In accordance with the LGPD – Law No. 13,709/2018

38win Privacy Policy – Your Data, Always Protected

This document explains clearly and directly how the 38win collects, stores, uses, and protects the personal data of platform users. We strictly comply with the General Data Protection Law (LGPD) and handle every piece of information with the respect you deserve. No fine print, no surprises.

Last updated: January 2026 · Version 2.4

1. Data Controller

The 38win, operator of the platform available at 38win.world, is the controller of personal data collected through the use of its services. As the data controller, the 38win defines the purposes and means by which personal data is processed, in accordance with the General Data Protection Law (LGPD — Law No. 13.709/2018) and other applicable Brazilian legislation.

The 38win has appointed a Data Protection Officer (DPO) responsible for receiving communications, answering questions, and ensuring compliance with LGPD obligations. To contact the DPO, use the email privacidade@38win.world or the live chat channel available on the platform 24 hours a day.

This Privacy Policy applies to all users of the 38win platform, including unregistered visitors, users with active accounts, and former users whose data remains within the legally established retention period.

2. Data We Collect

2.1 Data provided directly by you

By registering and using the platform 38win, you voluntarily provide us with the following personal data:

  • Identification: full legal name as shown on an official document, CPF, date of birth, and gender (optional).
  • Contact: email address, mobile number with area code, and full residential address including postal code (CEP).
  • Verification documents (KYC): government-issued ID image (national ID, driver's license, or passport), proof of address, and a selfie with the document, collected to fulfill identity verification obligations.
  • Financial data: registered Pix key, bank details for wire transfers, credit/debit card information processed exclusively by authorized payment gateways — the 38win does not store full card details on its own servers.
  • Communication preferences: choice over receiving promotional emails, push notifications, and SMS.

2.2 Automatically collected data

While using the platform, the 38win automatically collects technical information required for the service to function and remain secure:

  • Access data: IP address, browser or app type and version, operating system, device language setting, and the date and time of each access.
  • Usage data: pages visited, events clicked, bets placed, games accessed, session duration, and usage frequency.
  • Device data: unique device identifier (for security and fraud prevention), screen resolution, and connection type (Wi-Fi or mobile data).
  • Cookies and similar technologies: as described in section 7 of this policy.

2.3 Data received from third parties

In specific circumstances, the 38win may receive supplementary data from authorized partners: payment providers (such as identity confirmation linked to a Pix key), identity verification services, and, where applicable, regulatory bodies that require information sharing under a legal obligation.

3. How We Use Your Data

The 38win uses your personal data solely for the purposes described below, always grounded in one of the legal bases set out by the LGPD (contract performance, legal obligation, legitimate interest, or consent):

  • Account creation and management: registration, authentication, password recovery, and personalization of the platform experience.
  • Financial transaction processing: deposits via Pix, boleto bancário, credit/debit card, PicPay, Mercado Pago, and TED; withdrawal processing and financial history management.
  • Identity verification (KYC/AML): compliance with legal obligations related to anti-money laundering and age verification (18+).
  • Provision of betting and casino services: betting history recording, calculation and payment of winnings, and access to personal usage statistics and reports.
  • Customer support: support via live chat, email, and interaction logging for dispute resolution and continuous service improvement.
  • Marketing communications: sending offers, promotions, new game notifications, and relevant content — only with your express consent, which can be withdrawn at any time.
  • Security and fraud prevention: monitoring of access and betting patterns to identify suspicious activity, use of multiple accounts, and conduct that violates the Terms and Conditions.
  • Compliance with legal obligations: responding to requests from competent authorities as required by applicable Brazilian law.
  • Platform improvement: aggregated and anonymized analysis of usage data to identify opportunities for technical and user experience improvements.

The 38win does not use your personal data for any purposes not explicitly described in this policy. We do not sell, rent, or transfer personal data to third parties for commercial purposes unrelated to the platform's operation.

