Privacy Policy

This Privacy Policy (hereinafter "Policy") issued by Koboi89 (hereinafter "we", "us", "our", or "the Platform") and applies to all personal data collected from individuals who access, register on, or interact with the Koboi89 platform atkoboi89.cam and any associated domains, mobile interfaces, or service channels (collectively, the "Platform").

Koboi89 operates as an internationally licensed online gaming platform primarily serving players based in Malaysia. We recognise that data privacy is a fundamental right, and we are committed to processing personal data responsibly, lawfully, and in accordance with internationally recognised data protection principles.

This Policy should be read together with our Terms & Conditions and our Responsible Gambling Policy. By accessing the Platform or creating an Account, you acknowledge that you have read and understood this Policy and consent to the data processing activities described herein, to the extent that such processing requires consent as its legal basis.

If you have questions about any aspect of this Policy, you may contact our Data Support team at any time. Contact details are provided in Section 15 of this Policy.

For the purposes of this Policy, the following terms carry the meanings set out below:

Koboi89 collects the following categories of personal data from users of the Platform:

We collect personal data through the following means:

1. Direct submission: Information you provide when completing the account registration form, submitting KYC documents, making a deposit or withdrawal request, contacting our support team, or updating your account profile.
2. Automated technical collection: Data collected automatically when you access the Platform, including IP address, device identifiers, browser fingerprint, session duration, pages visited, and interaction logs. This data is collected via server logs, cookies, and similar tracking technologies as described in Section 8.
3. Payment service providers: Transaction confirmation data passed to us by your payment service provider (e.g., Maybank, CIMB, Touch 'n Go eWallet, DuitNow, FPX) upon completion of a deposit or withdrawal.
4. Identity verification providers: Verification outcomes and risk signals provided by third-party KYC and identity verification services used to confirm the authenticity of documents submitted during account registration or enhanced verification.
5. Fraud and security services: Risk scoring, device reputation signals, and flaged behaviour patterns from anti-fraud and security service providers used to protect the integrity of the Platform.

Koboi89 processes personal data only where a valid legal basis exists. The legal bases on which we rely for each principal processing activity are set out below:

1. Contract performance: Processing necessary to establish, manage, and operate your Account, process deposits and withdrawals, and provide the gaming and betting services you have engaged us to provide.
2. Legal obligation: Processing required to comply with anti-money-laundering (AML) and counter-terrorist financing (CTF) regulations, our international gaming licence conditions, age verification obligations, and law enforcement requests made under applicable legal process.
3. Legitimate interests: Processing for fraud detection, platform security, abuse prevention, product improvement, and internal analytics — where such processing is proportionate to, and does not override, your fundamental rights and interests.
4. Consent: Processing for direct marketing communications and optional analytics personalisation, where you have given explicit consent. You may withdraw consent for these activities at any time by adjusting your notification preferences in your Account settings or by contacting our support team.

Personal data collected by Koboi89 is used for the following purposes:

1. Creating and managing your Account, including identity verification and age confirmation (21+ requirement).
2. Processing deposits and withdrawals via your chosen MYR payment channel, including Maybank2u, CIMB Clicks, DuitNow, Touch 'n Go eWallet, Boost, GrabPay, FPX, and cryptocurrency networks.
3. Providing access to Platform games, sports betting markets, and live casino services.
4. Administering bonuses, promotions, VIP programme tier assessments, and loyalty rewards.
5. Conducting AML and CTF screening, including transaction monitoring and politically exposed person (PEP) screening, in compliance with our licensing conditions.
6. Detecting, investigating, and preventing fraud, account abuse, collusion, and prohibited conduct as defined in our Terms & Conditions.
7. Providing customer support via live chat, email, and other communication channels.
8. Sending transactional communications (e.g., deposit confirmations, withdrawal notifications, security alerts) — these are not optional and will be sent regardless of marketing preferences.
9. Sending promotional communications and personalised offers — only where you have opted in and only until you withdraw consent.
10. Improving Platform performance, user experience, and game content through aggregated, anonymised internal analytics.
11. Fulfilling responsible gambling obligations, including monitoring for indicators of problem gambling and enforcing self-exclusion requests.

Koboi89 does not sell, rent, or commercially distribute your personal data to third parties. We share personal data only in the following limited and necessary circumstances:

1. Payment processors and banking partners: Transaction data is shared with the payment service providers you use (including Maybank, CIMB, DuitNow, Touch 'n Go eWallet, Boost, GrabPay, FPX, and cryptocurrency networks) solely to execute your deposit or withdrawal instructions.
2. Identity verification providers: KYC Data is shared with licensed third-party identity verification services for the purpose of confirming document authenticity, age, and address as required by our licensing conditions.
3. Fraud prevention and security services: Risk-relevant technical data (device identifiers, IP addresses, behavioural signals) is shared with anti-fraud service providers under data processing agreements for the purpose of protecting the Platform and its users.
4. Regulatory and law enforcement authorities: Where required by a valid legal obligation, court order, or regulatory instruction, we will disclose personal data to the relevant authority. Where permitted by law, we will notify you of such disclosure.
5. Game content and technology providers: Limited technical data (e.g., session tokens, game round identifiers) is shared with licensed third-party game studios that supply game content to the Platform, solely for the purpose of delivering game functionality.
6. Corporate transactions: In the event of a merger, acquisition, or transfer of the Platform's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

The Koboi89 Platform uses cookies and similar tracking technologies to operate core platform functionality, improve user experience, and support fraud prevention. The categories of cookies used are described below:

1. strictly necessary cookies: Essential to platform operation — including session management, authentication tokens, security verification, and fraud detection signals. These cannot be disabled without impairing Platform functionality.
2. Functional cookies: Used to remember your language preferences, display settings, and account customisation choices between sessions. Disabling these will result in a reduced personalised experience.
3. Analytical cookies: Used to measure aggregate usage patterns — page views, navigation flows, session duration, and feature interaction rates — in anonymised form, for the purpose of improving Platform performance. These are activated on the basis of your consent.
4. Marketing and preference cookies: Where you have opted into personalised promotional communications, these cookies allow us to tailor offer delivery to your demonstrated interests and gaming activity patterns. These are consent-based and may be withdrawn at any time via your Account settings.

You may manage cookie preferences through your browser settings at any time. Disabling all cookies may affect your ability to use certain Platform features. For clarity, the Platform does not currently deploy third-party advertising cookies or share cookie data with external ad networks.

Koboi89 retains personal data for as long as is necessary to fulfil the purpose for which it was collected and to comply with applicable legal, regulatory, and licensing obligations. The following retention periods apply as general guide:

1. Active account data: Retained for the duration of your active Account relationship with the Platform.
2. Account data following closure: Retained for a minimum of five (5) years following account closure to comply with AML and gaming licence record-keeping requirements. Financial transaction records are retained for the same period.
3. KYC documentation: Retained for the duration of the active Account and for five (5) years following account closure, or such longer period as may be required by applicable regulatory mandate.
4. Support communications: Retained for three (3) years following the closure of the relevant support ticket or complaint, unless longer retention is required for dispute resolution or legal proceedings.
5. Marketing consent records: Retained for three (3) years following the withdrawal of consent, to evidence the consent lifecycle for compliance purposes.
6. Technical and analytical logs: Retained for a maximum of thirteen (13) months in identifiable form, after which they are anonymised or deleted.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised, in accordance with our internal data destruction protocols.

Koboi89 implements a comprehensive set of technical and organisational security measures to protect personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

1. Transport encryption: All data transmitted between your device and Platform servers is protected by 256-bit SSL/TLS encryption. The Platform enforces HTTPS across all interfaces.
2. Access control: Access to personal data on internal systems is restricted on a need-to-know basis, with role-based permissions, multi-factor authentication requirements, and comprehensive access audit logging.
3. Password security: Account passwords are stored as salted cryptographic hashes. Koboi89 personnel will never ask for your password via any communication channel.
4. Infrastructure security: Platform servers are hosted in secured data centre environments with physical access controls, network segmentation, intrusion detection systems, and 24/7 monitoring.
5. Vulnerability management: Regular security assessments, penetration testing, and patch management are conducted to identify and remediate technical vulnerabilities.
6. Incident response: A documented data breach response protocol is maintained, including notification procedures applicable where a breach is likely to result in a risk to the rights and freedoms of affected individuals.

While we implement robust security measures, no online platform can guarantee absolute security. You play an important role in protecting your Account by keeping your login credentials confidential, enabling two-factor authentication, and reporting any suspected unauthorised access promptly to our support team.

As an internationally operated Platform, some of your personal data may be transferred to, stored in, or processed in countries outside Malaysia, including countries where Platform infrastructure, game content providers, and third-party service providers are located.

Where personal data is transferred outside Malaysia to jurisdictions that may not have equivalent data protection legislation, Koboi89 ensures that appropriate safeguards are in place to protect your data, including:

1. Standard contractual data protection clauses incorporated into data processing agreements with receiving entities;
2. Transfers only to entities that have implemented technical and organisational security measures consistent with the standards described in Section 10 of this Policy;
3. Prior assessment of the legal and regulatory environment in the receiving jurisdiction to identify any material risks to the protection of personal data.

By using the Platform, you acknowledge and accept that your personal data may be processed internationally the manner described above.

Subject to applicable law and any overiding legal obligations (such as AML record-keeping requirements), you hold the following rights in respect of your personal data held by Koboi89: