Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is issued by 388wni ("we", "us", "our", "the Platform") and applies to all personal data collected from individuals ("you", "your", "User") who access the 388wni website, mobile applications and associated digital services (collectively, the "Platform").

We take privacy seriously. This Policy explains what personal data we collect, why we collect it, how we use and protect it, with whom we may share it, and what rights you have in relation to your data. We encourage you to read this Policy carefully before registering an account or using the Platform.

By accessing or using the Platform, you acknowledge that you have read and understood this Policy. If you do not agree with our data practices, please do not use the Platform.

2. Definitions

The following terms have the meanings assigned to them below when used throughout this Policy:

3. Data Controller Identity

388wni acts as the Data Controller in respect of personal data collected through the Platform. As Data Controller, 388wni determines the purposes for which personal data is collected and the means by which it is processed.

Where 388wni engages third-party service providers to process personal data on its behalf — for example, payment processors, KYC verification providers, or platform infrastructure partners — those parties act as Data Processors under contractual data processing agreements that obligate them to handle data only as instructed by 388wni and to maintain appropriate security standards.

For all data-related enquiries, correction requests, deletion requests or complaints, please use the contact details provided in Section 16 of this Policy.

4. Personal Data We Collect

388wni collects personal data through several channels. The categories of data collected, and the context in which each is collected, are described below.

4.1 Registration Data

When you create an account on the Platform, we collect:

• Full legal name
• Date of birth (to verify you meet the minimum age requirement)
• Email address
• Residential address (including city — e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar)
• Username and password (stored in hashed, non-reversible form)
• Phone number (where provided)

4.2 KYC Verification Data

To comply with identity verification and anti-money laundering obligations, we may collect:

• Copies of government-issued identity documents (e.g., CNIC, passport, driving licence)
• Proof of address documents (e.g., utility bills, bank statements)
• Payment method verification documents
• Source-of-funds documentation where applicable

4.3 Financial Transaction Data

All deposit and withdrawal activities generate transaction records, including:

• Transaction amounts in PKR or currency equivalent
• Payment method type and masked identifier (e.g., masked Easypaisa wallet number, masked bank account last digits)
• Transaction timestamps and reference numbers
• Deposit and withdrawal history

4.4 Usage & Behavioural Data

When you use the Platform, we automatically collect technical and behavioural data including:

• IP address and approximate geographic location
• Device type, operating system and browser version
• Session start and end times, pages visited and features used
• Betting history, wagering patterns and game play records
• Click interactions, search terms entered within the Platform

4.5 Communications Data

Where you contact our support team via Live Chat or email, we retain records of those communications including the content of messages, timestamps and resolution status for quality assurance and dispute management purposes.

5. How We Use Your Personal Data

388wni uses the personal data it collects for the following purposes:

6. Legal Basis for Processing

388wni processes personal data on one or more of the following legal bases:

• Contractual Necessity: Processing is required to perform the contract between you and 388wni — for example, operating your account, processing deposits and paying out withdrawals.
• Legal Obligation: Processing is required to comply with applicable legal and regulatory requirements — including KYC, anti-money laundering, and responsible gambling obligations imposed by the Platform's licensing jurisdiction.
• Legitimate Interest: Processing is necessary for 388wni's legitimate interests, including fraud prevention, platform security, responsible gambling monitoring and service improvement, where those interests are not overridden by your data protection rights.
• Consent: For certain processing activities — such as sending marketing or promotional emails — we rely on your explicit consent, which you may withdraw at any time by contacting support or updating your account communications preferences.

7. Data Sharing & Third-Party Disclosure

388wni does not sell, rent or trade your personal data. We may share personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate contractual safeguards:

• KYC & Identity Verification Providers: Third-party services used to verify identity documents and confirm age eligibility.
• Payment Processing Partners: Financial service providers involved in processing deposits and withdrawals. These partners receive only the data necessary to complete the specific transaction.
• Platform Infrastructure Providers: Cloud hosting, database management and security services that support the operation of the 388wni Platform under data processing agreements.
• Fraud Prevention & Security Services: Providers that assist in detecting and preventing fraudulent activity, account compromise and bonus abuse.
• Regulatory Authorities: Where required by the Platform's licensing jurisdiction, applicable law, court order or lawful regulatory request, 388wni may disclose personal data to competent authorities.
• Legal Advisors: In connection with the establishment, exercise or defence of legal claims, personal data may be shared with legal counsel under professional confidentiality obligations.

All third-party service providers acting as Data Processors are contractually required to process personal data only in accordance with 388wni's instructions, to maintain appropriate security measures, and to delete or return data upon termination of the service relationship.

8. International Data Transfers

388wni operates internationally. Your personal data may be transferred to, stored in, and processed in countries other than Pakistan, including the jurisdiction(s) in which 388wni holds its operating licence and where its infrastructure partners are based.

