Privacy Policy — 388wi

1 Introduction

This Privacy Policy ("Policy") sets out how 388wi ("we", "us", "our", "Platform") collects, processes, stores, shares and protects personal data relating to users ("you", "your", "User") of the 388wi website at https://388wi.cam and all associated services.

388wi is committed to handling personal data with transparency, integrity and respect for applicable privacy principles. We recognise that our users — including those accessing the Platform from major Pakistani cities such as Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar — have a legitimate expectation of privacy and data security when using online platforms.

By registering an Account, accessing the Platform or otherwise providing personal data to 388wi, you acknowledge that you have read and understood this Policy and agree to the processing of your personal data as described herein. If you do not agree with this Policy, you should not access or use the Platform.

2 Definitions

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person — including name, date of birth, national identity number (CNIC), email address, IP address and financial account details.
• "Processing" means any operation or set of operations performed on personal data, including collection, recording, storage, retrieval, use, disclosure, restriction, erasure or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing personal data. 388wi acts as data controller for personal data collected through the Platform.
• "Data Processor" means a third party that processes personal data on behalf of the data controller, pursuant to documented instructions.
• "Cookies" means small text files placed on your device by the Platform to store preference, session and analytics information.
• "KYC" means Know Your Customer identity verification procedures, including age verification, identity document checks, address verification and source-of-funds checks.
• "AML" means anti-money laundering compliance obligations applicable to the operator under its license jurisdiction.
• "Special Category Data" means personal data revealing racial or ethnic origin, political opinions, religious beliefs, health data, biometric data or any other category of sensitive data subject to heightened protection under applicable privacy law.

3 Data We Collect

We collect personal data across several categories, depending on the nature of your interaction with the Platform. The table below summarises the main data categories and examples.

4 How We Collect Personal Data

4.1 Directly from You

We collect personal data directly from you when you: register an Account; complete KYC verification; make a deposit or request a withdrawal; contact our support team; respond to surveys or promotional communications; or configure account settings including responsible gambling tools.

4.2 Automatically through Platform Use

When you access and interact with the Platform, certain technical and usage data is collected automatically through cookies, server logs, analytics tools and similar technologies. This includes your IP address, browser fingerprint, device identifiers and behavioral patterns across the Platform.

4.3 From Third-Party Sources

We may receive personal data from third-party service providers operating on our behalf, including identity verification agencies, payment processors and fraud prevention services. Data received from these sources is used only for the specific purpose for which it was shared and is handled in accordance with this Policy.

4.4 From Payment Providers

When you initiate a transaction, our payment processing partners may share transaction confirmation data with us — including reference numbers and settlement amounts in PKR or other currencies. 388wi does not receive or store full payment card numbers or complete mobile wallet credentials. Payment provider names such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are referenced only as familiar Pakistani payment tools; their privacy practices are governed entirely by their own respective policies.

5 Purposes of Processing & Legal Basis

We process personal data only where we have a lawful basis for doing so. The table below summarises our primary processing purposes and the corresponding legal basis for each.

6 Data Sharing & Disclosure

6.1 When We Share Your Data

388wi does not sell, rent or trade personal data. We share personal data only in the limited circumstances described in this section, and only to the extent necessary for the stated purpose.

6.2 Service Providers and Data Processors

We engage carefully selected third-party service providers who process personal data on our behalf under documented data processing agreements. These include identity verification providers, payment processing partners, fraud prevention and AML screening services, cloud infrastructure providers and customer support platform operators. All data processors are contractually bound to process data only on our documented instructions and to maintain appropriate security standards.

6.3 Regulatory and Legal Disclosure

We may be required to disclose personal data to regulatory authorities, law enforcement agencies, courts or other public authorities where required to do so by applicable law, court order or regulatory directive. This includes disclosures required under anti-money laundering regulations in the operator's license jurisdiction.

6.4 Business Transfers

In the event of a merger, acquisition, restructuring, sale of assets or insolvency proceeding involving 388wi, personal data held on the Platform may be transferred to the acquiring or successor entity as part of that transaction. Users will be notified of any such transfer where required by applicable law.

7 Cookies & Tracking Technologies

7.1 What Are Cookies

Cookies are small text files stored on your device when you visit a website. They enable the site to recognise your device on subsequent visits, retain your preferences and support essential functionality. 388wi uses cookies and similar technologies including web beacons and local storage.

7.2 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function. These enable session management, login authentication and security features. They cannot be disabled without impairing core Platform functionality.
• Performance & Analytics Cookies: Used to understand how users interact with the Platform — pages visited, time on page, navigation paths. This data is aggregated and used to improve Platform performance.
• Preference Cookies: Store your settings such as language preferences and responsible gambling limit configurations.
• Marketing Cookies (where applicable): Used only where you have explicitly opted in. These may track your interaction with promotional content to measure campaign effectiveness.

7.3 Managing Cookies

You can control and delete cookies through your browser settings. Most modern browsers allow you to block third-party cookies while permitting first-party cookies. Please note that disabling essential cookies will prevent core Platform functions from operating correctly. Instructions for managing cookies vary by browser — refer to your browser's help documentation for guidance.

8 Data Retention

We retain personal data for as long as necessary to fulfil the purposes for which it was collected, including to satisfy applicable legal, regulatory, accounting or reporting requirements. The following general retention guidelines apply:

• Account data: Retained for the duration of the active account relationship and for a minimum of five (5) years following account closure, or longer where required by applicable AML or regulatory obligations.
• KYC and identity documents: Retained for a minimum of five (5) years following account closure or the conclusion of any investigation, whichever is later, in compliance with applicable AML record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years following the relevant transaction date.
• Support correspondence: Retained for up to three (3) years following resolution of the relevant support interaction.
• Marketing consent records: Retained for the duration of the consent period and for a reasonable period thereafter as evidence of consent status.

When personal data is no longer required, it is securely deleted or anonymised in accordance with our internal data lifecycle procedures.

9 Data Security

388wi implements a range of technical and organisational security measures to protect personal data against unauthorised access, accidental loss, destruction or alteration. These measures include:

• TLS/HTTPS encryption for all data transmitted between your device and the Platform.
• Encryption of sensitive data at rest, including identity documents and financial records.
• Access controls restricting personal data access to authorised personnel on a need-to-know basis.
• Regular security assessments and vulnerability testing of Platform infrastructure.
• Multi-factor authentication options for user accounts.
• Incident response procedures for managing data breaches, including notification protocols where required by applicable law.

10 International Data Transfers

388wi may transfer personal data to data processors or storage infrastructure located outside Pakistan or outside the country in which you reside. When personal data is transferred to a jurisdiction that may not provide the same level of data protection as your home jurisdiction, we implement appropriate safeguards — which may include standard contractual clauses, binding corporate rules or equivalent mechanisms recognised under applicable privacy law.

By using the Platform, you acknowledge that your personal data may be processed in jurisdictions outside Pakistan, and you consent to such transfers as necessary for the operation of the Platform and the provision of Services to you.

11 Your Rights

Subject to applicable data protection law and the operator's license jurisdiction requirements, you hold the following rights in respect of your personal data. To exercise any of these rights, contact us using the details in Section 16.

We will respond to verified data rights requests within a reasonable timeframe consistent with applicable law. We reserve the right to verify your identity before processing a data rights request to prevent fraudulent access to another person's data.

12 Children's Privacy

The 388wi Platform is strictly for adults aged 18 or older — or the higher minimum age required by the operator's license jurisdiction. We do not knowingly collect personal data from persons under the minimum required age. If we discover that a minor has provided personal data or registered an account, we will immediately suspend the account, delete the associated personal data and take appropriate action in accordance with our Terms and Conditions and applicable law.

If you believe that a person under the minimum age may have registered on the Platform using false information, please contact us immediately at [email protected]. Parental control software can provide an additional layer of protection against minors accessing online gambling platforms.

13 Marketing Communications

13.1 Opt-In Basis

388wi sends promotional emails, bonus notifications and platform updates only to users who have explicitly opted in to receive such communications during registration or subsequently through account settings.

13.2 Withdrawing Consent

You may withdraw consent to receive marketing communications at any time by: clicking the unsubscribe link in any marketing email; adjusting notification preferences in your account settings; or contacting our support team directly.

13.3 Service Communications

Even where you have opted out of marketing communications, 388wi may continue to send essential service communications — including account security alerts, KYC requests, regulatory notifications and transaction confirmations. These are not marketing messages and are sent on the basis of our contractual and legal obligations to you.

14 Third-Party Links & External Services

The 388wi Platform may contain informational references to third-party payment providers, sports leagues or other services. These references are contextual only. 388wi is not responsible for the privacy practices, data processing activities or security standards of any third party. Users who interact with third-party services — including payment processors — are subject to those parties' own privacy policies and terms.

Payment providers referenced on this Platform, including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah, have independent privacy policies that govern how they collect and process user data. We encourage you to review the privacy documentation of any financial service you use in connection with your 388wi account.

15 Amendments to This Policy

388wi reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, business practices or Platform functionality. When material changes are made, we will update the "Last Updated" date at the top of this page and, where appropriate, notify registered users by email.

Your continued use of the Platform following the publication of an amended Privacy Policy constitutes your acceptance of the updated terms. We recommend reviewing this Policy periodically. The current version of this Policy supersedes all prior versions.

16 Contact Us

To exercise your data rights, ask questions about this Privacy Policy, raise a data protection concern or request information about how your personal data is processed, please contact 388wi using the details below: