Where you contact us with a support request, we process your contact data to the extent necessary to respond to and resolve your enquiry.
• Legal Obligation: We may process and retain certain data where required to do so by Applicable Law, including for fraud prevention, security incident logging or compliance with lawful authority requests.

Personal data collected through the Platform is used for the following purposes:

• Platform Operation: To serve pages, maintain session continuity and ensure the Platform functions correctly across devices commonly used in Pakistan, including mid-range Android handsets on mobile networks;
• Analytics & Improvement: To understand how users navigate the Platform, which content is most accessed and where improvements to structure, readability or coverage are needed;
• Security & Fraud Prevention: To detect, investigate and prevent unauthorised access attempts, abuse and technical attacks against the Platform;
• Support & Communications: To respond to enquiries submitted to [email protected] and to follow up where a support interaction remains unresolved;
• Legal Compliance: To fulfil obligations under Applicable Law, respond to lawful requests from regulatory or law enforcement authorities, and enforce our Terms & Conditions;
• Content Localisation: Aggregate geographic data helps us tailor content relevance for Pakistani users — for example, prioritising PSL cricket coverage, PKR-denomination examples and payment method references familiar to users in Karachi, Lahore, Islamabad, Rawalpindi and other major cities.

We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects on you. We do not use your data for direct marketing, unsolicited email campaigns or targeted advertising without your explicit consent.

444p uses cookies and similar technologies — including local storage and session storage — to support the operation and analysis of the Platform. The categories of cookies we use are described below:

You can manage or disable cookies at any time through your browser's settings. Most modern browsers — including those commonly used on Pakistani Android devices — allow you to block all third-party cookies, clear existing cookies or be notified when a cookie is set. Disabling strictly necessary cookies may impair Platform functionality.

Please note that third-party services integrated into the Platform — such as analytics providers — may set their own cookies subject to their respective privacy policies. 444p does not control the cookies set by third-party services beyond the consent mechanism provided at the point of first visit.

444p does not sell, rent, trade or otherwise transfer your personal data to third parties for their own commercial purposes. We may share data in the following limited circumstances:

• Service Providers & Data Processors: We engage trusted third-party vendors — including hosting providers, content delivery networks and analytics platforms — who process data strictly on our behalf and under contractual data processing agreements. These processors are prohibited from using your data for any purpose other than providing services to 444p.
• Legal & Regulatory Requirements: We may disclose personal data where required to do so by court order, applicable law, or the lawful request of a government or law enforcement authority with jurisdiction over 444p's operations.
• Business Transfers: In the event of a merger, acquisition, asset sale or restructuring of 444p, personal data held by us may be transferred to the acquiring entity as part of that transaction. We would notify affected users of any such transfer and any resulting changes to data processing arrangements.
• Protection of Rights: We may disclose data where necessary to investigate, prevent or take action against illegal activities, suspected fraud, threats to the security of the Platform or violations of our Terms & Conditions.

444p operates as an international platform. Personal data collected from Pakistani users may be transferred to and processed in countries other than Pakistan, including countries where 444p's infrastructure providers or processors are based. Such countries may have data protection regimes that differ from those applicable in Pakistan.

Where personal data is transferred internationally, 444p takes steps to ensure that appropriate safeguards are in place — including contractual clauses with processors and the selection of providers who maintain recognised security certifications — to ensure that your data is afforded a comparable level of protection to that described in this Policy.

Pakistani users should be aware that Pakistan's data protection framework continues to develop. 444p monitors relevant regulatory developments and updates its practices accordingly.

444p retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by Applicable Law. The following general retention periods apply:

• Support & contact communications: Retained for a period of up to 24 months from the date of last interaction, or such longer period as may be required to resolve an ongoing matter;
• Analytics and usage data: Aggregate and pseudonymised analytics data is retained for up to 26 months to support trend analysis and platform improvement;
• Server logs and security data: IP address logs and security event records are retained for up to 12 months for fraud prevention and incident investigation purposes;
• Cookie data: Session cookies are deleted when your browser session ends. Persistent cookies expire according to the duration set at the time of placement, typically between 30 days and 13 months depending on type.

At the end of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with an identifiable individual. We do not retain data beyond what is operationally or legally necessary.

Subject to Applicable Law, you may have the following rights in relation to your personal data held by 444p. You can exercise any of these rights by contacting us using the details in Section 17.

We will respond to all valid requests within 30 days of receipt. Where a request is complex or where multiple requests have been received, we may extend this period by a further two months, in which case we will notify you of the extension and the reason for it. We reserve the right to verify your identity before processing any request relating to personal data.

We do not charge a fee for handling data rights requests unless they are manifestly unfounded, excessive or repetitive, in which case we may charge a reasonable administrative fee or decline to act on the request.

The 444p Platform is intended exclusively for adults aged 18 and above, or the higher minimum age required by the relevant operator or licence jurisdiction. We do not knowingly collect personal data from individuals under the age of 18.

If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete that data from our systems. If you believe that a minor has provided personal data to 444p without appropriate consent, please contact us immediately using the details in Section 17.

Parents and guardians in Pakistan are encouraged to monitor their children's online activity and to use available parental control tools to prevent access to gambling-related content by minors.

The Platform may contain references to or links to third-party websites, operator platforms, payment services or sports organisations. This Privacy Policy applies solely to data collected by 444p through this Platform. It does not govern the data practices of any third party whose service you may access via a link from this Platform.

Third-party websites — including any betting operator platforms you may choose to visit after reading 444p content — are governed by their own privacy policies and terms. We strongly encourage you to review the privacy policy of any external website before providing personal data or engaging with their services.

444p is not responsible for, and makes no representations about, the privacy practices of any third-party service. The inclusion of a link or reference on the Platform does not constitute an endorsement of that third party's data practices.

444p serves a primarily Pakistani user base. We are mindful of the following Pakistan-specific privacy and legal considerations:

• Pakistan Electronic Crimes Act (PECA) 2016: Pakistan's data and cybercrime legislation includes provisions relevant to the unauthorised processing of personal data and online privacy. 444p's data practices are designed to remain consistent with the principles reflected in PECA and emerging Pakistani data protection frameworks.
• No Government Endorsement: 444p does not hold any licence, registration or approval from the Government of Pakistan, the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan (SBP) or any provincial authority. No endorsement of our privacy practices by any Pakistani governmental body is claimed or implied.
• Payment Provider References: References to services such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah within Platform Content are purely contextual and educational. They do not represent data-sharing, integration or commercial arrangements between 444p and any of those providers.
• Local Legal Advice: Pakistani users seeking specific advice on data protection rights under Pakistani law are encouraged to consult a qualified legal professional familiar with Pakistan's evolving data protection regime.

444p implements technical and organisational security measures appropriate to the nature and volume of personal data processed, including:

• Encryption in Transit: All data transmitted between your browser and the Platform is encrypted using TLS (Transport Layer Security) protocols;
• Access Controls: Access to personal data held by 444p is restricted to authorised personnel with a documented operational need, under role-based access control policies;
• Infrastructure Security: Our hosting infrastructure includes firewalls, intrusion detection systems and regular security patching to reduce exposure to known vulnerabilities;
• Pseudonymisation: Where feasible, analytics data is pseudonymised or aggregated so that individual users cannot be directly identified from usage records;
• Incident Response: We maintain documented procedures for identifying, containing and responding to personal data breaches, including notification obligations where required by Applicable Law.

While we take reasonable and industry-standard steps to protect personal data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security and encourage users to take their own precautions — including using up-to-date browsers, secure network connections and appropriate device security — when accessing the Platform.

444p reserves the right to amend this Privacy Policy at any time. Changes may be made to reflect updates to our data processing practices, new legal requirements, changes in the services we use or other operational developments.

When this Policy is updated, the "Last Updated" date at the top of the page will be revised accordingly. Where changes are material — meaning they significantly affect how we process your personal data or your rights in relation to it — we will make reasonable efforts to draw your attention to the changes through a notice on the Platform.

Continued use of the Platform following publication of an amended Privacy Policy constitutes your acceptance of the revised terms. If you do not accept the amended Policy, you must discontinue use of the Platform. We encourage you to review this page periodically to stay informed of how your data is being handled.

If you wish to exercise any of your data rights, have a question about this Privacy Policy, or wish to raise a concern about how 444p handles personal data, please contact us using the details below. All privacy-related correspondence must be submitted in writing in English.

For general platform support enquiries unrelated to privacy or data rights, the same contact address applies. Support is available 24/7 via email, with English as the primary language and Urdu available on select channels.