4. Data Sharing

The sharing of personal data by 38win is restricted to the following categories of recipients, all operating under data processing agreements that guarantee the same level of protection required by the LGPD:

  • Payment providers: authorized gateways for processing transactions via Pix, boleto bancário, credit/debit card, PicPay, and Mercado Pago. These partners receive only the data strictly necessary to process each transaction.
  • Live casino game providers: Evolution Gaming, Pragmatic Play, and Playtech receive an anonymous session identifier to record game results — they do not receive full personally identifiable information.
  • Identity verification services: KYC partners who perform document comparison and biometric verification to confirm users' identities during the withdrawal process.
  • Technology infrastructure: cloud and hosting providers that maintain the platform's servers, operating strictly as data processors under contract.
  • Legal authorities: data may be shared with Brazilian government, judicial, or regulatory authorities when required by law, court order, or applicable regulation.

No personal data is shared with third parties for advertising, market research, or any other commercial purpose not listed above. Business partners offering promotions on the 38win do not have access to individual user data — any campaign effectiveness analysis is conducted using aggregated and anonymized data.

5. Data Retention & Deletion

The 38win retains personal data for as long as necessary to fulfill the purposes for which it was collected, in compliance with applicable minimum legal retention periods:

  • Active account data: retained for the full duration of the account and for up to 5 years after voluntary closure, in accordance with anti-money laundering legal requirements.
  • Financial transaction history: retained for a minimum of 5 years after each transaction, as required by Brazilian tax and financial legislation.
  • KYC data (documents): retained for up to 5 years after account closure, or longer if required by a competent authority.
  • Support communication data: retained for 2 years for dispute resolution and service improvement purposes.
  • Marketing data: deleted immediately upon consent withdrawal or within 30 days of a deletion request.

Once retention periods expire, data is securely deleted or anonymized so that the user can no longer be identified. You may request early deletion of specific data by exercising the rights described in Section 8, subject to any legal obligations that require certain information to be retained.

6. Data Security

The 38win implements technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, or improper disclosure. The main security measures in place include:

  • Encryption in transit: all communications between your device and the servers of the 38win are protected by TLS 1.3, the latest standard for encryption in transit.
  • Encryption at rest: sensitive data stored on servers — including identity documents and banking details — is encrypted with AES-256.
  • Access control: personal data is accessible only to staff and systems with a legitimate need, controlled by multi-factor authentication and audit logs.
  • Continuous monitoring: intrusion detection systems and anomaly monitoring operate 24 hours a day to identify unauthorized access attempts.
  • Security testing: the platform undergoes regular penetration testing carried out by independent security firms.
  • Segregated balance: user funds are kept in accounts separate from the company's operations, protecting account balances from any operational contingencies.

In the event of a security incident that may affect your personal data, the 38win will notify the National Data Protection Authority (ANPD) and affected users within the timeframes set by the LGPD — generally within 72 hours of becoming aware of the incident. The notification will include a description of the incident, the data affected, and the measures taken to mitigate the risks.

7. Cookies & Tracking

The 38win uses cookies and similar technologies to ensure the platform functions correctly and to improve the user experience. Cookies are small text files stored on your device when you access the platform. The types of cookies used are:

You can configure your browser to block cookies, but doing so may affect essential platform features — such as the login process and betting slip loading. Marketing cookies can be declined without impacting the core functions of the 38win.

8. Your Rights Under the LGPD

The General Data Protection Law grants you a range of rights over your personal data. The 38win is committed to making it easy to exercise these rights — quickly and without red tape. To exercise any of them, contact us at privacidade@38win.world with the subject line "LGPD Rights – [your full name]".

The response time for LGPD rights requests is up to 15 calendar days from receipt confirmation. In cases requiring more in-depth analysis, this period may be extended by an additional 15 days with written justification.

9. Minors' Data

The platform 38win is intended exclusively for individuals aged 18 and over. We do not knowingly collect personal data from anyone under 18. If we identify that an account was created by a minor, it will be closed immediately, the data will be deleted, and any deposited balance will be refunded to the original payment method after verification.

If you are the guardian of a minor and believe they have created an account on the 38win without authorization, contact support immediately at suporte@38win.world or via live chat. We will handle the matter with priority and discretion.

10. International Data Transfers

Some of the operational partners of the 38win — such as cloud infrastructure providers and live game providers — may process data on servers located outside Brazil. In such cases, the 38win ensures that any transfer is carried out on the basis of one of the safeguards provided under the LGPD: standard contractual clauses requiring a level of protection equivalent to Brazilian standards, internationally recognized certifications, or an adequacy decision issued by the ANPD.

International data transfers are limited to the minimum necessary for platform operations. Sensitive data — such as identity documents and complete banking information — is preferably processed on servers located in Brazil.

11. Changes to This Privacy Policy

The 38win may update this Privacy Policy to reflect changes in its data practices, applicable legislation, or platform features. The most current version will always be available on this page, with the revision date shown at the top of the document.

For material changes that affect how your data is handled — such as new purposes of use, new partners with data access, or changes to retention periods — the 38win will send an email notification to all active registered users at least 15 days in advance, describing the changes and offering the option to close their account if they do not agree with the new terms.

12. Contact & Data Protection Officer (DPO)

To exercise your LGPD rights, clarify questions about this policy, or file a complaint regarding the handling of personal data, please contact 38win through the channels below:

  • DPO Email: privacidade@38win.world
  • General support: suporte@38win.world
  • Live chat: available 24 hours on the 38win platform

If, after contacting 38win, you feel your rights have not been properly addressed, you may file a complaint with the National Data Protection Authority (ANPD), the regulatory body responsible for enforcing the LGPD in Brazil.

How 38win Protects Your Data in Practice

Data protection is more than words on a page. Here is what 38win actively does to keep your information secure.

End-to-End SSL Encryption

All communication between your phone or computer and 38win's servers uses TLS 1.3 — the most current encryption protocol available. Data at rest on the servers is protected with AES-256. No information is ever transmitted without protection.

Full LGPD Compliance

38win strictly complies with the General Data Protection Law (Lei nº 13.709/2018 – LGPD). We have a designated DPO, documented data processing procedures, and incident response processes that meet the deadlines set by the ANPD.

Card Data Never Stored

38win does not store complete credit or debit card details on its own servers. All payment processing is handled exclusively by PCI-DSS certified gateways — the payment industry's security standard — which handle this data in an isolated environment.

No Sale of Data to Third Parties

38win does not sell, rent, or share personal data for advertising or market research purposes. Your data is used exclusively to operate the platform, process payments, and meet legal obligations — nothing more.

Full Control in Your Hands

You can unsubscribe from marketing communications at any time directly from your account dashboard. Access, correction, or deletion requests are handled within 15 days. Your LGPD rights are real and easy to exercise at 38win.

Incident Notification

If a security incident affects your data, you will be notified by email within the legally required timeframe. The notification will cover what happened, which data was affected, and the steps taken — no vague statements, no omissions.

Your Rights as a Data Subject at 38win

The LGPD gives you clear rights over your data. See what you can request from 38win at any time.

Right of Access

You can request a copy of all personal data 38win holds about you — including what data is processed, for what purposes, and with whom it has been shared. We respond within 15 business days.

Right to Correction

If any of your personal information is incorrect or out of date — such as your name, email, or address — you can request a correction at any time. Basic details can be updated directly in your account dashboard without needing to contact support.

Right to Erasure

You can request deletion of your personal data. Data that is not legally required to be retained (such as financial history from the past 5 years) will be deleted. Data subject to legal retention obligations will be kept for the minimum required period and then deleted.

Right to Withdraw Consent

For processing activities based on consent — such as receiving marketing communications — you may withdraw your authorization at any time. Withdrawal does not affect the lawfulness of any processing carried out prior to it.