Where personal data is transferred internationally, 388wni takes steps to ensure that appropriate safeguards are in place — including contractual data transfer mechanisms, data processing agreements and, where applicable, adequacy determinations — to ensure that your data receives a level of protection consistent with this Policy.

By using the Platform, you acknowledge and accept that your personal data may be processed outside Pakistan as described in this section.

9. Data Retention

388wni retains personal data for as long as is necessary for the purposes set out in this Policy, subject to the following principles:

• Active Accounts: Personal data associated with active accounts is retained for the duration of the account relationship plus any additional period required by applicable legal, regulatory or AML obligations.
• Closed Accounts: Following account closure, personal data — including KYC documents, transaction records and communications history — is typically retained for a minimum of five (5) years in order to satisfy anti-money laundering regulatory requirements and to support dispute resolution. Specific retention periods may vary depending on the licensing jurisdiction's requirements.
• Self-Excluded Users: Where a User has self-excluded, account data sufficient to enforce the exclusion is retained for the duration of the exclusion period and any cooling-off period thereafter.
• Marketing Data: Where you have opted into marketing communications, we retain your email address and preferences until you withdraw consent or request erasure.

Once the applicable retention period has expired and there is no longer a legitimate legal or business reason to hold the data, 388wni will securely delete or irreversibly anonymise the personal data in question.

10. Cookies & Tracking Technologies

388wni uses cookies and similar technologies to operate and improve the Platform. The categories of cookies used are described below:

You can control cookie preferences through your browser settings. Disabling essential cookies will prevent the Platform from functioning correctly. For analytics and functional cookies, you may manage preferences through the cookie consent interface presented when you first access the Platform.

11. Your Data Rights

Subject to applicable law and any overriding legal obligations (including KYC and AML retention requirements), you have the following rights in relation to your personal data held by 388wni:

12. Security Measures

388wni implements and maintains a range of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration or destruction:

• Encryption in Transit: All data transmitted between your device and the 388wni Platform is encrypted using TLS (Transport Layer Security).
• Encryption at Rest: Sensitive personal data, including identity document copies and financial records, is stored using encryption at rest.
• Password Security: Passwords are stored in hashed, salted, non-reversible form. 388wni staff do not have access to your password in plaintext.
• Access Controls: Internal access to personal data is restricted on a role-based, least-privilege basis. Staff with access to personal data are subject to confidentiality obligations.
• Security Reviews: 388wni conducts periodic security assessments and monitors systems for suspicious activity and potential breaches.
• Incident Response: In the event of a personal data breach that poses a risk to User rights, 388wni will notify affected users and relevant authorities in accordance with applicable law.

No system is completely immune to security risks. While we take all reasonable measures, we cannot guarantee absolute security. You are also responsible for maintaining the security of your account credentials and for notifying us promptly of any suspected unauthorised access.

13. Children's Privacy

The 388wni Platform is strictly for adults aged 18 and over, or the higher minimum age required by the operator's licensing jurisdiction. We do not knowingly collect personal data from individuals under the minimum age requirement.

If we become aware that personal data has been collected from an underage individual, we will immediately suspend the associated account, void any wagers placed and initiate the deletion of all data associated with that account (subject to any mandatory legal reporting obligations).

If you are a parent or guardian and believe your child has accessed or registered on the Platform, please contact us immediately through the channels listed in Section 16.

14. Third-Party Links & Services

The 388wni Platform may contain references to, or integration with, third-party services (such as game providers or payment method providers). This Privacy Policy applies only to personal data collected and processed by 388wni directly.

Third-party services — including game studios, payment processors and KYC providers — operate under their own privacy policies. 388wni is not responsible for the data practices of third-party services beyond the contractual data processing agreements that govern our service provider relationships.

We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of the Platform.

15. Amendments to This Policy

388wni reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations or Platform features. Where changes are material, we will provide reasonable notice through the Platform — for example, via an in-account notification or a prominent banner — and will update the "Last Updated" date at the top of this page.

Your continued use of the Platform following any amendment constitutes your acknowledgement of the updated Policy. If you do not agree with the revised Policy, you should cease using the Platform and may request account closure as described in our Terms & Conditions.

16. Contact Us

For all data protection enquiries, access requests, correction requests, erasure requests or privacy-related complaints, please contact the 388wni data team through the following channels:

• Live Chat: Available within the Platform, 24 hours a day, 7 days a week — the fastest channel for urgent data queries.
• Help Centre: Self-service articles on account data management, cookie preferences and data rights are available in the Platform's Help Centre.
• Support Email: [email protected] — plain text only. Do not click. Copy and paste into your email client if needed.

We will acknowledge all data-related requests within a reasonable timeframe and respond fully within the period required by applicable law. For complex requests, we may need to verify your identity before processing. We will not charge a fee for reasonable requests but reserve the right to charge a reasonable fee for manifestly unfounded, excessive or repetitive requests.