Privacy Policy

Introduction

This Privacy Policy ("Policy") is published by Subur88 ("we", "us", "our", "the Platform") and applies to all personal data collected through the Subur88 website at https://subur88.buzz, any associated mobile applications, and all related services provided under the Subur88 brand (collectively, "the Platform").

Subur88 is committed to protecting the privacy and personal data of all users ("you", "your", "the User") who access, register on, or interact with the Platform. This Policy sets out the types of personal data we collect, the purposes for which it is processed, the conditions under which it may be disclosed to third parties, the security measures in place to protect it, and the rights available to you in relation to your data.

This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy, both of which form part of your overall agreement with Subur88.

Definitions

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

• "Personal Data" — Any information that relates to an identified or identifiable natural person, including but not limited to name, date of birth, email address, telephone number, financial account details, and IP address.
• "Processing" — Any operation performed on Personal Data, including collection, recording, storage, use, disclosure, transmission, erasure, or destruction.
• "Data Controller" — Subur88, as the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" — Any third-party entity that processes Personal Data on behalf of Subur88 pursuant to written instructions and under contractual data protection obligations.
• "User" / "Data Subject" — Any natural person who registers an account or otherwise interacts with the Subur88 Platform.
• "Cookies" — Small text files placed on your device by the Platform to facilitate session management, analytics, and personalisation functionality.
• "KYC" — Know Your Customer; the identity verification process applied to Users prior to the processing of withdrawals and at other stages as required by platform policy or regulatory obligation.

Data We Collect

Subur88 collects the following categories of personal data in connection with the operation of the Platform:

How We Collect Your Data

Subur88 collects personal data through the following channels and mechanisms:

• Direct Submission: Data you provide voluntarily when registering an account, completing KYC verification, making deposits or withdrawal requests, or contacting our support team via Live Chat, email, or WhatsApp.
• Automated Technical Collection: Data collected automatically when you access the Platform, including IP address, browser fingerprint, device identifiers, and session activity logs, via server logs and platform analytics systems.
• Cookies and Tracking Technologies: Data collected through cookies, pixel tags, and similar technologies placed on your device during Platform use. Full details are provided in Section 8 (Cookies & Tracking).
• Third-Party Payment Providers: Transaction confirmation data received from payment processors such as Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, and banking institutions (Maybank, CIMB, Public Bank, Hong Leong Bank) in connection with deposit and withdrawal transactions.
• Identity Verification Services: Data received from third-party KYC and identity verification providers used to authenticate your identity against the documents you submit.
• Fraud and AML Screening Services: Data received from third-party screening services used to check for indicators of fraudulent activity, money laundering, or sanctions list matches.

Data Processing & Use

Subur88 processes your personal data for the following specific purposes:

• Account Management: To create, maintain, and manage your registered account, including processing login authentication, updating account details, and facilitating account closure.
• Transaction Processing: To process your deposits and withdrawal requests in Malaysian Ringgit (MYR) through your selected payment method and to maintain accurate financial records of all transactions.
• Identity Verification (KYC): To verify your identity, confirm your age (21+), and satisfy source-of-funds requirements in accordance with anti-money laundering obligations.
• Regulatory Compliance: To fulfil our legal and regulatory obligations, including the retention of transaction records and the reporting of suspicious activity to relevant authorities where legally required.
• Responsible Gambling: To monitor your gaming activity for indicators of problem gambling behaviour and to administer responsible gambling tools including deposit limits, self-exclusion, and session controls.
• Fraud Prevention and Platform Security: To detect, investigate, and prevent fraudulent transactions, account takeovers, and other security threats using technical and behavioural data analysis.
• Customer Support: To respond to your enquiries, resolve disputes, and maintain records of support interactions for quality assurance and compliance purposes.
• Platform Improvement: To analyse aggregated usage data and improve the performance, stability, and user experience of the Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided explicit consent to receive such communications. You may withdraw consent at any time.

Legal Basis for Processing

Subur88 processes your personal data on the following legal grounds:

• Contractual Necessity: Processing that is necessary to perform the contract between you and Subur88 — for example, processing your deposits, withdrawals, and wager transactions.
• Legal Obligation: Processing required to comply with applicable laws and regulatory requirements, including anti-money laundering (AML) obligations, age verification requirements, and record-keeping mandates.
• Legitimate Interests: Processing carried out in pursuit of Subur88's legitimate business interests, such as fraud prevention, platform security, and improving our services, where those interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing based on your explicit consent — primarily in the context of marketing communications and certain optional data collection activities. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Data Sharing & Disclosure

Subur88 does not sell, rent, or trade your personal data. We may share your data in the following limited and controlled circumstances:

• Payment Processors: Financial data necessary to process your transactions is shared with your selected payment provider (e.g., Touch 'n Go eWallet, Boost, Maybank, CIMB, DuitNow, FPX, GrabPay) solely for the purpose of executing the transaction.
• KYC and Identity Verification Providers: Identity documents and verification data may be shared with third-party KYC service providers contracted to assist with identity authentication and age verification.
• Fraud and AML Screening Services: Technical and transactional data may be shared with screening service providers to support our anti-fraud and anti-money laundering obligations.
• Game Content Providers: Certain usage and session data may be shared with licensed game providers whose content is hosted on the Platform, solely for the purpose of delivering a stable and personalised gaming experience.
• Legal and Regulatory Authorities: We may disclose personal data to law enforcement, regulatory bodies, or other government agencies where required to do so by applicable law, court order, or binding regulatory directive.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of Subur88's business assets, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

Cookies & Tracking Technologies

Subur88 uses cookies and similar tracking technologies to operate the Platform effectively and to enhance your user experience. Cookies are small text files stored on your device that allow the Platform to recognise your browser or device during a session and across future visits.