Right to Data Portability

You may request your data in a structured, machine-readable format to transfer it to another service, as provided for by the LGPD. Delivery takes up to 15 calendar days after the request is confirmed.

Right to File a Complaint with the ANPD

If you believe that 38win has not handled your data properly or has not responded satisfactorily to your requests, you may file a complaint directly with the National Data Protection Authority (ANPD) through the authority's official portal.

Summary: Data Collected, Purpose, and Legal Basis

Data Type Primary Purpose Legal Basis (LGPD) Retention
Full name, CPF, date of birth Account registration and identity verification Contract performance / Legal obligation 5 years after account closure
Email and mobile number Communication, support, and security Contract performance / Legitimate interest 5 years after account closure
KYC documents (RG/CNH) Age verification and AML Legal obligation 5 years after account closure
Payment data (Pix, TED) Processing deposits and withdrawals Contract performance / Legal obligation 5 years as required by tax law
Betting history Settlement, disputes & reports Contract performance / Legal obligation 5 years after account closure
IP address & access data Security & fraud prevention Legitimate interest 2 years
Marketing preferences Sending promotional communications Consent Until consent is withdrawn
Platform usage data Product improvement (anonymized) Legitimate interest 2 years (anonymized thereafter)

Your Data Secure, Your Bet Worry-Free

At 38win, you place your bets knowing your data is protected under the LGPD, your Pix transactions are processed securely, and your information is never sold to third parties. Create your account and experience a platform that takes privacy seriously.

Create Free Account Responsible Gambling

+18 years · LGPD compliant · Secure Pix · AES-256 encrypted data

FAQ – Privacy at 38win

No. The 38win does not sell, rent, or share personally identifiable data with advertising networks, data brokers, or any company for commercial purposes unrelated to the platform's operation. Partners that offer promotions on the platform do not have access to individual user data. Any campaign effectiveness analysis is carried out using fully anonymized and aggregated data — with no information that could identify a specific user. If you receive marketing communications from 38win, it is because you gave express consent at the time of registration or at a later point. That consent can be withdrawn at any time through your account dashboard or by email at privacidade@38win.world.

To request deletion of your personal data, send an email to privacidade@38win.world with the subject line "LGPD Data Deletion", including your full name and CPF for identity confirmation. We respond within 15 business days. Please note that data subject to legal retention obligations — such as financial history from the past 5 years, as required by tax and anti-money laundering legislation — cannot be deleted before the legal retention period expires, even upon request. In such cases, 38win will inform you which data will be retained, for how long, and under which specific legal obligation. All other data will be deleted within the response deadline.

Full credit and debit card details — card number, CVV, and expiration date — are never stored on 38win's servers. This information is processed exclusively by our partner payment gateways, which are certified PCI-DSS Level 1 (the highest certification level in the payments industry). 38win stores only a reference token provided by the gateway, used to facilitate future transactions without sensitive card data passing through the platform again. For Pix transactions, 38win stores the Pix key used to process withdrawals — this information is retained for the legal retention period applicable to financial history.

After account closure, 38win retains mandatory data for the legally required period — generally 5 years for financial and KYC data, in accordance with anti-money laundering legislation and tax obligations. Data not subject to any legal retention requirement — such as marketing preferences, platform usage data, and support communications older than 2 years — is deleted within 90 days of account closure. Once all retention periods have expired, any remaining data is securely deleted or anonymized so it can no longer be linked to you. You will receive an email confirmation when the final deletion is complete.

Yes, but only when legally required. 38win may share personal data with Brazilian governmental, judicial, or regulatory authorities when there is: a valid court order, a request from a law enforcement authority in the regular exercise of its duties, or a request from the Receita Federal, the Financial Activities Control Council (COAF), or the ANPD in the exercise of their legal powers. In such cases, 38win shares only the data specifically requested and for the minimum period necessary to comply. Whenever legally permitted, the user is notified of the request before it is fulfilled. Voluntary data sharing with authorities — without a legal basis — does not occur.
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