388won Privacy
Policy

1. Introduction

This Privacy Policy ("Policy") describes how 388won ("388won," "we," "us," "our") collects, processes, stores, shares, and protects personal data relating to registered Players and visitors to the 388won platform accessible at 388won.net ("Platform").

This Policy applies to all personal data we hold about you, regardless of how we collected it — whether through your account registration, use of the Platform's features, communication with our support team, participation in promotions, or your use of payment services integrated into the Platform.

This Policy should be read alongside the 388won Terms and Conditions, which govern your use of the Platform as a whole. Where any conflict arises between this Policy and the Terms and Conditions on a data-related matter, this Policy shall prevail.

2. Data Controller

The data controller responsible for your personal data collected through the 388won Platform is the operating entity behind 388won.net. As the data controller, 388won is responsible for determining the purposes and means by which your personal data is processed.

For all privacy-related enquiries, rights requests, or complaints, you may contact our data team at the contact details set out in Section 14 of this Policy. We aim to acknowledge all data-related correspondence within seventy-two (72) hours and resolve requests within thirty (30) calendar days of receipt.

3. Data We Collect

3.1 Information You Provide Directly

When you register for a 388won account, use the Platform's services, contact our support team, or participate in promotions, you provide us with personal data. This includes, but is not limited to:

• Full legal name as it appears on your government-issued identity document;
• Pakistani mobile telephone number (03xx format) and/or email address;
• Date of birth (for age verification — players must be 21 or older);
• Residential address in Pakistan;
• Copies of identity documents (such as CNIC, passport, or driving licence) submitted for KYC verification;
• Payment method details including mobile wallet numbers (JazzCash, EasyPaisa) and bank account information;
• Correspondence and communications submitted to our support team.

3.2 Information Collected Automatically

When you access the 388won Platform, we automatically collect certain technical information about your device and session, including:

• IP address and approximate geographic location derived from it;
• Device type, operating system, and browser version;
• Pages visited, features used, time spent on each page, and navigation paths;
• Betting and gaming activity data, including wager amounts, game selections, and outcomes;
• Session timestamps and login history;
• Cookie identifiers and similar tracking technologies (see Section 6).

3.3 Information from Third Parties

In certain circumstances, 388won may receive personal data about you from third parties, including:

• Identity verification and KYC service providers used to validate documents and confirm player identities;
• Payment processors (JazzCash, EasyPaisa, Raast, and participating banks) who confirm transaction status;
• Fraud prevention and risk management service providers who share risk signals relevant to account security;
• Publicly available sources where relevant to fulfilling anti-money laundering obligations.

4. How We Use Your Data

388won processes your personal data for the following defined purposes:

We do not use your personal data for any purpose that is incompatible with those listed above without first obtaining your explicit consent or establishing another lawful basis for the new processing activity.

5. Legal Basis for Processing

388won processes personal data only where a lawful basis exists for doing so. The primary legal bases we rely on are:

• Contractual necessity: Processing required to perform our obligations under the Terms and Conditions you entered into on registration — including account management, payment processing, and delivery of gaming services.
• Legal obligation: Processing required to comply with applicable law — including KYC identity verification, anti-money laundering record-keeping, and responsible gaming obligations.
• Legitimate interests: Processing for fraud prevention, platform security, abuse detection, and analytics that are in the legitimate interests of 388won and its Players, where those interests are not overridden by your fundamental privacy rights.
• Consent: Where we rely on consent — such as for marketing communications — we will obtain that consent explicitly and you may withdraw it at any time without affecting other processing activities.

6. Cookies & Tracking Technologies

6.1 What Cookies We Use

The 388won Platform uses cookies and similar tracking technologies to operate correctly and improve your experience. The categories of cookies we deploy include:

• Essential cookies: Required for core Platform functionality including session management, the 388won Login process, and security features such as CSRF protection. These cannot be disabled without breaking core functionality.
• Functional cookies: Remember your preferences such as language settings, lobby display options, and responsible gaming tool settings across sessions.
• Analytics cookies: Used on an anonymised or aggregated basis to understand how Players navigate the Platform, which features are most used, and where performance improvements can be made.
• Security cookies: Help detect and prevent fraudulent activity, bot traffic, and unauthorised account access attempts.

6.2 Managing Cookies

You may manage non-essential cookies through your browser settings. Most modern browsers on Android and iOS — including Chrome and Safari used widely across Pakistan — allow you to view, block, or delete cookies. Note that disabling essential cookies may prevent you from accessing certain features of the 388won Platform, including the 388won Login page.

7. Third-Party Data Sharing

7.1 Categories of Recipients

388won shares personal data with third parties only where necessary and only with parties who are bound by appropriate contractual data protection obligations. The categories of third parties we may share data with include:

• Payment processors: JazzCash, EasyPaisa, Raast, and participating banks receive the minimum data required to process your deposits and withdrawals.
• Identity verification providers: KYC service providers who verify the authenticity of documents you submit during account verification.
• Fraud and risk management providers: Third-party services that help 388won detect and prevent fraudulent activity, collusion, and money laundering.
• IT and hosting infrastructure providers: Providers of server infrastructure, database management, and cloud services that store Platform data under contractual confidentiality obligations.
• Regulatory and legal authorities: Government bodies, law enforcement agencies, or regulatory authorities where disclosure is required by applicable law or a binding court order.