We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These enable core features such as login session management, security validation, and shopping cart / cashier functionality. These cookies cannot be disabled without significantly impairing Platform functionality.
• Functional Cookies: Used to remember your preferences such as language settings, display preferences, and previously entered form data, to provide a more personalised experience.
• Analytical Cookies: Used to collect aggregated, anonymised data about how users interact with the Platform — including pages visited, session duration, and navigation paths — to help us improve Platform performance and content.
• Security Cookies: Used to detect and prevent fraudulent activity, bot access, and account takeover attempts by analysing behavioural patterns and device fingerprints.

You may manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform. Strictly necessary cookies cannot be disabled as they are fundamental to the operation of the service.

Data Retention

Subur88 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following general retention periods apply:

• Active Account Data: Retained for the duration of your account's active status and for a minimum period of five (5) years following account closure, in accordance with anti-money laundering record-keeping requirements.
• Transaction Records: Financial transaction records are retained for a minimum of seven (7) years following the transaction date to satisfy statutory accounting and AML obligations.
• KYC Verification Documents: Identity documents and verification records are retained for the duration of the account relationship and for a period of five (5) years following account closure.
• Support and Communication Records: Customer support correspondence and Live Chat transcripts are retained for a period of three (3) years following the close of the relevant support interaction.
• Marketing Preference Data: Retained until you withdraw your consent to receive marketing communications, at which point it will be deleted or anonymised within a reasonable operational timeframe.

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

Data Security

Subur88 has implemented a comprehensive suite of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• Transport Layer Security (TLS/SSL): All data transmitted between your device and the Subur88 Platform is encrypted using 256-bit SSL/TLS encryption, preventing interception during transmission.
• Access Controls: Access to personal data within Subur88's systems is restricted on a need-to-know basis. Employees are granted the minimum level of data access required to perform their role, and all access is logged and audited.
• Two-Factor Authentication (2FA): Optional 2FA is available to all registered users to provide an additional layer of account security beyond the standard password.
• Intrusion Detection Systems: The Platform employs automated intrusion detection and real-time security monitoring systems to identify and respond to security threats promptly.
• Data Pseudonymisation: Where operationally feasible, personal data used for analytical and internal reporting purposes is pseudonymised to reduce privacy risk.
• Regular Security Audits: The Platform undergoes regular security assessments and penetration testing conducted by qualified security professionals to identify and remediate vulnerabilities.

Your Rights

Subject to applicable law, you have the following rights in relation to the personal data that Subur88 holds about you. To exercise any of these rights, please contact our support team using the details provided in Section 15.

Subur88 will respond to verified data rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, of which you will be notified. Please note that certain rights may be limited where Subur88 is required to retain data to comply with legal obligations, including AML and KYC record-keeping requirements.

Children & Minors

The Subur88 Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. The Platform employs age verification measures at registration and during the KYC process to prevent access by minors.

If Subur88 becomes aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete such data and close the associated account. Any balances, wagers, or winnings in such an account will be forfeited.

Third-Party Services & Links

The Subur88 Platform may display information about or references to payment providers, game content providers, and other third-party services. Subur88 is not responsible for the privacy practices, content, or data handling of any third-party service provider, platform, or linked resource that is not under the direct operational control of Subur88.

When you interact with a third-party payment provider — such as Touch 'n Go eWallet, Boost, GrabPay, or your banking institution — the collection and processing of your data during that interaction is governed by that provider's own privacy policy. Subur88 recommends that you review the privacy policies of all third-party services you engage with in connection with your use of our Platform.

Game content provided by third-party licensed game studios may involve the transmission of session and gameplay data to those studios for the purpose of delivering the game. Such data sharing is governed by contractual data processing agreements and limited strictly to what is necessary for game delivery.

Policy Amendments

Subur88 reserves the right to update or amend this Privacy Policy at any time. Changes may be made to reflect developments in our data processing practices, changes in applicable law, or improvements to our platform services.

When material changes are made to this Policy, Subur88 will notify registered Users by posting a prominent notice on the Platform or by sending a notification to your registered email address prior to the change taking effect. The "Last Updated" date displayed at the top of this page will be revised accordingly.

Your continued use of the Subur88 Platform following notification of any changes to this Privacy Policy constitutes your acceptance of those changes. If you do not agree to the revised Policy, you must stop using the Platform and may request account closure through our support team.

We encourage you to review this Privacy Policy periodically to remain informed of how Subur88 protects your personal data and what rights are available to you.

Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by Subur88, please contact our Data Protection team through any of the following channels:

• Email: [email protected] — Please use the subject line "Privacy Policy Enquiry" or "Data Rights Request" for efficient routing. We aim to acknowledge all privacy-related email enquiries within 48 hours and to provide a substantive response within 30 days.
• Live Chat: Available 24 hours a day, 7 days a week, directly on the Platform. Our multilingual support team can assist with general privacy queries in English, Bahasa Melayu, and Chinese.
• WhatsApp: Available 24/7. Contact details are accessible within your registered account portal after login.

For formal data rights requests (access, rectification, erasure, restriction, portability, or objection), please submit your request in writing via email to ensure a clear and auditable record. Include your registered username and a description of your specific request.