Privacy Policy

1 Introduction

This Privacy Policy ("Policy") is published by Starbuck88 ("we", "us", "our", "the Platform"), the operator of the online gaming platform accessible at starbuck88.cam. This Policy governs how Starbuck88 collects, uses, stores, discloses, and otherwise processes personal data in connection with your use of our platform and services.

Starbuck88 operates as an international online gaming platform serving players primarily based in Malaysia, providing sports betting, live casino, slot games, and related gambling services. We are committed to handling all personal data with transparency, integrity, and respect for your privacy rights.

This Policy applies to all registered players, prospective players who browse the Platform without registering, and any other individuals whose personal data we process in the course of our operations. By accessing or using Starbuck88, you acknowledge that you have read and understood this Policy and consent to the data practices described herein.

If you have any questions about how we process your data, please contact our support team via live chat (available after logging in to your account) or by email at [email protected].

2 Definitions

In this Policy, the following terms carry the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, identification number, contact details, financial information, device identifiers, and IP address.
• "Processing" means any operation performed on Personal Data, whether by automated means or otherwise, including collection, recording, storage, use, disclosure, erasure, or destruction.
• "Controller" means the entity that determines the purposes and means of processing Personal Data — in this context, Starbuck88.
• "Data Subject" means the individual to whom Personal Data relates — in this context, the registered player or platform visitor.
• "Third Party" means any natural or legal person other than the Data Subject, Starbuck88, and its directly authorised data processors.
• "KYC" means Know Your Customer — the identity and age verification procedures applied to registered players prior to withdrawal processing.
• "AML" means Anti-Money Laundering — regulatory and procedural obligations to detect and prevent the use of the Platform for money laundering or terrorist financing.
• "Cookies" means small data files stored on a user's device by the Platform's web server to enable session management, preference storage, and analytics.

3 Data We Collect

Starbuck88 collects the following categories of personal data, depending on how you interact with the Platform:

3.1 Registration Data

When you create an account, we collect your full legal name, date of birth, residential address (including city and postcode — relevant for players in Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam, and other Malaysian cities), email address, and chosen username. This information is necessary to establish your account and verify your eligibility to use the Platform.

3.2 Identity Verification (KYC) Data

To comply with our licensing obligations and to process withdrawal requests, we collect copies of government-issued photo identification (Malaysian MyKad, Driver's Licence, or Passport), proof of residential address (utility bill or bank statement within three months), and, where required, a selfie with the identity document. This data is processed solely for age and identity verification purposes.

3.3 Financial and Transaction Data

We collect transaction records associated with your account, including deposit and withdrawal amounts, payment method reference identifiers, timestamps, and currency values in Malaysian Ringgit (MYR). For FPX transfers via Maybank, CIMB, Public Bank, or Hong Leong, we retain payment reference numbers but do not store full bank account credentials. For e-wallet transactions via Touch 'n Go eWallet, Boost, or GrabPay, we store transaction reference IDs provided by the respective payment processors. For cryptocurrency transactions (Bitcoin, Ethereum, USDT TRC20), we retain wallet address references and blockchain transaction hashes.

3.4 Gaming and Betting Activity Data

We collect records of your gaming and betting activity on the Platform, including game sessions, wager amounts, outcomes, sports betting selections (including bets placed on Liga Super Malaysia, EPL, and other competitions), and bonus usage. This data is used for account management, dispute resolution, responsible gambling monitoring, and regulatory compliance.

3.5 Technical and Device Data

When you access the Platform, we automatically collect your IP address, browser type and version, operating system, device type, screen resolution, referring URL, and session timestamps. This data is used for fraud detection, security monitoring, and platform performance optimisation.

3.6 Communications Data

If you contact our support team via live chat, WhatsApp, or email, we retain a record of the communication, including the channel used, timestamps, the content of your enquiry, and the resolution provided. Communications are retained for quality assurance, training, and dispute resolution purposes.

4 How We Collect Your Data

We collect personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal request, place a bet, contact customer support, or respond to a survey or promotion.
• Automatically — through cookies, web beacons, and server logs when you browse or interact with the Platform, as described in Section 10.
• From payment processors — when you initiate a transaction via FPX, DuitNow, Touch 'n Go eWallet, Boost, GrabPay, or a cryptocurrency network, the relevant processor shares transaction reference data with us to confirm and record your payment.
• From identity verification services — where we engage third-party KYC service providers to assist with document verification, those providers may share verification outcomes and associated data with us.
• From fraud prevention and AML screening services — we may receive risk signals and screening outcomes from third-party providers engaged to help us meet our AML and fraud prevention obligations.

5 Purposes of Data Processing

Starbuck88 processes your personal data for the following specific purposes:

Starbuck88 does not use your personal data for automated individual decision-making that produces legally significant effects, except as required for fraud prevention and AML screening where human review is applied to flagged cases.

6 Legal Basis for Processing

Starbuck88 processes your personal data on the following legal bases, as applicable to each processing activity:

• Contract performance: Processing necessary to create and manage your account, process deposits and withdrawals, and deliver the gaming services you have requested.
• Legal obligation: Processing required to comply with our KYC, AML, and responsible gambling obligations under the terms of our international gaming licence.
• Legitimate interests: Processing for fraud detection, platform security, and responsible gambling monitoring, where our interests in maintaining platform integrity do not override your rights and freedoms.
• Consent: Processing for direct marketing communications, where we have obtained your explicit opt-in consent. You may withdraw consent for marketing at any time by contacting our support team.

