How We Protect Your Privacy
Six core commitments that define how 388won handles your personal data.
All personal data collected by 388won is stored on encrypted servers using industry-standard AES-256 encryption. Access is restricted to authorised personnel only, with full audit logging of any data access events.
You have the right to access, correct, restrict, port and request deletion of your personal data. Requests are handled via [email protected] and acknowledged within five working days, subject to identity verification.
388won does not sell your personal data to third parties. Data is shared only with trusted service providers bound by confidentiality agreements, or where required by applicable law or regulatory obligation.
We provide a full breakdown of every cookie category used on the Platform — essential, analytics, functional and marketing. You can manage your cookie preferences at any time through the cookie settings panel in your account.
Identity documents submitted for KYC verification (such as your CNIC or passport) are processed solely for age and identity verification purposes. They are not shared with advertisers and are retained only for as long as legally required.
You can opt out of marketing communications at any time — via your account notification settings, by clicking the unsubscribe link in any email, or by writing to [email protected]. Transactional and security messages cannot be opted out of while your account remains active.
This Privacy Policy ("Policy") describes how the operator of the 388won platform ("388won", "we", "us", "our") collects, processes, stores and discloses personal data relating to individuals ("User", "you", "your") who access or use the 388won website at https://388won.cam, its mobile interface and all associated services (collectively, the "Platform").
This Policy forms part of the broader legal framework governing your use of 388won, alongside our Terms & Conditions. By creating an account or continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.
The following defined terms apply throughout this Policy:
| Term | Meaning |
|---|---|
| Personal Data | Any information that identifies or can reasonably identify a living individual, directly or indirectly — including name, email address, device identifiers and financial data. |
| Processing | Any operation performed on personal data — including collection, storage, retrieval, use, disclosure, erasure or destruction. |
| Data Controller | The entity that determines the purposes and means of processing personal data. For this Platform, the Data Controller is the 388won operator. |
| Data Processor | A third party that processes personal data on behalf of the Data Controller under a written agreement, such as a payment gateway or KYC verification provider. |
| Consent | A freely given, specific, informed and unambiguous indication of agreement to the processing of personal data for a stated purpose. |
| KYC | Know Your Customer — the mandatory identity and age verification process applied before withdrawals and certain account actions. |
| Cookie | A small text file placed on a User's device by the Platform for purposes of session management, analytics, functionality or marketing. |
388won collects personal data through several channels: directly from you when you register and use the Platform, automatically when you browse the Platform, and from trusted third parties such as KYC and payment service providers. The categories of data collected are set out below.
3.1 Registration Data
- Full legal name as it appears on your identity document.
- Date of birth (for age verification).
- Residential address, including city (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar).
- Email address.
- Mobile phone number.
- Username and hashed password (passwords are never stored in plain text).
- Preferred currency (PKR by default for Pakistani users).
3.2 Identity Verification (KYC) Data
- Scanned copies or photographs of government-issued identity documents (e.g., CNIC, passport, driving licence).
- Proof of address documents (e.g., utility bill, bank statement).
- Selfie or liveness verification images where required.
- Source-of-funds documentation for high-value accounts.
3.3 Financial Data
- Payment method identifiers (e.g., masked card numbers, mobile wallet identifiers for Easypaisa or JazzCash account references).
- Transaction history including deposits, withdrawals, wagers and bonus activity — all recorded in PKR.
- Bank account references where bank transfer is used (e.g., HBL, UBL, Meezan Bank, Bank Alfalah, Raast).
Note: Payment provider names listed above are familiar Pakistani payment references. Their mention does not imply endorsement of gambling by any of those institutions.
3.4 Technical & Usage Data
- IP address and approximate geolocation derived from IP.
- Device type, operating system and browser information.
- Session data including login timestamps, pages visited, features used and bet history.
- Cookies and similar tracking technologies (see Section 8).
3.5 Communications Data
- Records of your communications with our support team, including live chat transcripts and email correspondence.
- Responses to surveys or promotional communications where you have opted in.
- Responsible-gambling tool selections and self-exclusion requests.
388won processes your personal data under one or more of the following legal bases, depending on the purpose of processing:
- Contractual Necessity: Processing required to perform our contract with you — including account creation, payment processing, bet settlement and withdrawal fulfilment.
- Legal Obligation: Processing required to comply with applicable laws, such as anti-money-laundering obligations, record-keeping requirements and responses to lawful law-enforcement requests.
- Legitimate Interests: Processing necessary for the legitimate business interests of 388won, such as fraud detection, security monitoring, product improvement and responsible-gambling compliance — provided those interests are not overridden by your rights.
- Consent: Processing based on your freely given consent, such as sending promotional emails and placing non-essential cookies. You may withdraw consent at any time without affecting prior processing.
Personal data collected by 388won is used exclusively for the purposes described below. We do not use your data for any purpose incompatible with those originally stated at the time of collection.
| Purpose | Details |
|---|---|
| Account Management | Creating, maintaining and securing your 388won account; enabling login and account recovery. |
| Age & Identity Verification | Confirming you meet the 18+ minimum age requirement and that your identity matches your payment methods and submitted documents. |
| Payment Processing | Facilitating deposits and withdrawals; detecting and preventing payment fraud; maintaining transaction records in PKR. |
| Platform Delivery | Providing sports betting, live casino, slots and other gaming services; personalising the Platform experience. |
| Security & Fraud Prevention | Detecting duplicate accounts, bonus abuse, money laundering, match fixing and other prohibited conduct outlined in the Terms & Conditions. |
| Responsible Gambling | Monitoring for indicators of problem gambling; applying deposit limits, loss limits, cooling-off periods and self-exclusion as requested or required. |
| Customer Support | Responding to queries, complaints and responsible-gambling requests submitted via [email protected] or live chat. |
| Legal Compliance | Fulfilling regulatory, AML, tax and law-enforcement obligations; retaining records for the periods required by applicable law. |
| Marketing (with consent) | Sending promotional emails, SMS or push notifications about bonuses, PSL or ICC tournament promotions, and new features — only where you have opted in. |
| Analytics & Improvement | Analysing aggregated usage patterns to improve Platform performance, user experience and game offerings. |
388won does not sell, rent or trade your personal data. Data is shared only in the circumstances described below, and only to the minimum extent necessary for the stated purpose.
6.1 Service Providers (Data Processors)
We engage trusted third-party service providers to support Platform operations, including KYC verification providers, payment processors, fraud-detection platforms, cloud hosting providers, customer support software vendors and analytics platforms. All processors are contractually bound to process data only on our instructions and to maintain appropriate security standards.
6.2 Legal & Regulatory Disclosure
We may disclose your personal data to law-enforcement authorities, courts, regulators or government bodies where required by a valid legal order, judicial process or regulatory obligation. Where permitted by law, we will notify you of such disclosure.
6.3 Business Transfers
In the event of a merger, acquisition, sale of assets or restructuring of the 388won operator, your personal data may be transferred to the successor entity. You will be notified in advance of any such transfer and your rights under this Policy will be preserved.
6.4 Anti-Money-Laundering Networks
Where required by applicable AML obligations, certain transactional data and identity information may be shared with licensed financial intelligence bodies or shared AML screening databases.
We retain your personal data only for as long as necessary to fulfil the purposes described in this Policy, or for as long as required by applicable law — whichever is longer. The table below provides indicative retention periods by data category:
| Data Category | Retention Period | Basis |
|---|---|---|
| Account Registration Data | Duration of account + 5 years post-closure | Legal obligation / AML compliance |
| KYC & Identity Documents | Duration of account + 5 years post-closure | Regulatory requirement |
| Financial Transaction Records | Duration of account + 7 years post-closure | AML / tax record-keeping |
| Betting & Gaming History | Duration of account + 3 years post-closure | Legitimate interest / dispute resolution |
| Support Communications | 3 years from last interaction | Legitimate interest / legal defence |
| Marketing Consent Records | Until consent is withdrawn + 1 year | Proof of consent |
| Technical & Log Data | 13 months on a rolling basis | Security / fraud detection |
| Cookie Data (non-essential) | As specified per cookie (typically 30 days – 2 years) | Consent |
Upon expiry of the applicable retention period, data is securely deleted or anonymised so that it can no longer be associated with any individual. Anonymised aggregate data may be retained indefinitely for statistical purposes.
388won uses cookies and similar technologies (including local storage, session storage and pixel tags) to operate the Platform, understand how Users interact with it, and — where you have consented — to deliver personalised marketing. The four categories of cookies we deploy are described below.
| Category | Purpose | Can Be Disabled? |
|---|---|---|
| Session management, authentication tokens, CSRF protection and load-balancing. Required for the Platform to function. These cannot be disabled while you use the site. | No | |
| Aggregate usage statistics (page views, session duration, navigation paths). Help us understand how Users across Karachi, Lahore, Islamabad and other cities interact with the Platform so we can improve it. | Yes (via cookie settings) | |
| Remembering your language preference, currency display (PKR), odds format, time zone (PKT/UTC+5) and other personal display settings. | Yes (may affect experience) | |
| Tracking engagement with promotional campaigns and personalising offers (e.g., PSL season bonuses, T20 tournament promotions). Only placed with your prior consent. | Yes (consent-based) |
You can review and update your cookie preferences at any time through the cookie settings panel available in your account profile. Note that disabling analytics or functional cookies may affect Platform performance or personalisation features. Disabling essential cookies will prevent the Platform from operating.
388won implements a layered security architecture to protect your personal data against unauthorised access, accidental loss, alteration and destruction. Key security measures include:
- Encryption in Transit: All data transmitted between your device and the Platform is protected by TLS 1.2 or higher (HTTPS). Never use the Platform over an unsecured public Wi-Fi network without a trusted VPN.
- Encryption at Rest: Stored personal data and financial records are encrypted using AES-256 on our hosting infrastructure.
- Access Controls: Access to personal data is restricted on a strict need-to-know basis. Staff with data access are subject to background screening and confidentiality obligations.
- Two-Factor Authentication: 2FA is available for all user accounts and is strongly recommended. Internal administrative systems require 2FA by default.
- Penetration Testing: The Platform undergoes periodic independent security audits and penetration tests to identify and remediate vulnerabilities.
- Incident Response: In the event of a personal data breach that creates a risk to Users, 388won will notify affected users without undue delay and take all reasonable steps to contain and investigate the breach.
Subject to applicable law and the terms of this Policy, you hold the following rights with respect to your personal data held by 388won. To exercise any of these rights, submit a written request to [email protected] with your registered email address and a brief description of your request. We will verify your identity before processing any rights request.
| Right | What It Means |
|---|---|
| Right of Access | Request a copy of the personal data 388won holds about you, along with information about how it is processed. |
| Right to Rectification | Request correction of any inaccurate or incomplete personal data held on your account. |
| Right to Erasure | Request deletion of your personal data where it is no longer necessary for the purposes collected, or where you withdraw consent and no other legal basis applies. Note: data subject to mandatory regulatory retention periods cannot be erased until those periods expire. |
| Right to Restriction | Request that processing of your data be restricted in certain circumstances — for example, while the accuracy of data is disputed. |
| Right to Data Portability | Receive a copy of data you provided to us in a structured, commonly used machine-readable format, where processing is based on consent or contract. |
| Right to Object | Object to processing based on legitimate interests, including profiling for marketing. You have an absolute right to object to direct marketing at any time. |
| Right to Withdraw Consent | Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of prior processing. |
We aim to respond to all rights requests within 30 calendar days. Where a request is complex or involves a high volume of data, this period may be extended by a further 60 days, with notification provided to you within the initial 30-day window.
The 388won Platform is strictly for adults aged 18 years or older, or the higher minimum age required by the operator's licensing jurisdiction. We do not knowingly collect personal data from individuals under the age of 18.
Where 388won identifies or reasonably suspects that personal data has been provided by a person under the minimum age, the relevant account will be immediately suspended, all data will be securely deleted and any funds will be returned via the original deposit method following verification. If you believe that a minor has registered on the Platform, please contact [email protected] immediately.
To deliver the Platform and its associated services, your personal data may be transferred to and processed in countries outside your country of residence. Where such transfers occur, 388won ensures that appropriate safeguards are in place to protect your data — including contractual clauses that require recipients to maintain data protection standards equivalent to those described in this Policy.
Users in Pakistan should be aware that Pakistan currently does not have a comprehensive data protection law equivalent to GDPR. Notwithstanding this, 388won applies consistent data protection standards to all Users regardless of location, and processes data only for the legitimate purposes described in this Policy.
388won reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, business practices or Platform functionality. When material changes are made, we will notify you via email to your registered address and/or by displaying a prominent notice on the Platform at least 14 days before the changes take effect.
Your continued use of the Platform after the effective date of any updated Policy constitutes your acceptance of the revised terms. If you do not agree with the updated Policy, you must cease using the Platform and may request account closure by contacting [email protected].
Previous versions of this Policy are archived and available on request. The "Effective Date" at the top of this document always reflects the date on which the current version came into force.
If you have any questions about this Privacy Policy, wish to exercise your data rights, or want to raise a concern about how 388won handles your personal data, please contact us using the details below. All privacy-related correspondence must be submitted in writing.
Data Controller Contact Details
- Platform: 388won (https://388won.cam)
- Privacy & Data Requests: [email protected]
- Support Hours: 24 hours a day, 7 days a week
- Response Language: English (Urdu available on request)
- Time Zone: PKT (UTC+5)
Please include your registered email address and a clear description of your request or concern in all correspondence. We may ask you to verify your identity before processing any data-related request. We aim to acknowledge all privacy queries within 5 working days and resolve them within 30 calendar days.
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