Last updated: 1 January 2026
Section 1
Introduction
This Privacy Policy ("Policy") describes how 378win ("Platform", "we", "us", "our"),
accessible at https://378win.cam, collects, uses, stores, shares and
protects the personal data of individuals ("User", "you", "your") who access or use
our services.
378win is an English-language online gaming information and entertainment platform
designed for users based in Pakistan. We are committed to handling your personal data
responsibly and transparently in accordance with applicable data protection principles
and the terms of our operating license.
By registering on or using the 378win platform, you acknowledge that you have read
and understood this Policy and consent to the collection and use of your personal
data as described herein. This Policy is incorporated by reference into our
Terms & Conditions. If you do not agree with
any part of this Policy, please discontinue use of the platform immediately.
Note for Pakistani Users: Pakistan's data
protection landscape is governed by the Personal Data Protection Bill (under
legislative development) and relevant provisions of the Prevention of Electronic
Crimes Act, 2016 (PECA). This Policy reflects general international data
protection standards applicable to the platform's operating license jurisdiction.
Nothing in this Policy constitutes legal advice regarding Pakistani data
protection obligations. Users with specific legal concerns should seek qualified
independent legal guidance.
Section 2
Definitions
For the purposes of this Privacy Policy, the following definitions apply:
"Personal Data"
Any information that identifies or can reasonably be used to identify a living individual, directly or in combination with other data.
"Processing"
Any operation performed on personal data, including collection, storage, use, disclosure, transfer, deletion or destruction.
"Data Controller"
The entity that determines the purposes and means of processing personal data — in this context, 378win.
"Data Processor"
A third party that processes personal data on behalf of the Data Controller, such as a KYC verification provider or analytics service.
"Consent"
A freely given, specific, informed and unambiguous indication of agreement to the processing of personal data for a stated purpose.
"KYC Data"
Identity and age verification documents submitted by Users, including CNIC, passport, proof of address and selfie/liveness data.
"Cookie"
A small data file placed on a User's device by a web server, used to store preferences, session identifiers and usage information.
"Third Party"
Any entity other than the User and 378win, including payment processors, technology vendors and regulatory authorities.
Section 3
Data We Collect
378win collects personal data through multiple channels in the ordinary course of
operating the platform. The categories of data we may collect are set out below.
We collect only what is necessary for the stated purpose.
| Data Category |
Examples |
Collection Method |
| Registration Data |
Full name, date of birth, email address, username, password (hashed) |
Provided by User at registration |
| KYC / Identity Data |
CNIC or passport copy, proof of address, selfie or liveness image |
Uploaded by User through secure KYC portal |
| Financial Data |
Deposit records, withdrawal requests, transaction history, payment method references |
Generated through platform transactions |
| Device & Technical Data |
IP address, browser type, device model, operating system, screen resolution |
Collected automatically on platform access |
| Usage Data |
Pages visited, games accessed, session duration, click patterns, search queries |
Collected automatically via cookies and analytics |
| Communications Data |
Support ticket content, email correspondence, chat transcripts where applicable |
Generated through User–support interactions |
| Responsible Gambling Data |
Deposit limit settings, self-exclusion requests, cooling-off period activations |
Provided by User or generated by platform safety tools |
Payment Data Note: Payment method references on
the 378win platform — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank
and Bank Alfalah — are cited for contextual illustration only. 378win does not
directly store full payment card or bank account numbers. Financial transaction
processing is handled by the operator's designated payment processors, each
operating under their own privacy and security frameworks. Users should review
their chosen payment provider's privacy policy independently.
Section 4
Legal Basis for Processing
378win processes personal data only where a lawful basis exists. The applicable legal
bases for processing your data are as follows:
-
Contractual Necessity: Processing required to
operate your account, verify your identity, process transactions and deliver the
services described in our Terms & Conditions. Without this processing, we
cannot provide the platform to you.
-
Legal Obligation: Processing required to comply
with anti-money laundering (AML) obligations, Know Your Customer (KYC) requirements,
financial record-keeping duties and any applicable regulatory obligations imposed
under the operator's license jurisdiction.
-
Legitimate Interests: Processing undertaken to
prevent fraud, detect prohibited conduct such as multi-accounting or bonus abuse,
improve platform security and analyse usage patterns to enhance service quality —
where these interests are not overridden by your privacy rights.
-
Consent: Where required, we will seek your
explicit consent for specific processing activities — for example, sending
promotional communications or placing non-essential cookies. You may withdraw
consent at any time by contacting support or adjusting your browser settings,
without affecting the lawfulness of prior processing.
Section 5
How We Use Your Data
Personal data collected by 378win is used exclusively for the following purposes:
5.1 Account Operations
- Creating and managing your registered account
- Verifying your identity and age through the KYC process
- Processing deposit and withdrawal transactions
- Applying and managing bonus offers in accordance with published terms
- Communicating account-related updates, security alerts and service notifications
5.2 Legal Compliance
- Fulfilling anti-money laundering (AML) and counter-terrorism financing (CTF) obligations
- Maintaining transaction records as required by the operator's license jurisdiction
- Responding to lawful requests from competent regulatory or law enforcement authorities
- Enforcing our Terms & Conditions and investigating suspected breaches
5.3 Platform Improvement
- Analysing aggregated usage data to improve platform performance and user experience
- Identifying technical errors, security vulnerabilities and fraud patterns
- Personalising content recommendations where you have not opted out
- Conducting internal research and analytics on an anonymised or pseudonymised basis
5.4 Responsible Gambling
- Recording and enforcing self-exclusion requests, deposit limits and cooling-off periods
- Monitoring usage patterns to identify potential signs of problem gambling behaviour
- Sending responsible gambling reminder communications where appropriate
5.5 Marketing Communications
Where you have consented to receive promotional communications, we may contact you
about relevant bonuses, promotions and platform updates by email. You may withdraw
this consent at any time by contacting support. We do not send unsolicited
commercial communications to Users who have not opted in.
Section 6
Data Sharing
378win does not sell, rent or trade your personal data to third parties. We may
share personal data with third parties only in the following limited circumstances:
-
KYC & Identity Verification Providers:
Third-party providers that process identity documents and liveness checks on our
behalf, operating under strict data processing agreements and applicable data
protection standards.
-
Payment Processing Partners:
Transaction data may be shared with payment processors as necessary to execute
deposits and withdrawals. These processors operate under their own terms and
privacy policies. Their engagement does not imply endorsement of gambling by
any referenced payment brand.
-
Technology & Infrastructure Providers:
Hosting, content delivery, security and analytics service providers that support
platform operations under confidentiality and data processing obligations.
-
Regulatory & Law Enforcement Authorities:
Where required by law, court order or lawful regulatory request, we will disclose
personal data to competent authorities. We will inform you of such disclosure
where legally permitted to do so.
-
Business Transfers:
In the event of a merger, acquisition, reorganisation or sale of assets, your
personal data may be transferred to a successor entity subject to equivalent
privacy protections. You will be notified of any such transfer.
All third-party data processors engaged by 378win are required to maintain appropriate
security standards and to use personal data only for the specific purposes for which
it was shared.
Section 7
Data Retention
378win retains personal data only for as long as is necessary for the purposes for
which it was collected or as required by applicable law. The following general
retention principles apply:
-
Active Account Data: Retained for the duration
of your account registration and for a reasonable period thereafter to allow for
dispute resolution and account reinstatement requests.
-
KYC and Identity Documents: Retained for the
minimum period required under the applicable AML and KYC regulatory framework —
typically five (5) years from the date of account closure or last transaction,
whichever is later.
-
Financial Transaction Records: Retained for a
minimum of five (5) years in accordance with standard financial record-keeping
obligations applicable under the operator's license jurisdiction.
-
Communications and Support Data: Retained for
a reasonable period, typically up to three (3) years, to facilitate resolution of
any ongoing or future disputes relating to your account or transactions.
-
Analytics and Usage Data: Aggregated or
pseudonymised usage data may be retained indefinitely for statistical and
improvement purposes, as it cannot reasonably be used to re-identify individual Users.
On the expiry of the applicable retention period, personal data is securely deleted
or irreversibly anonymised in a manner that prevents re-identification.
Section 8
Cookies & Tracking Technologies
378win uses cookies and similar tracking technologies to operate the platform,
remember your preferences and analyse usage patterns. The following cookie
categories are deployed:
| Type |
Purpose |
Category |
| Session Cookies |
Maintain your logged-in state and security token during a browsing session. Deleted when you close your browser. |
Essential |
| Authentication Cookies |
Remember your login status across sessions where "Remember Me" is selected. Required for account access. |
Essential |
| Preference Cookies |
Store your display preferences such as language selection and responsible gambling limit settings. |
Functional |
| Security Cookies |
Detect and prevent fraudulent activity, cross-site request forgery and bot traffic. |
Essential |
| Analytics Cookies |
Collect aggregated, pseudonymised data about page visits, session duration and feature usage to help us improve the platform. |
Analytics |
| Performance Cookies |
Monitor platform load times, error rates and technical performance to identify issues affecting User experience. |
Analytics |
Managing Cookies
Essential cookies cannot be disabled as they are required for platform operation.
Non-essential cookies (functional and analytics) can be managed through your
browser settings. Most modern browsers allow you to block, delete or set expiry
preferences for cookies. Please note that disabling certain cookies may affect the
functionality of the platform — for example, preference cookies that store your
responsible gambling limit settings. Consult your browser's help documentation for
instructions on cookie management specific to your browser and device.
Section 9
Your Rights
Subject to applicable data protection law and the legal obligations to which 378win
is subject (including AML/KYC record-keeping requirements), you have the following
rights in relation to your personal data:
Right of Access
You have the right to request a copy of the personal data we hold about you and information about how it is being processed.
Right to Rectification
You have the right to request correction of inaccurate or incomplete personal data held by 378win without undue delay.
Right to Erasure
You may request deletion of your personal data where it is no longer necessary for the purpose collected, subject to overriding legal retention obligations.
Right to Restrict Processing
You may request that we temporarily restrict processing of your data in certain circumstances, such as while the accuracy of data is disputed.
Right to Data Portability
Where processing is based on consent or contract and carried out by automated means, you may request a structured, machine-readable copy of your data.
Right to Object
You may object to processing based on legitimate interests, including profiling for marketing purposes. We will cease processing unless compelling legitimate grounds override your interests.
To exercise any of these rights, please contact our support team using the details
provided in Section 14. We will respond to verified requests within a reasonable
timeframe. We may need to verify your identity before processing a rights request
to ensure data is not disclosed to unauthorised parties.
Important Limitation: Certain rights — in
particular the right to erasure — may be restricted where data must be retained
to comply with legal obligations such as AML record-keeping requirements or ongoing
dispute resolution. We will inform you of any restriction applied to a rights
request and the reason for it.
Section 10
Security Measures
378win implements a range of technical and organisational security measures to protect
your personal data against unauthorised access, accidental loss, destruction or
disclosure. These measures include:
- SSL/TLS encryption for all data transmitted between your browser and the platform
- At-rest encryption for sensitive stored data including KYC documents and financial records
- Strict access controls limiting internal access to personal data to authorised personnel on a need-to-know basis
- Regular security assessments and vulnerability reviews of platform infrastructure
- Secure password hashing — plain-text passwords are never stored
- Session timeout controls to reduce the risk of unauthorised access to active sessions
- Two-factor authentication options available to Users for enhanced account security
While 378win takes every reasonable precaution to secure personal data, no internet
transmission or digital storage system is entirely immune from risk. In the event of
a data breach that is likely to result in a high risk to your rights, we will notify
affected Users without undue delay as required by applicable law.
You are also responsible for maintaining the security of your own account — including
choosing a strong password and not sharing your login credentials with any third party.
If you suspect your account has been compromised, please contact support immediately.
Section 11
Minors & Age Restriction
The 378win platform is strictly restricted to adults aged 18 or above — or the higher
minimum age required by the applicable operator/license jurisdiction. We do not
knowingly collect personal data from individuals below the minimum required age.
Age verification is conducted through the KYC process as a mandatory step before full
account activation. If we become aware that personal data has been collected from a
minor, we will take immediate steps to delete that data and close the associated account.
Parents and guardians are encouraged to use device-level parental controls and content
filtering tools to prevent access to online gambling platforms by minors in their
household. The 18+ minimum does not imply that online gambling is lawful for all
adults in Pakistan — local laws may impose additional restrictions.
Section 12
International Data Transfers
As an internationally operated platform, 378win may transfer personal data to servers
or third-party processors located outside Pakistan. Where such transfers occur, we
ensure that appropriate safeguards are in place to protect your data, including:
- Standard contractual clauses or equivalent data transfer mechanisms approved under applicable data protection frameworks
- Transfer only to jurisdictions or processors that maintain adequate data protection standards
- Contractual obligations on all third-party processors to apply equivalent security and privacy standards to those described in this Policy
By using the 378win platform, you acknowledge that your personal data may be transferred
to and processed in jurisdictions outside Pakistan. We take reasonable steps to ensure
that any such processing is conducted in accordance with this Policy and applicable
data protection principles.
Section 13
Policy Updates
378win reserves the right to update or amend this Privacy Policy at any time in
response to changes in applicable law, platform operations or industry best practice.
Where material changes are made, we will provide notice through the platform — for
example, by displaying a prominent banner or sending an email notification to
registered Users.
The "Last updated" date at the top of this page reflects the most recent revision.
Continued use of the platform following the publication of an updated Policy
constitutes your acceptance of the revised terms. If you do not agree to the
updated Policy, please discontinue platform use and contact support to request
account closure.
Section 14
Contact Us
For any questions, concerns, data access requests or complaints regarding this
Privacy Policy or the processing of your personal data, please contact the
378win support team. Our team communicates in English and can accommodate
Urdu-speaking users where needed.
Email (plain text — not a link):
[email protected]
Available during standard business hours. Response times may vary during high-volume
periods such as PSL cricket season or major ICC tournament dates. We endeavour to
respond to all privacy-related inquiries within a reasonable timeframe.
Users across Pakistan — including Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad,
Multan and Peshawar — are welcome to contact us in English. For responsible gambling
matters specifically, please also visit our
Responsible Gambling page.