7 Data Sharing & Disclosure

Starbuck88 does not sell, rent, or otherwise trade your personal data to third parties for their commercial purposes. We share personal data with third parties only in the following limited circumstances:

7.1 Service Providers and Data Processors

We engage selected third-party service providers to assist in operating the Platform, including payment processing partners (FPX network operators, e-wallet providers including Touch 'n Go, Boost, and GrabPay, and cryptocurrency payment processors), KYC and identity verification service providers, AML and fraud screening providers, and cloud hosting and infrastructure providers. All service providers are contractually bound to process personal data only on our instructions, to maintain appropriate security measures, and not to use data for their own purposes.

7.2 Gaming Software Providers

Certain gaming activity data — specifically game session logs — may be shared with our third-party game software providers for the purpose of game performance verification, dispute resolution, and RNG audit compliance. These providers receive anonymised or pseudonymised data wherever practicable.

7.3 Legal and Regulatory Disclosure

We may disclose personal data to our licensing authority, law enforcement agencies, regulatory bodies, or courts where we are legally obliged to do so, or where disclosure is necessary to protect the rights, property, or safety of Starbuck88, our players, or the public.

7.4 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of Starbuck88's assets, personal data held on player accounts may be transferred to the acquiring entity, subject to that entity assuming the privacy obligations described in this Policy.

8 International Data Transfers

As an international online gaming platform, Starbuck88 may transfer personal data to, and process it in, countries outside Malaysia. This includes transfers to our licensing jurisdiction and to the countries where our service providers operate their data processing infrastructure.

Where personal data is transferred internationally, Starbuck88 takes steps to ensure that adequate protections are in place, including contractual data protection obligations consistent with internationally recognised standards. By using Starbuck88, you acknowledge and consent to the transfer of your personal data outside Malaysia for the purposes described in this Policy.

9 Data Retention

Starbuck88 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and our licensing obligations. Specific retention guidelines are as follows:

• Active account data: Retained for the duration of the account's active status plus a minimum of five years following account closure, in line with AML record-keeping requirements under international gaming licence conditions.
• KYC documentation: Retained for a minimum of five years from the date of verification or the date of account closure, whichever is later.
• Transaction records: Retained for a minimum of five years from the date of each transaction.
• Customer support communications: Retained for a minimum of three years from the date of the interaction.
• Technical and device logs: Retained for a maximum of 12 months in rolling format, unless a specific security or fraud investigation requires extended retention.

Following the expiry of the applicable retention period, personal data is securely deleted or permanently anonymised.

10 Cookies & Tracking Technologies

Starbuck88 uses cookies and similar tracking technologies on the Platform. Cookies are small text files stored on your device by your web browser at the instruction of the Platform's server.

10.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the operation of the Platform, including maintaining your login session, preserving your in-game state, and enabling secure transactions. These cookies cannot be disabled without preventing core Platform functionality.
• Performance and Analytics Cookies: Used to collect anonymised data about how players navigate and use the Platform, enabling us to identify bottlenecks, measure load times, and improve user experience. These do not track you across external websites.
• Fraud Prevention Cookies: Help our security systems identify suspicious activity patterns, such as account takeover attempts or automated bot behaviour, by maintaining a device fingerprint reference during your session.

10.2 Cookie Management

You may control or restrict the use of cookies through your browser settings. However, please note that disabling strictly necessary cookies will prevent you from using core Platform features, including logging in and placing bets. Instructions for managing cookies are available through your browser's help documentation.

11 Your Data Rights

Subject to applicable law and the requirements of our licensing obligations, you have the following rights in relation to your personal data held by Starbuck88:

To exercise any of the rights above, please contact our support team via live chat after logging in to your account, or by email to [email protected]. We will respond to verified requests within 30 days. Identity verification will be required before any personal data is disclosed or modified.

12 Children & Minors

Starbuck88 is an adult online gaming platform strictly for individuals aged 21 years and above. We do not knowingly collect personal data from anyone under the age of 21. Age verification is a mandatory step in the KYC process, and we reserve the right to request proof of age from any player at any time.

If we become aware that personal data has been collected from a player who is under 21, we will immediately suspend that account, void any associated transactions, and delete the personal data collected, subject only to any mandatory retention obligations that may apply.

Parents or guardians who believe that a minor may have registered on the Platform using false age information should contact our support team immediately via live chat or at [email protected].

13 Security Measures

Starbuck88 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers — the same standard used by major Malaysian banking portals including Maybank2u and CIMB Clicks.
• Access controls ensuring that personal data is accessible only to authorised personnel who require it for defined operational purposes.
• Regular security assessments, penetration testing, and vulnerability scanning of the Platform's infrastructure.
• Segregation of player fund accounts from operational accounts to protect financial data integrity.
• Fraud detection monitoring systems operating in real-time to identify and respond to suspicious access attempts or transaction patterns.

In the event of a personal data breach that is likely to pose a risk to your rights and freedoms, Starbuck88 will take prompt remediation steps and notify affected individuals in accordance with our obligations under applicable data protection frameworks.

14 Changes to This Privacy Policy

Starbuck88 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or Platform functionality. Where changes are material, we will endeavour to notify registered players via the Platform interface or by email to the address associated with your account.

The current version of this Policy, together with the date of last update, is always accessible at starbuck88.cam/privacy-policy. Your continued use of the Platform following the effective date of any amendment constitutes acceptance of the revised Policy. We encourage you to review this page periodically.

15 Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by Starbuck88, please contact us through the following channels:

• Live Chat (preferred): Available 24 hours a day, 7 days a week after logging in to your account. Agents are available in English, Bahasa Melayu, and Mandarin. Average response time: 3–5 minutes.
• Email: [email protected] — for non-urgent data rights requests and general privacy enquiries. Response within 2–4 business hours.

When submitting a data rights request, please state clearly: (a) the nature of your request; (b) the specific data or processing activity it relates to; and (c) your registered account email address, so that we may verify your identity and respond appropriately.