Privacy Policy — How Koboy89 Handles Your Personal Data

Koboy89 ("we", "us", "our", "the Platform") operates the online casino and sports betting platform accessible at https://koboy89.cam. We are committed to protecting and respecting the privacy of every individual who interacts with our Platform, whether as a registered Member or as a visitor.

This Privacy Policy ("Policy") describes in detail how Koboy89 collects, receives, processes, stores, shares, and protects personal data submitted by or generated through your use of the Platform. It also explains the choices you have regarding your personal data and the rights you may exercise at any time.

This Policy forms part of the overall contractual relationship between you and Koboy89, alongside our Terms & Conditions. By registering an Account or continuing to use the Platform, you acknowledge that you have read, understood, and accept the data practices described in this Policy.

For the purposes of this Privacy Policy, the following terms carry the meanings assigned below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, identification number, contact details, financial data, location data, or any combination of information that can identify an individual.
• "Data Subject" means the individual to whom the Personal Data relates — in this context, you, the Member or visitor.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data. Koboy89 is the Data Controller for all Personal Data collected through the Platform.
• "Data Processor" means any third party that processes Personal Data on behalf of the Data Controller, pursuant to a data processing agreement.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, erasure, or destruction.
• "KYC" means Know Your Customer verification procedures used to confirm Member identity and satisfy applicable compliance obligations.
• "Cookie" means a small data file placed on your device by the Platform for the purposes of session management, analytics, or personalisation.
• "MYR" means Malaysian Ringgit, the primary transaction currency of the Platform.

Koboy89 collects the following categories of Personal Data in connection with your use of the Platform:

We do not collect sensitive personal data categories such as racial or ethnic origin, religious beliefs, biometric data, or health information unless expressly required for a specific regulatory purpose and you have given explicit consent.

Koboy89 collects Personal Data through the following primary channels:

• Direct submission: Information you provide when registering an Account, completing KYC verification, submitting a support request, or communicating with our team via live chat or email.
• Automated collection: Technical and usage data collected automatically when you access and interact with the Platform, including via cookies, server logs, and similar tracking technologies.
• Payment processing: Transaction data exchanged between Koboy89 and our approved payment partners (including Maybank2u, CIMB Clicks, Public Bank, Hong Leong Connect, Touch 'n Go eWallet, Boost, GrabPay, DuitNow, and FPX) in connection with deposits and withdrawals.
• Third-party verification: Identity and document verification data received from third-party KYC service providers engaged to assist with regulatory compliance checks.
• Publicly available sources: In limited circumstances for fraud prevention, we may supplement your information with data obtained from publicly available government databases or credit reference agencies.

Koboy89 processes your Personal Data for the following specific purposes. We do not use your data for any purpose other than those listed below without first obtaining your explicit consent or being required to do so by law.

1. Account Management: Creating, maintaining, and managing your registered Koboy89 Account, including authentication, account settings, and profile updates.
2. Service Delivery: Facilitating your access to casino games, sports betting markets, live dealer tables, and all other Platform features you choose to use.
3. Payment Processing: Processing deposits and withdrawals in MYR via your chosen Malaysian payment method, reconciling transactions, and maintaining accurate financial records.
4. KYC & Regulatory Compliance: Verifying your identity and age in accordance with applicable gaming regulations and anti-money laundering (AML) obligations. This includes collecting and retaining copies of identity documents as required.
5. Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, account compromise, and other forms of abuse or prohibited conduct on the Platform.
6. Customer Support: Responding to your enquiries, resolving disputes, and providing ongoing support via live chat and email.
7. Responsible Gambling: Monitoring gameplay patterns to identify potential indicators of problem gambling behaviour, administering deposit limits, loss limits, and self-exclusion requests, and fulfilling our duty of care obligations.
8. Communications: Sending transactional notifications (account activity, deposit confirmations, withdrawal status updates) and, where you have opted in, marketing communications about promotions and new Platform features.
9. Analytics & Platform Improvement: Analysing aggregated usage data to understand how Members interact with the Platform and to identify areas for improvement in performance, design, and user experience.
10. Legal Obligations: Meeting any applicable legal, regulatory, or governmental reporting requirements imposed on the Platform operator.

Koboy89 relies on the following legal bases when processing your Personal Data:

• Contractual necessity: Processing required to perform the services you have contracted with us by registering an Account and using the Platform (e.g., payment processing, account management, game access).
• Legal obligation: Processing required to comply with applicable legal and regulatory requirements, including anti-money laundering laws, age verification obligations, and data retention mandates.
• Legitimate interests: Processing carried out in pursuit of Koboy89's legitimate business interests, including fraud prevention, platform security, analytics, and service improvement — provided these interests are not overridden by your rights and freedoms.
• Consent: Processing for purposes such as optional marketing communications, where we have obtained your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Koboy89 does not sell, rent, or trade your Personal Data to third parties for their own commercial purposes under any circumstances. We may disclose your data to the following categories of recipients solely for the purposes outlined in this Policy:

• Payment Service Providers: Malaysian financial institutions and e-wallet operators (including Maybank, CIMB, Public Bank, Hong Leong, Touch 'n Go, Boost, GrabPay, DuitNow, FPX) to facilitate transaction processing. Each provider is governed by their own privacy terms.
• Identity Verification Partners: Third-party KYC and AML service providers engaged to assist with document verification and compliance screening under contractual data processing agreements.
• Technology Service Providers: Cloud infrastructure, hosting, analytics, and customer support technology providers who process data on our behalf under strict data processing agreements that prohibit independent use of your data.
• Game Content Partners: Licensed game studios whose titles are accessible through the Platform may receive limited technical data necessary for game delivery and RNG integrity, but do not receive identifiable personal information beyond session identifiers.
• Regulatory & Law Enforcement Authorities: Where we are legally obligated to do so by court order, regulatory directive, or applicable law. We will notify you of any such disclosure where permitted by law.
• Business Successors: In the event of a merger, acquisition, or sale of Platform assets, your data may be transferred to the successor entity, subject to equivalent privacy protections. You will be notified of any such event.

Koboy89 retains Personal Data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. Specific retention periods by data category are as follows:

• Account and Identity Data: Retained for the duration of your Account's active status, plus a minimum of five (5) years following Account closure to satisfy regulatory obligations relating to KYC records.
• Financial Transaction Data: Retained for a minimum of seven (7) years from the date of the relevant transaction in accordance with financial recordkeeping requirements.
• Customer Support Communications: Retained for three (3) years from the date of the communication, or longer if related to an unresolved dispute or regulatory inquiry.
• Technical and Usage Data: Retained for up to twenty-four (24) months, after which it is anonymised or deleted.
• Marketing Consent Records: Retained for the duration of your active consent, plus three (3) years following withdrawal of consent or Account closure as evidence of compliance.

Upon expiry of the applicable retention period, Personal Data will be securely deleted or anonymised such that it can no longer be associated with any identifiable individual.

Koboy89 uses cookies and similar tracking technologies (including web beacons and local storage) to operate and improve the Platform. Cookies are small data files stored on your device when you visit the Platform.

We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that maintain your login state and security tokens. These cannot be disabled without impairing Platform functionality.
• Performance & Analytics Cookies: Collect aggregated, anonymised data about how visitors interact with the Platform — such as pages visited, time spent, and error messages — to help us improve Platform performance and user experience.
• Functional Cookies: Remember your preferences and settings (such as language, display preferences, and last-used payment method) to provide a more personalised experience.
• Security Cookies: Used to detect and prevent fraudulent activity, including unusual login patterns and suspicious transaction behaviour.

You may manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of some Platform features. Koboy89 does not use third-party advertising cookies or track your activity on other websites.

Koboy89 implements a comprehensive suite of technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and Koboy89 servers is encrypted using industry-standard SSL/TLS protocols.
• Data Encryption at Rest: Sensitive personal data, including identity documents and financial information, is encrypted at rest within our secure database infrastructure.
• Access Controls: Access to Personal Data is restricted on a strict need-to-know basis. All staff with data access privileges are subject to confidentiality obligations and undergo regular security training.
• Two-Factor Authentication: Koboy89 offers two-factor authentication (2FA) for Member Accounts to provide an additional layer of protection against unauthorised access.
• Regular Security Audits: The Platform undergoes periodic independent security assessments and penetration testing to identify and remediate potential vulnerabilities.
• Incident Response: Koboy89 maintains a documented data breach response procedure. In the event of a data breach that poses a risk to your rights, we will notify affected Members without undue delay and in accordance with applicable notification requirements.

While we implement robust safeguards, no internet-based system can guarantee absolute security. We encourage you to take your own precautions — including using a strong, unique password and enabling 2FA on your Account.

Subject to applicable data protection law, you hold the following rights in respect of your Personal Data held by Koboy89. To exercise any of these rights, please contact our support team via live chat or email at [email protected].

We will respond to all verified rights requests within thirty (30) calendar days of receipt. Requests will be verified against your Account credentials before any action is taken. There is no charge for exercising your rights in most circumstances.

The Koboy89 Platform is strictly intended for use by individuals aged 21 years and above. We do not knowingly collect, process, or retain Personal Data from any person under the age of 21.

If we become aware that Personal Data has been collected from a person below the minimum age threshold — whether through registration, KYC verification, or any other means — we will immediately suspend the associated Account, delete all collected Personal Data, and take appropriate action to prevent further access.

If you are a parent or guardian and believe that a minor under your care has registered on the Koboy89 Platform, please contact us immediately at [email protected] so that we may investigate and take appropriate remedial action without delay.

In order to deliver the Platform's services, your Personal Data may be transferred to and processed in countries other than Malaysia. This may occur when we use cloud infrastructure, third-party service providers, or game studio partners whose operations are based in other jurisdictions.

Where Personal Data is transferred outside of Malaysia, Koboy89 ensures that such transfers are made only to recipients who provide an adequate level of data protection — either through contractual data protection clauses, binding corporate rules, or other legally recognised transfer mechanisms.

Where required, we implement additional safeguards to ensure that your Personal Data receives protection consistent with the standards described in this Policy regardless of where it is processed. By using the Platform, you acknowledge and consent to such cross-border transfers as necessary for the delivery of our services.

Koboy89 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or Platform functionality. When material changes are made — particularly changes that affect your rights or the way we use your Personal Data — we will notify registered Members via email to their registered address and/or through a prominent in-platform notification at least fourteen (14) days before the changes take effect.

The most current version of this Policy is always accessible at https://koboy89.cam/privacy-policy. The "Last Updated" date at the top of this page reflects the date of the most recent revision. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

If you do not agree with any changes to this Policy, you have the right to close your Account and request deletion of your Personal Data, subject to our legal retention obligations.

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or have concerns about how your Personal Data is being handled, please contact Koboy89 through the following channels:

• Live Chat: Available 24/7 directly through the Koboy89 Platform — average response time under 2 minutes.
• Email: [email protected] — privacy-related email enquiries are responded to within 2 business hours. Please include "Privacy Request" in your subject line to ensure prompt routing to the appropriate team.

When submitting a rights request, please provide your full registered name, Account username, and a clear description of your request to enable efficient and accurate processing. We may need to verify your identity before actioning any request.