388wim Privacy Policy

This Privacy Policy ("Policy") describes how 388wim ("388wim", "we", "us" or "our") collects, uses, stores, shares and protects personal information relating to users ("you", "your" or "User") of the 388wim platform, accessible at https://388wim.cam/ (the "Platform").

388wim is an online gaming information and services platform. In the course of providing our services — including account registration, gaming, payment processing, customer support, responsible gambling tools and marketing communications — we collect and process certain categories of personal data. This Policy explains each of those processing activities clearly and in plain English.

This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy. By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your information as described herein.

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

• "Personal Data": Any information relating to an identified or identifiable natural person. This includes, but is not limited to, name, email address, date of birth, payment details, IP address and device identifiers.
• "Processing": Any operation performed on personal data, including collection, recording, storage, retrieval, use, disclosure, transmission, restriction, erasure or destruction.
• "Data Controller": 388wim, which determines the purposes and means of processing personal data collected through the Platform.
• "Data Processor": A third party that processes personal data on behalf of 388wim in accordance with a data processing agreement and 388wim's documented instructions.
• "Consent": A freely given, specific, informed and unambiguous indication of agreement by the User to the processing of their personal data for a stated purpose.
• "KYC Data": Identity verification documentation provided by a User in fulfilment of Know Your Customer obligations, including but not limited to national identity documents, proof of address and payment method verification.
• "Sensitive Data": Special categories of personal data attracting a higher level of protection, which 388wim does not knowingly collect unless strictly necessary and with appropriate legal basis.
• "Cookies": Small text files stored on a User's device by the Platform for session management, analytics and functionality purposes.

388wim collects personal data through several channels depending on how you interact with the Platform. The categories of data we collect include:

3.1 Registration Data

When you create an account on the Platform, we collect: full name, date of birth, email address, residential country, chosen username and password (stored in hashed form). Additional fields may be presented where required by the applicable operator or regulatory framework.

3.2 KYC & Identity Verification Data

To comply with anti-money laundering (AML) and Know Your Customer (KYC) requirements, we may request: a copy of a valid national identity document (such as a CNIC for Pakistani users), proof of residential address, and in some cases proof of ownership of the payment method used. This data is handled with a heightened level of care and is processed only to the extent required for verification purposes.

3.3 Financial & Transaction Data

We collect records of deposits, withdrawals and transaction history to administer your account and comply with financial reporting obligations. We do not store full card numbers or complete account credentials for payment instruments. Payment method references — including those associated with Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah — are processed only to the extent necessary to facilitate your transaction and fulfil our compliance obligations.

3.4 Technical & Usage Data

When you access the Platform, we automatically collect certain technical data, including: IP address, device type and operating system, browser type and version, session duration and pages visited, referring URL and general geolocation derived from IP (country/city level only). This data is used for Platform security, analytics and improving user experience.

3.5 Support & Communication Data

When you contact our support team via live chat, email or the help centre, we retain records of that communication, including the content of your enquiry and our response, to facilitate resolution and maintain service quality records.

3.6 Responsible Gambling Data

Where you use responsible-gambling tools — such as setting deposit limits, requesting a cooling-off period or initiating self-exclusion — we retain records of those elections to ensure they are enforced correctly and consistently across all access points to your account.

The following table summarises the primary purposes for which 388wim processes your personal data and the data categories involved in each activity:

388wim processes personal data only where a lawful basis for doing so exists. The lawful bases relied upon are as follows:

• Contract Performance: Processing that is necessary to deliver the services you have contracted for when registering an Account — including account management, gaming access, payment processing and customer support.
• Legal Obligation: Processing required to comply with applicable legal and regulatory requirements, including AML regulations, KYC obligations, responsible-gambling mandates, financial record-keeping obligations and any requirements imposed by the applicable operator licence.
• Legitimate Interest: Processing carried out to pursue the legitimate interests of 388wim — such as improving the Platform, detecting and preventing fraud, enhancing security and conducting analytics — where those interests are not overridden by your rights and interests.
• Consent: Processing carried out on the basis of your freely given, specific and informed consent — principally for direct marketing communications. Where consent is the basis for processing, you retain the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

388wim does not sell, rent or trade your personal data to third parties for commercial or marketing purposes. We may share personal data with the following categories of third parties only to the extent necessary and subject to appropriate safeguards:

• Payment Service Providers: To facilitate deposit and withdrawal transactions, financial data is shared with the payment processor or gateway used for the relevant transaction. These providers process your data as independent data controllers or data processors under their own privacy policies.
• Identity Verification Services: KYC data may be shared with third-party identity verification providers engaged by 388wim to fulfil regulatory verification obligations.
• Gaming Technology Providers: Game content providers may receive technical session data to deliver game functionality. No personally identifiable information beyond what is technically necessary is shared with game providers.
• Regulatory and Law Enforcement Authorities: We may be required to disclose personal data to regulatory bodies, competent authorities or law enforcement agencies in accordance with applicable legal obligations. Where we are legally compelled to make such disclosures, we will comply.
• IT and Infrastructure Service Providers: Hosting, cloud storage, analytics and support tool providers engaged by 388wim process data on our behalf under binding data processing agreements.

388wim retains personal data for as long as necessary to fulfil the purposes for which it was collected, including to satisfy applicable legal, regulatory, tax and accounting obligations. The following general retention principles apply:

• Active Account Data: Retained for the duration of the account relationship and for a defined period following account closure, as required by applicable regulations.
• KYC and Identity Documents: Retained for the period required by AML and licensing regulations applicable to the operator, which typically extends beyond account closure.
• Transaction Records: Retained for a minimum period as required by applicable financial record-keeping obligations. Specific retention windows are determined by the relevant regulatory framework.
• Support Communications: Retained for a reasonable period to support quality assurance, dispute resolution and regulatory reference purposes.
• Marketing Consent Records: Retained for as long as necessary to demonstrate and manage consent status, and for the period required by applicable privacy law.
• Responsible Gambling Records: Self-exclusion, cooling-off and limit-setting records are retained for extended periods to prevent circumvention and ensure continuity of protection.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data disposal procedures.

388wim uses cookies and similar tracking technologies to operate the Platform, maintain session state and perform basic analytics. We do not deploy third-party advertising or behavioural tracking cookies.

You can manage cookie preferences through your browser settings. Blocking essential cookies will affect your ability to use the Platform. Analytics and functional cookies may be disabled without preventing basic Platform access.

388wim implements technical and organisational security measures designed to protect personal data against unauthorised access, disclosure, alteration, accidental loss or destruction. Key measures include:

• TLS/SSL Encryption: All data transmitted between your device and the Platform is encrypted using Transport Layer Security (TLS). The padlock indicator in your browser confirms an active encrypted connection.
• Password Hashing: User passwords are never stored in plain text. They are processed using a one-way cryptographic hash function, ensuring that even in the event of a data breach, original passwords cannot be recovered.
• Access Controls: Internal access to personal data is restricted on a need-to-know basis. Team members with access to personal data are subject to confidentiality obligations.
• Infrastructure Security: Platform servers and databases are hosted within secured, access-controlled environments with regular security patching and monitoring.
• Breach Response: In the event of a personal data breach that poses a risk to your rights and freedoms, 388wim will notify affected users and, where required, the relevant regulatory authority, within the timeframe prescribed by applicable law.

Subject to applicable law and any overriding legal obligations, you hold the following rights with respect to your personal data held by 388wim. Requests can be submitted to our support team at the contact details in Section 15.

We will endeavour to respond to all data rights requests within 30 days of receipt. Where a request is particularly complex or numerous, this period may be extended by a further two months, and you will be notified accordingly. We may request proof of identity before processing a data rights request to prevent unauthorised disclosure.

The 388wim Platform is strictly intended for adults aged 18 years and above, or the higher minimum age required by the applicable operator or license jurisdiction. 388wim does not knowingly collect personal data from individuals under the minimum eligible age.

If you believe that a minor has provided personal data to 388wim, please contact our support team immediately using the details in Section 15. Upon verification, we will take prompt steps to delete the relevant data and close the associated account.

As an online platform with a global infrastructure, 388wim may transfer personal data to servers or service providers located in jurisdictions outside your country of residence, including outside Pakistan. Such transfers are conducted only where:

• The destination country provides an adequate level of data protection as determined by the applicable regulatory framework.
• Appropriate safeguards are in place, such as standard contractual clauses or binding corporate rules, to ensure that your personal data receives equivalent protection in the destination jurisdiction.
• The transfer is necessary for the performance of a contract between you and 388wim, or for the performance of pre-contractual steps taken at your request.

Where transfers occur, 388wim ensures that data processors in recipient jurisdictions are bound by contractual obligations to process your data only in accordance with our documented instructions and this Privacy Policy.

The 388wim Platform may reference or provide information about third-party payment services, responsible gambling organisations or other external resources in an informational context. 388wim does not operate or control those third-party platforms and is not responsible for their privacy practices.

References to payment services such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah are made solely to describe familiar payment infrastructure available in Pakistan. When you transact using any of these services, your data is processed by the relevant provider under its own privacy policy, which you should review independently. 388wim does not claim any affiliation with or endorsement from these providers.

388wim reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, our data processing activities or the structure of the Platform. The "Last reviewed" date at the top of this page will be updated whenever a material change is made.

Where changes are material — meaning they significantly affect how we process your personal data or the rights available to you — we will provide advance notice via Platform notification or by email to your registered address prior to the changes taking effect.

Your continued use of the Platform following the effective date of any amendment constitutes your acknowledgement of the updated Privacy Policy. If you do not accept the amended terms, you should discontinue use of the Platform and request account closure.

If you have any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data by 388wim, please contact us using the details below. Our support team provides assistance in English, with Urdu-language support available on request.

For questions about responsible gambling tools — including self-exclusion, deposit limits or account cooling-off — please visit our Responsible Gambling page or raise the matter directly with our support team via live chat.