389win88 – Privacy and Data Protection Policy

1. Introduction

389win88 is a Sports Betting and online casino platform serving Brazilian users. We understand that when you use any digital service, you're entrusting it with information that deserves real care — not just a paragraph buried in the site footer.

This Privacy Policy explains, in plain language and without unnecessary legal jargon, how 389win88 collects, uses, stores, protects, and may share the personal data of platform users. It applies to all 389win88 services: Sports Betting, Live Casino, slots, crash games, jackpots, the VIP Program, and any other product available on the platform.

By creating an account, making a deposit via Pix, or confirming any bet on 389win88, you acknowledge that you have read and understood this Privacy Policy. If you have questions before completing registration, please contact our privacy channel before proceeding.

2. Data Controller

The controller of personal data processed by 389win88 is the company responsible for operating the platform in Brazil. The 389win88 Data Protection Officer (DPO) is the official point of contact for privacy-related matters and can be reached by email at privacidade@389win88.net.

Any communication related to the exercise of data subject rights — including requests for access, correction, portability, or deletion — must be directed exclusively to the privacy channel indicated above. The platform's general support team does not handle requests of a legal or data protection nature.

3. Personal Data We Collect

3.1 Data provided directly by you

At registration and throughout your use of the platform, 389win88 collects the following information that you voluntarily provide:

• Full name and date of birth;
• CPF (Cadastro de Pessoas Físicas);
• Email address and mobile phone number;
• Full residential address (including ZIP code);
• Identity documents (national ID, driver's license, or passport) when requested for verification;
• Banking and payment details to process deposits via Pix, boleto bancário, credit or debit card, PicPay, Mercado Pago, and TED transfers to Nubank, Itaú, Bradesco, Banco do Brasil, and other available banks;
• Profile information, such as sport and communication preferences.

3.2 Automatically collected data

389win88 also automatically collects certain technical information when you access the platform from a mobile phone, tablet, or computer:

3.3 Transaction and betting data

389win88 automatically logs all financial transactions and betting activity carried out on the platform: deposits, withdrawals, confirmed bets, results, bonus usage, and VIP Program activity. This record-keeping is legally required for anti-money laundering purposes and to meet regulatory obligations.

4. How 389win88 Uses Your Data

389win88 uses the personal data it collects solely for the following purposes:

• Account operation: create, manage, and maintain your account on the platform, verify identity, and confirm eligibility to use the services;
• Transaction processing: process deposits via Pix, bank slip, credit and debit card, PicPay, Mercado Pago, wire transfer, and other available methods, as well as requested withdrawals;
• Service delivery: provide Sports Betting, live casino, slots, crash games, jackpots, and VIP Program features;
• Account communication: send registration confirmations, security alerts, transaction notifications, and essential operational information;
• Promotional communications: send offers, bonuses, and updates from 389win88 — only to users who have consented to receive them;
• Security and fraud prevention: detect, investigate, and prevent unauthorized access, fraud, multiple accounts, and any activity that violates the platform's Terms and Conditions;
• Legal and regulatory obligations: comply with legal anti-money laundering requirements, financial record retention obligations, and requests from competent authorities;
• Platform improvement: analyze usage patterns to improve the experience, fix issues, and develop new features on 389win88.

5. Legal Basis for Processing (LGPD)

389win88 processes personal data only where there is a legal basis under the LGPD authorizing such processing. The legal bases applied are:

• Contract performance (art. 7, V of the LGPD): processing is necessary to perform the service agreement accepted at registration — without this data, it is not possible to create an account, process bets, or carry out transactions;
• Compliance with a legal or regulatory obligation (art. 7, II): identification data and financial records are processed to comply with obligations imposed by Brazilian law, including anti-money laundering regulations;
• Legitimate interest (Art. 7, IX): used for platform security, fraud prevention, and service improvement, provided it does not override the fundamental rights of the data subject;
• Consent (Art. 7, I): used to send 389win88 marketing communications and promotions — consent may be withdrawn at any time without any impact on your account.

6. Sharing Data with Third Parties

389win88 does not sell users' personal data. Information is shared with third parties only in the situations listed below, and always limited to the minimum data necessary for the specific purpose:

6.1 Essential service providers

389win88 works with service providers that support the operation of the platform — including technology infrastructure providers, payment processors, identity verification suppliers, and analytics tool providers. These partners receive only the data necessary to perform the contracted service and are contractually required to handle that information in accordance with the LGPD and 389win88's security standards.

6.2 Legal obligations and authorities

389win88 may share data with Brazilian public, regulatory, or judicial authorities when required by law, such as in compliance with a court order, a regulatory body's request, or reporting obligations under anti-money laundering legislation (Law No. 9,613/1998 and COAF regulations).

6.3 Game and casino providers

The Live Casino, slots, and crash games available on 389win88 are provided by third-party developers. To ensure the games function properly, minimal session data is transmitted to these providers — this does not include complete financial information or the user's personal documents.

7. Cookies and Tracking Technologies

389win88 uses cookies and similar technologies to ensure the platform operates correctly, improve the browsing experience, and — with your consent — personalize the content displayed. The types of cookies used are:

• Essential cookies: required for the platform to function properly — they keep your session active, remember basic preferences, and ensure transactions are processed securely. They cannot be disabled without affecting the service's functionality;
• Analytical cookies: collect information on how users navigate the 389win88 platform — which sections they visit, how long they spend on each page, and which features they use. All data is anonymized and used solely to improve the product;
• Preference cookies: store settings you have configured, such as language and display preferences, so you do not need to reset them on each visit;
• Marketing cookies: used only if you have consented to receiving personalized communications. They allow 389win88 to present promotions that are more relevant to your usage profile.

You can manage cookie preferences through your browser settings. Disabling analytics and marketing cookies does not affect access to the platform's core features. Disabling essential cookies may prevent login, the bet slip, and transaction processing from working correctly.

8. Data Storage and Security

Personal data of 389win88 users is stored on secure servers protected by the following technical and organizational measures:

• 256-bit SSL encryption on all data transmissions between users' devices and the platform;
• Encryption of data at rest for sensitive information, such as identity documents and banking data;
• Strict access controls: only staff with a proven operational need are granted access to users' personal data, with multi-factor authentication required;
• Continuous security monitoring with alerts for unauthorized access and anomalous behavior;
• Periodic backups with secure retention to ensure service availability;
• Regular vulnerability testing and security audits conducted by specialized teams.

In the event of a security incident that may compromise users' personal data, 389win88 will notify the National Data Protection Authority (ANPD) and the affected individuals within the deadlines established by the LGPD.

9. Data Retention

389win88 retains personal data for as long as necessary to fulfill the purposes described in this Privacy Policy and to meet specific legal obligations:

• Registration and active account data: retained for the full period the account remains active, plus the time needed to resolve any pending disputes;
• Financial transaction records: retained for a minimum of 5 (five) years after each transaction, as required by Brazilian financial legislation and anti-money laundering regulations;
• Betting records: retained for a minimum of 5 (five) years for audit purposes, fraud prevention, and potential dispute resolution;
• Identity verification documents: retained for the applicable legal period after account closure, and never for less than the minimum required by current regulations;
• Marketing communication data: deleted or anonymized upon user request, except where retention is required by a legal obligation.

Once the applicable retention period has expired, data is securely deleted or anonymized in a way that no longer allows identification of the individual, without prejudice to compliance with any remaining legal obligations.

10. Your Rights as a Data Subject (LGPD)

The LGPD guarantees you, as the data subject whose information is processed by 389win88, the following rights, which may be exercised at any time through the platform's privacy channel:

To exercise any of the rights listed above, submit your request to privacidade@389win88.net with the subject line "LGPD Rights" and identification of the data subject. 389win88 will respond within the statutory deadline of up to 15 days from receipt of the request.

11. Protection of Minors' Data

389win88 services are intended exclusively for users aged 18 and over. The platform does not intentionally collect personal data from minors and has eligibility verification mechanisms at registration to enforce this restriction.

If 389win88 becomes aware that data from a user under 18 has been inadvertently collected, the account will be closed immediately, the data will be deleted, and the balance will be returned to the legal guardian upon submission of supporting documentation.

If you are the legal guardian of a minor and suspect they have created an account on 389win88, please contact platform support immediately via live chat or by emailing privacidade@389win88.net.

12. Fraud Prevention and Anti-Money Laundering

389win88 has legal obligations regarding the prevention of money laundering and terrorism financing under Law No. 9,613/1998 and the regulations of the Financial Activities Control Council (COAF). To meet these obligations, 389win88:

• Performs user identity verification (KYC – Know Your Customer);
• Monitors transaction patterns to identify suspicious behavior;
• Reports suspicious transactions to the relevant authorities when required by law;
• Retains transaction records for the minimum legally required period.

Data processing for these purposes is legally required and cannot be objected to by the data subject, as it arises from compliance with a legal obligation under art. 7, II of the LGPD. 389win88 handles this data with the utmost confidentiality, and only authorized personnel have access to anti-money laundering information.

13. Links to External Pages

In certain contexts, the 389win88 platform may include references or links to pages belonging to Brazilian regulatory bodies and government agencies. 389win88 is not responsible for the privacy practices of any external pages. This Privacy Policy applies exclusively to pages and services operated directly by 389win88.

The third-party game providers that power 389win88's Live Casino and slots have their own privacy policies governing the handling of game session data. 389win88 only selects providers that demonstrate compliance with appropriate data protection standards.

14. Changes to This Privacy Policy

389win88 may update this Privacy Policy periodically to reflect changes in Brazilian legislation, platform practices, or new regulatory requirements. Any material changes will be communicated to users via their registered email and through an in-platform notification at least 15 days before taking effect.

Changes arising from urgent legal requirements may take effect immediately, but 389win88 will notify users as soon as possible after implementation. Continued use of the platform after any changes take effect constitutes tacit acceptance of the updated Privacy Policy.

We recommend reviewing this Policy periodically to stay informed about how 389win88 protects your information. A version history of previous editions can be requested from the platform's DPO through the privacy channel.

15. How to Get in Touch – DPO and Privacy Channel

To exercise your rights as a data subject, clarify questions about this Privacy Policy, or report any concerns related to the processing of your personal data by 389win88, please use the channels below:

• DPO email: privacidade@389win88.net — for data protection matters, the exercise of LGPD rights, and formal complaints;
• General support email: suporte@389win88.net — for operational matters, account issues, and transactions;
• Live chat: available 24 hours on the 389win88 platform for urgent support matters;
• WhatsApp: available at the number listed on the platform for support in Portuguese.

LGPD rights requests submitted through the correct channel (DPO email) will be answered within 15 calendar days, as stipulated by Lei nº 13.709/2018. For more complex cases, 389win88 may request an extension with a written justification.

If you do not receive a satisfactory response from 389win88 within the legally required timeframe, you may file a complaint directly with the National Data Protection Authority (ANPD), as provided under art. 18, VIII of the LGPD.