378win Privacy Policy

This Privacy Policy is issued by 378win, the online gaming platform accessible at 378win.net (referred to throughout this document as "378win", "we", "us", or "our"). 378win operates an online gaming and sports betting platform serving players in Pakistan and other eligible jurisdictions.

For the purposes of this Privacy Policy, 378win is the data controller in respect of the personal data of registered players and platform visitors. As data controller, 378win determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out in accordance with applicable data protection principles.

378win collects personal data in several categories, depending on your interaction with the platform. The following table summarises the main categories of personal data we process:

We do not collect or store sensitive personal data beyond what is strictly necessary for identity verification and regulatory compliance. We do not store full payment card numbers on 378win servers — payment transactions are processed through our authorised payment processor partners.

378win collects personal data through the following channels and methods:

The majority of personal data we hold about you is provided directly by you in the course of your interaction with the 378win platform. This includes data provided when you register an account, complete identity verification, make a deposit or withdrawal, contact customer support, respond to a survey or promotion, or update your account settings.

When you access the 378win platform, certain technical data is collected automatically by our systems. This includes your IP address, device identifiers, browser type and version, session start and end times, pages visited, and actions taken within the platform. This data is collected through server logs, cookies, and similar tracking technologies and is used primarily for platform security, fraud detection, and performance monitoring.

In certain circumstances, 378win may receive personal data about you from third parties. This includes data received from identity verification service providers in connection with KYC procedures, data from payment processors in connection with financial transaction processing, and data from fraud prevention services in connection with security monitoring. Such data is handled in accordance with this Privacy Policy.

378win uses the personal data it collects for the following defined purposes:

• Account Registration and Management: To create and maintain your 378win account, verify your identity and age (21+ requirement), manage your account settings, and provide you with access to the platform's services.
• Service Delivery: To process bets, game sessions, deposits, withdrawals, and bonus claims, and to provide you with a personalised, functional gaming experience across all 378win products.
• Regulatory and Legal Compliance: To fulfil our obligations under applicable anti-money laundering (AML) regulations, Know Your Customer (KYC) requirements, responsible gaming obligations, and other applicable legal and regulatory duties.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, bonus abuse, money laundering, multiple account registration, and other prohibited conduct. To protect the security and integrity of the 378win platform and its players.
• Customer Support: To respond to your support queries, resolve disputes, investigate complaints, and provide you with technical and account assistance via live chat and email.
• Responsible Gaming: To monitor gaming activity for indicators of problem gambling behaviour, to enforce self-exclusion periods and account limits set by players, and to fulfil our responsible gaming obligations to players and regulators.
• Platform Improvement: To analyse aggregated and anonymised usage data to understand how the platform is used, identify technical issues, improve performance, and develop new features and products that better serve Pakistani players.
• Marketing Communications: Where you have provided your consent, to send you promotional communications about 378win bonuses, new features, and special offers. You may withdraw consent to marketing communications at any time by contacting the support team.

378win processes your personal data on the following legal bases, depending on the specific processing activity:

• Contractual Necessity: The processing of your personal data is necessary for the performance of the contract between you and 378win — namely, the provision of online gaming services under the 378win Terms and Conditions. This covers account registration, service delivery, payment processing, and account management.
• Legal Obligation: Certain processing is required to comply with legal and regulatory obligations applicable to 378win's operation as an online gaming platform, including AML and KYC obligations, age verification, and responsible gaming requirements.
• Legitimate Interests: 378win processes certain personal data on the basis of legitimate business interests, including fraud prevention, platform security monitoring, and platform improvement through aggregated analytics. We have assessed that these interests are not outweighed by your individual privacy rights.
• Consent: Where processing is based on your consent — primarily in relation to marketing communications — you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

378win does not sell, rent, or trade your personal data to any third party for their own marketing or commercial purposes. Personal data is shared with third parties only in the following circumstances and under appropriate data protection safeguards:

378win shares financial and identity data with authorised payment processing partners — including the operators of JazzCash, EasyPaisa, HBL, UBL, Allied Bank, SadaPay, and cryptocurrency processing services — to the extent necessary to process deposits, withdrawals, and refunds. These partners are contractually required to handle your data in accordance with applicable data protection requirements and to use it solely for the purpose of transaction processing.

To fulfil identity verification and age verification requirements, 378win may share identity data with authorised third-party KYC and identity verification service providers. These providers process personal data solely for verification purposes under 378win's instruction and in accordance with applicable data protection obligations.

378win may share technical and identity data with fraud prevention service providers to detect and prevent fraudulent activity, bonus abuse, and security threats on the platform. Such sharing is limited to the data necessary for these fraud prevention purposes.

378win will disclose personal data to regulatory authorities, law enforcement agencies, or other governmental bodies where required to do so by applicable law, court order, or regulatory direction. 378win will only disclose the minimum data necessary to comply with such requirements and will, where legally permissible, notify affected players of such disclosures.

In the event of a merger, acquisition, restructuring, or sale of all or part of 378win's business assets, personal data held by 378win may be transferred to the relevant acquiring or successor entity as part of that transaction. Players will be notified of any such transfer that materially affects the processing of their personal data.

The 378win platform uses cookies and similar tracking technologies to provide certain platform functionality, maintain session integrity, and collect technical data for security and analytics purposes. The following types of cookies are used on the 378win platform:

• Strictly Necessary Cookies: These cookies are essential for the operation of the 378win platform and cannot be disabled. They include session cookies that maintain your login state, security tokens, and cookies required for payment processing functionality. Without these cookies, the platform cannot function correctly.
• Functional Cookies: These cookies remember your preferences and settings — such as your preferred language and game display settings — to provide a more personalised and consistent experience across sessions.
• Analytics Cookies: 378win uses analytics cookies to collect aggregated, anonymised data about how players use the platform. This data helps us understand usage patterns, identify technical issues, and improve the platform experience. Analytics cookies do not identify individual users.
• Security Cookies: These cookies assist in fraud detection and platform security monitoring by identifying unusual or suspicious session behaviour patterns.

378win implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, disclosure, alteration, or destruction. These measures include:

• Encryption of personal data in transit using TLS (Transport Layer Security) protocols and encryption of sensitive data at rest.
• Strict access controls limiting access to personal data to authorised 378win personnel on a need-to-know basis, with all access logged and monitored.
• Regular security assessments and vulnerability testing of the 378win platform and its underlying infrastructure.
• Secure, encrypted storage of passwords. 378win does not store plain-text passwords and your password is not accessible to 378win staff.
• Fraud detection systems that monitor account activity in real time for signs of unauthorised access or security anomalies.

Notwithstanding these measures, no data transmission over the internet or electronic storage system can be guaranteed to be completely secure. Players have an important role in protecting their own account security — please refer to the account security provisions in the 378win Terms and Conditions for your obligations in this regard.

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, 378win will notify affected players without undue delay and will take immediate steps to contain and remediate the breach.

378win retains personal data for as long as is necessary to fulfil the purposes set out in this Privacy Policy, or as required by applicable legal, regulatory, and compliance obligations. The following general retention principles apply:

• Active Account Data: Personal data associated with an active 378win account is retained for the duration of the account relationship and for a defined period following account closure to fulfil post-closure legal and regulatory obligations.
• Financial and Transaction Records: Financial records, including deposit and withdrawal transaction data and bet history, are retained for a minimum period as required by applicable AML regulations and financial record-keeping obligations. This period is typically a minimum of five years from the date of the relevant transaction.
• Identity Verification Documents: KYC and identity verification documents are retained for the period required by applicable AML and gaming regulatory obligations, which is typically a minimum of five years from the date of verification or account closure, whichever is later.
• Support Communications: Customer support correspondence is retained for a defined period to facilitate dispute resolution and quality assurance. Records relating to formal disputes or complaints may be retained for longer in connection with any ongoing legal proceedings.
• Marketing Data: Where processing is based on consent, marketing data is retained until you withdraw your consent or for a defined period of inactivity, whichever occurs first.

Once personal data is no longer required and no legal obligation to retain it exists, it is securely deleted from 378win systems or rendered permanently anonymous so that it can no longer be attributed to an identified individual.

378win recognises the following rights in relation to your personal data. You may exercise any of these rights by contacting the 378win support team via live chat or at [email protected]:

378win will respond to data rights requests within a reasonable timeframe. In some cases — particularly where legal or regulatory obligations require data to be retained — it may not be possible to fulfil a deletion or restriction request in full. Where this is the case, we will explain the reasons clearly.

The 378win platform is strictly intended for adults aged 21 years and over. 378win does not knowingly collect personal data from any person under the age of 21. If 378win discovers that personal data has been collected from an individual who is under 21 years of age, that data will be deleted from our systems immediately and the associated account will be closed.

If you are a parent or guardian and you believe that a person under 21 in your care has registered an account or provided personal data to 378win, please contact the support team at [email protected] immediately. We will investigate and take appropriate action without delay.

378win uses age verification procedures — including CNIC verification — during the account registration and KYC process to identify and prevent underage access to the platform. These controls are a core component of both our responsible gaming obligations and our data protection obligations.

In certain operational contexts, personal data held by 378win may be transferred to or processed by systems or service providers located outside Pakistan. This may occur in connection with cloud hosting infrastructure, payment processing services, or identity verification providers that operate internationally.

Where personal data is transferred internationally, 378win takes steps to ensure that appropriate safeguards are in place to protect the data in accordance with applicable data protection principles. This includes the use of contractual data protection clauses with service providers that require them to handle transferred personal data with a standard of protection equivalent to that applied within Pakistan.

By registering an account on 378win and accepting this Privacy Policy, you acknowledge that your personal data may be transferred and processed in jurisdictions outside Pakistan in connection with the provision of 378win's services, subject to the safeguards described in this section.

378win reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal or regulatory requirements, or platform operations. When material changes are made, 378win will take reasonable steps to notify registered players — either by displaying a prominent notice on the platform or by communicating to the email address registered to your account.

The most current version of this Privacy Policy is always accessible at 378win.net/privacy-policy. The date of the most recent revision is shown at the top of this document. Your continued use of the 378win platform following the posting of any amendment constitutes your acknowledgement of the updated Privacy Policy.

We encourage all 378win players to review this Privacy Policy periodically to stay informed about how we protect and use your personal data. If you have any concerns about any changes made to this Policy, please contact the support team before continuing to use the platform.

If you have any questions, concerns, or requests relating to this Privacy Policy or to the processing of your personal data by 378win, please contact us through one of the following channels:

• Live Chat: Available 24 hours a day, 7 days a week via the live chat function on the 378win platform. Recommended for urgent data security or account access concerns.
• Email: [email protected] — for data access requests, deletion requests, consent withdrawals, and general privacy enquiries. Please include "Privacy Request" in the subject line of your email to ensure prompt routing to the appropriate team. Typical response time within 1 hour during business hours.

When submitting a data rights request, please provide your full registered name, the email address associated with your 378win account, and a clear description of your request. We may need to verify your identity before processing your request to ensure that personal data is not disclosed to or acted upon at the request of an unauthorised party.