388wen Privacy Policy

§1 Introduction

388wen ("we", "us", "our") operates the online sports betting and casino platform accessible at 388wen.vip. This Privacy Policy sets out how we collect, use, store, share, and protect the personal information of all users who register accounts, place bets, play casino games, or otherwise interact with the 388wen Platform.

This Policy applies to all users of the Platform, with particular relevance to users accessing 388wen from Pakistan. By registering an Account or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

If you do not agree with any part of this Policy, you should not use the Platform. You may contact our support team at any time to discuss privacy-related concerns before or after registration.

§2 Data Controller

For the purposes of applicable data protection law, the data controller responsible for your personal information is the legal entity operating the 388wen Platform under its international gaming licence. As the data controller, 388wen determines the purposes and means by which your personal data is processed.

Correspondence regarding data protection matters should be directed to our Data Protection Officer via the contact details provided in Section 15 of this Policy. We will acknowledge all formal data protection enquiries within five business days.

§3 Personal Data We Collect

388wen collects the following categories of personal data from users. The specific data collected will depend on how you interact with the Platform:

3.1 Identity & Contact Data

• Full legal name (as it appears on your CNIC or passport)
• Date of birth (used to verify the 21+ age requirement)
• Residential address in Pakistan (city, province, postal code)
• Email address (used for account management and communications)
• Mobile number registered to your JazzCash or EasyPaisa wallet, or your standard Pakistani mobile number

3.2 Verification & KYC Documents

• Scanned copy or photograph of your National Identity Card (CNIC) or valid passport
• Proof of address document (utility bill, bank statement, or similar, dated within three months)
• Payment method verification — for example, a screenshot of your JazzCash or EasyPaisa app showing the account registered in your name, or a bank card image showing only the last four digits

3.3 Financial & Transaction Data

• Deposit and withdrawal history, including amounts in PKR and timestamps
• Payment method identifiers (wallet IDs, masked card numbers — never full card numbers)
• Bonus and promotional credit history
• Balance snapshots where required for regulatory reporting

3.4 Betting & Gaming Activity

• Bet history: markets wagered on, odds accepted, stake amounts, and outcomes
• Casino session data: games played, session duration, spin/hand history, and win/loss records
• Responsible gaming tool usage: deposit limit settings, cooling-off activations, and self-exclusion requests

3.5 Technical & Device Data

• IP address at the time of registration and each login session
• Device type, operating system, and browser version
• Geolocation data (city-level, derived from IP — not GPS)
• Cookies and session identifiers (see Section 9)
• Access logs including page visits, click paths, and error events

3.6 Communications Data

• Live chat transcripts between you and our support team
• Email correspondence sent to or received from [email protected]
• Complaint and dispute records

§4 How We Collect Your Data

388wen collects personal data through the following channels:

• Directly from you: When you complete the registration form, submit KYC documents, make a deposit or withdrawal request, use the live chat, or contact us by email.
• Automatically: When you browse or interact with the Platform, our servers and analytics tools automatically record technical and device data as described in Section 3.5.
• From payment processors: When you deposit or withdraw funds, our authorised payment partners (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa/Mastercard processors, and USDT gateway providers) share transaction confirmation data with us.
• From fraud prevention partners: We may receive risk-scoring data from third-party fraud detection services that process device fingerprint data on our behalf under strict data processing agreements.
• From regulatory authorities: In limited circumstances, regulatory bodies or law enforcement may share information with us that relates to an account under investigation.

§5 Purpose & Legal Basis for Processing

The table below sets out each purpose for which 388wen processes your personal data and the corresponding legal basis under applicable data protection principles:

§6 Data Sharing & Third Parties

388wen does not sell, rent, or trade your personal data. We share your data only in the limited circumstances described below, and only with parties bound by appropriate data processing agreements or legal obligations:

6.1 Payment Processors

To execute PKR deposits and withdrawals, we share necessary identity and transaction data with our authorised payment partners including JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa/Mastercard acquiring banks, and our USDT gateway provider. These parties process your data solely to execute the payment instruction and are contractually prohibited from using your data for any other purpose.

6.2 Fraud Prevention & KYC Services

We use regulated third-party services to assist with identity verification and fraud detection. These providers process data on our behalf as data processors under strict contractual terms and are not permitted to use your data independently.

6.3 Game Providers

For casino games and slots provided by third-party studios, your anonymised session data (stake amounts, game outcomes) is shared with the relevant game provider for the purpose of game integrity and RTP verification. Your personal identity is not disclosed to game providers.

6.4 Regulatory & Legal Disclosure

388wen may disclose your personal data to its licensing authority, financial intelligence units, or law enforcement agencies where required to do so by applicable law, court order, or regulatory direction. We will notify you of any such disclosure where legally permitted to do so.

6.5 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of 388wen's assets, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer and of any changes to this Privacy Policy that result from it, at least 30 days in advance.

§7 Data Retention

388wen retains your personal data for as long as necessary to fulfil the purposes described in this Policy, subject to the following minimum retention periods required by our regulatory obligations:

At the end of the applicable retention period, your data is securely deleted or anonymised such that it can no longer be linked to you as an individual. Anonymised, aggregated data may be retained indefinitely for statistical and analytical purposes.

§8 Security Measures

388wen employs industry-standard technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. Our security programme includes:

• Encryption at rest: All personal data stored in our databases is encrypted using AES-256 encryption. Encryption keys are managed through a dedicated key management service with strict access controls.
• Encryption in transit: All data transmitted between your device and 388wen servers is protected using TLS 1.3. HTTPS is enforced across all Platform pages with HTTP Strict Transport Security (HSTS) headers.
• Access controls: Access to personal data within 388wen is granted on a strict need-to-know basis. All staff with access to production data undergo background checks and regular data protection training.
• Penetration testing: Our Platform undergoes third-party security penetration testing at least once per calendar year, with additional testing following significant infrastructure changes.
• Two-factor authentication: All internal staff accounts with access to user data are protected by mandatory two-factor authentication. We strongly encourage users to enable 2FA on their own 388wen accounts.
• Intrusion detection: Real-time monitoring systems alert our security team to abnormal access patterns, failed authentication attempts, and potential account takeover activity.

§9 Cookies & Tracking Technologies

388wen uses cookies and similar browser storage technologies to operate the Platform, maintain your session, prevent fraud, and improve your user experience. The following categories of cookies are used:

9.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function and cannot be disabled. They include session tokens that keep you logged in while you navigate, CSRF protection tokens that prevent cross-site request forgery attacks, and load balancer cookies that route your requests to the correct server. No personal data beyond a session identifier is stored in these cookies.

9.2 Performance & Analytics Cookies

We use first-party analytics tools to understand how users interact with the Platform — which pages are visited most frequently, where users encounter errors, and how navigation flows can be improved. This data is aggregated and does not identify you personally. You may opt out of performance cookies via the cookie preference centre without affecting Platform functionality.

9.3 Fraud Detection Cookies

Our fraud prevention systems use cookies and device fingerprinting technology to identify suspicious patterns — for example, multiple accounts registered from the same device. This processing is carried out in our legitimate interest and that of our users to maintain a fair and secure Platform.

9.4 Preference Cookies

These cookies remember your preferences such as your selected language, odds format, and display settings, so you do not have to reconfigure them on each visit. Preference cookies are optional and can be cleared through your browser settings at any time.

§10 Your Data Rights

As a user of 388wen, you hold the following rights in relation to your personal data. To exercise any of these rights, contact our Data Protection Officer via live chat or at [email protected] with the subject line "Data Rights Request":

• Right of Access: You may request a copy of all personal data 388wen holds about you. We will provide this in a structured, commonly used, machine-readable format (JSON or CSV) within 30 days of your verified request.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request correction. Basic details such as address and phone number can be updated directly from your Account Settings page.
• Right to Erasure ("Right to Be Forgotten"): You may request deletion of your personal data. Note that certain data must be retained for regulatory compliance (see Section 7) and cannot be erased before the applicable retention period has elapsed. We will explain any applicable restrictions when responding to your request.
• Right to Restrict Processing: You may request that we restrict processing of your data — for example, while a rectification request is being assessed. Restricted data will not be deleted but will not be actively used.
• Right to Data Portability: You may request that we transfer your personal data to another service provider in a structured, machine-readable format, where technically feasible.
• Right to Object: You may object to processing based on legitimate interest (such as certain fraud prevention activities or direct marketing). We will assess your objection and discontinue processing unless compelling legitimate grounds exist that override your rights.
• Right to Withdraw Consent: Where processing is based on your consent (for example, marketing emails), you may withdraw that consent at any time without affecting the lawfulness of prior processing. Use the unsubscribe link in any marketing email or update preferences in your Account Settings.

§11 Minors & Age Policy

The 388wen Platform is strictly for users aged 21 and above. We do not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory step during registration and before any withdrawal is processed.

If 388wen becomes aware that personal data has been collected from a user who is under 21 years of age, we will immediately suspend that account, delete the associated personal data to the extent not required for regulatory reporting of the underage access incident, and, where appropriate, report the matter to the relevant regulatory authority.

§12 International Data Transfers

388wen's primary data infrastructure is hosted in data centres that operate under internationally recognised security standards. In the course of providing payment processing, fraud prevention, and game delivery services, your data may be transferred to and processed in jurisdictions outside of Pakistan.

Where such international transfers occur, 388wen ensures that appropriate safeguards are in place, including contractual data processing agreements that impose data protection standards equivalent to those described in this Policy. We do not transfer personal data to jurisdictions that do not provide an adequate level of data protection without ensuring these additional safeguards are in place.

§13 Marketing Communications

388wen will only send you promotional communications — including bonus offers, PSL cricket betting promotions, slot tournaments, and platform news — if you have opted in to receive them at the time of registration or subsequently updated your preferences in Account Settings.

We send marketing communications via email and, where you have provided consent, via SMS to your registered Pakistani mobile number. We do not make unsolicited phone calls or send communications through third-party messaging platforms.

You can unsubscribe from marketing communications at any time by clicking the unsubscribe link in any email we send, updating your notification preferences in Account Settings, or contacting support at [email protected]. Opting out of marketing will not affect transactional communications such as deposit confirmations, withdrawal notifications, or important account security alerts.

§14 Changes to This Privacy Policy

388wen may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or Platform features. When we make material changes — those that significantly affect your rights or how your data is used — we will notify you by email to your registered address at least 14 days before the changes take effect.

For minor updates (such as clarifications or formatting changes that do not affect substance), we will update the "Last Updated" date at the top of this Policy without individual notification. We encourage you to review this Policy periodically. Continued use of the Platform after the effective date of any update constitutes acceptance of the revised Policy.

Previous versions of this Privacy Policy are available upon request from our Data Protection Officer.

§15 Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise a data right, or want to raise a privacy concern, please contact us through the following channels:

• Live Chat: Available 24/7 directly on the Platform — fastest response channel
• Email: [email protected] — use subject line "Privacy Enquiry" or "Data Rights Request"
• Response Time: Acknowledgement within 5 business days; full response within 30 calendar days

If you are not satisfied with our response to a privacy complaint, you have the right to escalate the matter to the relevant supervisory authority or data protection regulator under the laws applicable in your jurisdiction. We will provide details of the appropriate authority upon request.