Privacy Policy

01 Introduction

This Privacy Policy ("Policy") describes how 388com ("388com", "we", "us", "our"), the operator of the website located at https://388com.cam (the "Platform"), collects, uses, stores, discloses and protects personal data relating to users of the Platform ("User", "you", "your").

388com is committed to handling your personal data responsibly and in a manner consistent with internationally recognised data protection principles. By registering an account, depositing funds, placing bets or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

This Policy should be read together with our Terms & Conditions and our Responsible Gambling Policy, both of which are incorporated by reference.

02 Definitions

The following definitions apply throughout this Policy:

• "Personal Data" — any information that identifies or can reasonably be used to identify a living individual, directly or indirectly.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, use, disclosure, erasure or destruction.
• "Data Controller" — the entity that determines the purposes and means of processing Personal Data. For the Platform, this is 388com.
• "Data Processor" — any third party that processes Personal Data on behalf of 388com under a written agreement and in accordance with 388com's instructions.
• "Cookies" — small text files placed on a User's device by the Platform to recognise returning visitors, maintain session state and gather analytical data.
• "KYC" — Know Your Customer procedures used to verify a User's identity, age and payment method ownership.
• "Sensitive Data" — a sub-category of Personal Data warranting heightened protection, which may include financial account details and identity document information.

03 Data We Collect

388com collects the following categories of Personal Data from users of the Platform:

We do not intentionally collect Special Category Data (such as data revealing racial or ethnic origin, religious beliefs, or health data) unless strictly required for responsible gambling assessment purposes and only with your explicit consent.

04 How We Collect Data

388com collects Personal Data through the following means:

• Direct Submission: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or responding to surveys and promotions.
• Automated Technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, server logs and session-tracking technologies.
• Third-Party Sources: Identity and fraud-screening data received from KYC verification providers, payment processors and anti-money-laundering screening databases, used to supplement information you have provided directly.
• Payment Method Interactions: Transaction confirmation data received from payment processing systems. Payment provider names such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are referenced for context only; 388com does not represent that any of these providers endorse or support gambling services.

05 Data Processing & Purpose

388com processes your Personal Data only for specific, legitimate purposes. The primary purposes for which we process your data are as follows:

• Account Management: Creating, maintaining and securing your 388com account, including password resets and two-factor authentication.
• KYC & Identity Verification: Verifying your identity and age to comply with licensing obligations and to prevent underage gambling.
• Payment Processing: Facilitating deposits and withdrawals, investigating disputed transactions and maintaining accurate financial records.
• Anti-Money Laundering (AML) & Fraud Prevention: Monitoring transactions and account behaviour to detect and prevent financial crime, in compliance with applicable regulatory requirements.
• Responsible Gambling: Monitoring betting patterns to identify potential problem gambling behaviour and to administer self-exclusion, deposit limits and other responsible gambling tools.
• Customer Support: Responding to enquiries, resolving disputes and maintaining records of communications for quality assurance.
• Platform Improvement: Analysing aggregated usage data to improve the Platform's features, performance and user experience.
• Marketing Communications: Sending promotional offers, bonus notifications and event alerts (e.g., PSL fixtures, ICC tournaments, major football matches, UFC events) to users who have opted in to receive such communications.
• Legal & Regulatory Compliance: Meeting our obligations under applicable laws and responding to lawful requests from regulatory or law-enforcement authorities.

06 Legal Basis for Processing

Where international data protection frameworks apply, 388com relies on the following legal bases to process your Personal Data:

• Contractual Necessity: Processing required to fulfil our obligations under the Terms & Conditions, including account management, payment processing and bet settlement.
• Legitimate Interests: Processing necessary for our legitimate business interests — such as fraud detection, platform security and product improvement — where those interests are not overridden by your rights and freedoms.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including AML obligations, KYC requirements and responses to lawful regulatory or law-enforcement requests.
• Consent: Processing based on your freely given, specific, informed and unambiguous consent — primarily for marketing communications and optional personalisation features. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out prior to withdrawal.

07 Data Sharing

388com does not sell, rent or trade your Personal Data to any third party for their independent marketing purposes. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• KYC & Identity Verification Providers: Third-party services used to verify the identity and age of users during account registration and at withdrawal.
• Payment Processors: Entities that facilitate deposits and withdrawals on the Platform. Data shared is limited to what is necessary to complete and authenticate each transaction.
• Fraud & AML Screening Services: Providers of databases and tools used to screen users and transactions against sanctions lists, fraud registries and other relevant databases.
• Technology & Hosting Partners: Infrastructure, cloud-hosting and software providers that support the operation of the Platform, bound by data processing agreements with 388com.
• Customer Support Platforms: Third-party tools used to manage live chat and email support interactions, used only to facilitate communication between users and 388com's support team.
• Regulatory & Law Enforcement Authorities: Where required by applicable law or a lawful regulatory order, 388com may disclose user data to government bodies, courts or law-enforcement agencies.
• Responsible Gambling Bodies: In jurisdictions where 388com's licence requires sharing of self-exclusion or problem gambling data with central registries, 388com will comply with those obligations.

08 Data Retention

388com retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Active Account Data: Retained for the lifetime of your account and for a minimum of five (5) years following account closure, to comply with AML record-keeping requirements.
• KYC & Identity Documents: Retained for a minimum of five (5) years after the end of the business relationship, or longer if required by applicable regulatory obligation.
• Transaction Records: Retained for a minimum of five (5) years in line with standard financial record-keeping practice.
• Support Communications: Retained for three (3) years from the date of the communication unless related to an open dispute, in which case records are kept until the dispute is fully resolved.
• Cookie & Analytics Data: Session cookies are deleted at the end of the browser session. Persistent cookies and analytics identifiers are retained for periods specified in the cookie settings, typically not exceeding thirteen (13) months.
• Marketing Preference Records: Opt-out and consent records are retained indefinitely to demonstrate compliance and to honour your stated preferences.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be attributed to any individual.

09 Data Security

388com implements a range of technical and organisational measures designed to protect your Personal Data against unauthorised access, accidental loss, alteration or disclosure. These measures include, but are not limited to:

• TLS/SSL encryption for all data transmitted between your device and the Platform.
• Encryption of sensitive data at rest, including identity documents and financial records.
• Role-based access controls ensuring that only authorised personnel can access Personal Data, strictly on a need-to-know basis.
• Regular security assessments and vulnerability testing of the Platform's infrastructure.
• Multi-factor authentication options for user accounts and mandatory multi-factor authentication for internal staff systems handling Personal Data.
• Incident response procedures for detecting, investigating and reporting data breaches within applicable regulatory timeframes.

While 388com takes data security seriously, no online platform can guarantee absolute security. Users are encouraged to use strong, unique passwords, to keep their login credentials confidential and to notify 388com's support team immediately upon suspecting any unauthorised access to their account.

10 Cookies & Tracking Technologies

388com uses cookies and similar tracking technologies to operate and improve the Platform. The following cookie categories are in use:

• Strictly Necessary Cookies: Essential for the Platform to function, including session management, authentication and security. These cannot be disabled without impairing core functionality.
• Functional Cookies: Remember your preferences, such as language settings, odds format and preferred sports markets (e.g., cricket, PSL, football), to personalise your experience on return visits.
• Analytical Cookies: Collect anonymised data on how users navigate the Platform — pages visited, time on site, error events — to help 388com improve performance and usability.
• Marketing Cookies: Used to measure the effectiveness of 388com's own promotional campaigns on the Platform. These are only active with your consent.

You may manage your cookie preferences through your browser settings. Disabling certain cookies may limit Platform functionality. Consent for non-essential cookies may be withdrawn at any time by adjusting your browser or account settings.

11 International Data Transfers

388com may transfer your Personal Data to countries outside your country of residence, including to countries where the Platform's servers, KYC providers or technology partners are located. Where such transfers occur, 388com takes steps to ensure that appropriate safeguards are in place, which may include:

• Standard contractual clauses approved by relevant data protection authorities.
• Data processing agreements with all third-party processors that impose obligations equivalent to those binding on 388com.
• Transfers only to jurisdictions that provide an adequate level of data protection as determined by applicable law or by 388com's internal data transfer assessment process.

By using the Platform, you acknowledge that your Personal Data may be transferred to and processed in jurisdictions outside Pakistan. 388com will at all times endeavour to ensure that such transfers are conducted lawfully and with appropriate protections in place.

12 Your Rights

Subject to applicable law and any overriding legal obligations (such as AML record-keeping requirements), you have the following rights in relation to your Personal Data held by 388com:

• Right of Access: You may request a copy of the Personal Data 388com holds about you, together with information about how it is being processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete Personal Data. For straightforward corrections (e.g., contact details), you may update data directly within your account settings.
• Right to Erasure: You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to any legal obligation requiring its retention.
• Right to Restriction: You may request that processing of your Personal Data be restricted in certain circumstances, for example where you contest the accuracy of the data or object to its processing.
• Right to Data Portability: Where processing is based on your consent or on a contractual necessity, you may request a copy of the data you have provided in a commonly used, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes. Where you object to marketing, your preference will be honoured immediately.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of the above rights, please contact our support team using the contact details in Section 15 of this Policy. 388com will respond to valid requests within thirty (30) calendar days. In complex cases, this period may be extended by a further sixty (60) days, with prior notice provided.

13 Minors & Age Verification

The Platform is strictly for users who are 18 years of age or older, or the higher minimum age required by the operator's license jurisdiction. 388com does not knowingly collect Personal Data from individuals under the applicable minimum age. Age verification is a mandatory component of the account registration and KYC process.

If 388com discovers or has reasonable grounds to suspect that Personal Data has been collected from an individual below the minimum age, the relevant account will be immediately suspended, all associated data will be reviewed, and — following completion of the investigation — data relating to the underage individual will be deleted except to the extent that its retention is required by law for fraud prevention or AML purposes.

If you are a parent or guardian and believe that a minor in your care has registered an account on the Platform, please contact us immediately using the details in Section 15.

14 Policy Amendments

388com reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, our data processing activities or the Platform's features. The date of the most recent update is displayed at the top of this document.

Where changes are material — meaning they significantly affect how your Personal Data is processed or your rights in relation to it — 388com will provide reasonable advance notice via a Platform notification or email to your registered address before the changes take effect. Your continued use of the Platform following the effective date of an amended Policy constitutes your acceptance of the revised version.

15 Contact Us

If you have any questions about this Privacy Policy, wish to exercise a data subject right, or have a concern about how your Personal Data is being handled, please contact the 388com support team. Email addresses are displayed as plain text only and are not clickable links.

• Email: [email protected]
• Live Chat: Available 24/7 via the account dashboard (as operator-provided information)
• Response Time: Privacy and data rights requests are acknowledged within 3 business days and actioned within 30 calendar days from receipt of a verified request.

For responsible gambling enquiries, including self-exclusion requests, please visit our Responsible Gambling page.