7.2 No Sale of Personal Data

388won does not sell, rent, auction, or otherwise transfer your personal data to any third party for commercial purposes. Sharing described in Section 7.1 is limited to what is operationally necessary and is governed by data processing agreements with each third party.

8. Data Security

388won implements a multi-layered technical and organisational security framework to protect your personal data from unauthorised access, accidental loss, disclosure, alteration, or destruction. Key measures include:

• Transport Layer Security (TLS 1.3): All data transmitted between your device and our servers is encrypted in transit.
• AES-256 encryption at rest: Sensitive stored data, including identity documents and payment information, is encrypted in our databases.
• Bcrypt password hashing: Account passwords are never stored in plaintext. They are hashed using bcrypt with a per-user salt before storage.
• Two-factor authentication (2FA): Available on all 388won accounts. Players are strongly encouraged to enable 2FA via SMS OTP.
• Access controls: Internal access to personal data is restricted to staff with a documented operational need. All access is logged and subject to regular audit.
• 24/7 security monitoring: Our security team monitors systems continuously for anomalous activity, intrusion attempts, and data breach indicators.
• Penetration testing: The Platform undergoes scheduled third-party penetration testing to identify and remediate security vulnerabilities.

While 388won takes every reasonable precaution to protect your data, no online system can guarantee absolute security. In the event of a data breach that creates a material risk to your rights, 388won will notify affected Players in accordance with applicable requirements.

9. Data Retention

388won retains personal data for no longer than is necessary for the purposes for which it was collected, subject to any longer retention periods required by applicable law. Our standard retention schedule is as follows:

Following expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Anonymised data is no longer personal data and may be retained for statistical and analytical purposes without limitation.

10. Your Rights

Subject to applicable law and certain limitations, you have the following rights in relation to your personal data held by 388won:

• Right of access: You may request a copy of the personal data we hold about you and information about how we use it.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data. You can update most account information directly from your 388won account settings.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes collected and no overriding legal obligation requires its retention.
• Right to restrict processing: You may request that we limit the processing of your data in certain circumstances, such as where you contest its accuracy.
• Right to data portability: You may request a machine-readable copy of personal data you provided to us in structured, commonly used format.
• Right to object: You may object to processing based on our legitimate interests, including direct marketing. We will cease processing upon a valid objection unless we have compelling grounds to continue.
• Right to withdraw consent: Where we rely on your consent as the legal basis for processing, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact the 388won data team via live chat or email at [email protected]. We will respond to rights requests within thirty (30) calendar days. We may need to verify your identity before fulfilling a rights request to ensure we are not disclosing data to an unauthorised party.

11. Marketing Communications

388won may send you promotional communications about offers, bonuses, new games, and platform news via SMS to your registered Pakistani mobile number and/or email, where you have provided your consent to receive such communications.

You may withdraw your consent to receive marketing communications at any time by:

• Updating your communication preferences in your 388won account settings;
• Replying STOP to any SMS marketing message from 388won;
• Contacting our support team via live chat and requesting removal from marketing communications.

Withdrawal of marketing consent does not affect your ability to receive essential service communications — such as transaction confirmations, security alerts, account notices, and support responses — which are sent on the basis of contractual necessity rather than consent and cannot be opted out of while your account is active.

12. Children's Privacy

The 388won Platform is strictly intended for individuals aged twenty-one (21) years or older. We do not knowingly collect personal data from individuals under the age of 21.

388won recommends that parents and guardians use device-level parental controls to prevent underage access to online gaming platforms on shared devices.

13. Policy Updates

388won reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform services. The "Last updated" date at the top of this Policy will be revised whenever material changes are made.

Where changes are material — meaning they affect your rights or how your data is used in a significant way — 388won will notify registered Players by email to their registered address and/or via an in-platform notification prior to the changes taking effect. For non-material updates (such as clarifications of existing language), the revised Policy will be published without prior individual notification.

Continued use of the 388won Platform after the effective date of any revised Policy constitutes your acceptance of the updated terms. Players who do not agree with the updated Policy should discontinue use of the Platform and contact support to arrange account closure.

14. Contact & Complaints

For all privacy-related enquiries, data rights requests, or concerns about how 388won handles your personal data, you may reach our team through the following channels:

• Live Chat: Available 24/7 inside your 388won account — average first response under 5 minutes, in Urdu or English
• Email: [email protected] — average response within 24 business hours

If you believe that 388won has not handled your personal data in accordance with this Policy or applicable law, you have the right to lodge a complaint. We encourage you to contact us directly in the first instance so we have the opportunity to address your concern before it is escalated.