Borneo338 Privacy Policy

This Privacy Policy ("Policy") is issued by Borneo338 ("the Platform", "we", "us", "our") and applies to all personal data collected and processed in connection with your use of the Borneo338 website, mobile platform, and associated services accessible at the domain borneo338.cam.

Borneo338 is committed to protecting the privacy and personal data of every registered member and website visitor. We process personal data responsibly, in accordance with applicable data protection legislation, and only for the purposes described in this Policy.

By registering an account on Borneo338, depositing funds, or continuing to access and use our platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

For the purposes of this Policy, the following definitions apply:

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, identification number, contact details, financial data, and online identifiers.
• "Data Subject" — the individual to whom the Personal Data relates; in the context of this Policy, primarily you as a registered member or visitor of Borneo338.
• "Data Controller" — Borneo338, which determines the purposes and means of processing Personal Data collected through the platform.
• "Data Processor" — a third party that processes Personal Data on behalf of Borneo338 under a contractual arrangement and subject to data protection obligations.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, disclosure, alteration, or deletion.
• "KYC Data" — identity verification documents submitted as part of the Know Your Customer process, including copies of the Malaysian MyKad and supporting address evidence.

Borneo338 collects personal data through multiple touchpoints during the account lifecycle. The categories of data collected and the context in which they arise are detailed below.

3.1 Registration Data

When you create a Borneo338 account, we collect the information you voluntarily provide during registration, including your full legal name, date of birth, gender, residential address, email address, and mobile phone number.

3.2 Identity Verification (KYC) Data

As part of our compliance obligations, we may collect copies of government-issued identification documents (including the Malaysian MyKad, passport, or equivalent), proof of residential address (such as a utility bill or bank statement from a Malaysian financial institution), and, where applicable, documentation confirming ownership of payment methods used for deposits.

3.3 Financial & Transaction Data

We collect records of all financial transactions conducted through your Borneo338 account, including deposit amounts, withdrawal requests, gaming transaction history, bonus credits and usage, and payment method details (such as the masked account number associated with your Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, or DuitNow accounts).

3.4 Gameplay & Betting Data

We collect data relating to your gaming and betting activity on the platform, including the games accessed, wagers placed, odds accepted, session durations, responsible gambling tool usage, and outcomes. This data is used for account administration, fraud detection, and to personalise your experience where consent has been provided.

3.5 Technical & Device Data

When you access Borneo338, our systems automatically collect technical data including your IP address, device type and operating system, browser version, access timestamps, session duration, and general geographic location derived from IP geolocation (city and country level — not precise GPS coordinates unless separately consented to).

3.6 Communication Data

Where you contact our support team via live chat or email, we retain records of those communications for service quality, compliance, and dispute resolution purposes. Email content sent to [email protected] is stored for a minimum of 12 months.

Borneo338 processes your personal data on one or more of the following legal bases, depending on the category of data and the purpose of processing:

• Contractual Necessity: Processing required to perform our contractual obligations to you as a registered member — including account management, payment processing, and gameplay facilitation.
• Legal Obligation: Processing required to comply with applicable laws, including anti-money laundering (AML) obligations, age verification requirements, and financial reporting duties.
• Legitimate Interests: Processing for fraud prevention, platform security, service improvement, and responsible gambling monitoring — where these interests are not overridden by your fundamental rights.
• Consent: Processing for optional communications such as promotional emails or personalised offers — only where you have given explicit consent. Consent may be withdrawn at any time without affecting lawfulness of prior processing.

Borneo338 uses the personal data it collects for the following specific purposes. We do not process your data for any purpose that is incompatible with those listed below without first obtaining your explicit consent.

• Account Administration: Creating, maintaining, and managing your Member Account, including processing deposits, withdrawals, and managing your account balance in MYR.
• Identity Verification (KYC): Verifying your identity and age (21+ requirement) prior to processing withdrawal requests and as required by our compliance framework.
• Payment Processing: Facilitating deposits and withdrawals via your selected Malaysian payment method (Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong, USDT TRC20).
• Fraud Prevention & Security: Monitoring transactions, login patterns, and gameplay activity to detect and prevent fraud, money laundering, and unauthorised account access.
• Responsible Gambling: Monitoring gameplay patterns to identify signs of problematic gambling behaviour and, where appropriate, proactively offering responsible gambling tools or support referrals.
• Customer Support: Responding to your queries, complaints, and support requests submitted via live chat or email.
• Legal & Regulatory Compliance: Meeting our obligations under applicable anti-money laundering, age verification, and financial reporting laws.
• Marketing Communications (with consent only): Sending promotional offers, bonus notifications, and relevant gaming updates where you have opted in. You may opt out at any time.

Borneo338 does not sell personal data to third parties. We share personal data only in the limited circumstances described below, and solely to the extent necessary for the stated purpose.

6.1 Payment Service Providers

We share relevant transaction and identity data with our payment processing partners — including the operators of Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, and the relevant Malaysian banks — to process your deposits and withdrawals securely. These providers operate under their own privacy policies and regulatory obligations.

6.2 Identity Verification Partners

KYC document verification may be conducted through a third-party identity verification service. Such providers are contractually bound to process your documents solely for the purpose of identity verification and to maintain equivalent data security standards.

6.3 Fraud Prevention & Compliance

We may share data with fraud prevention agencies, financial intelligence units, or regulatory authorities where required to investigate suspected fraud, money laundering, or other illegal activity. Such disclosures may be made without prior notice to you where legally required.

6.4 Legal Requirements

We may disclose personal data in response to a valid court order, subpoena, or regulatory directive, or where disclosure is necessary to protect the rights, property, or safety of Borneo338, its members, or the public.

Borneo338 retains personal data for the minimum period necessary to fulfil the purpose for which it was collected, and to meet any applicable legal retention requirements. The following indicative retention periods apply:

Upon expiry of the applicable retention period, personal data will be securely deleted or irreversibly anonymised. Data required to be retained beyond these periods due to a legal hold or ongoing investigation will be kept only for as long as the hold remains in place.

Borneo338 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include but are not limited to:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and Borneo338 servers is encrypted in transit using industry-standard SSL/TLS protocols.
• Encryption at Rest: Sensitive personal data stored on our servers, including KYC documents and financial records, is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorised personnel on a strict need-to-know basis. All internal access is logged and audited.
• Two-Factor Authentication: Two-factor authentication (2FA) is available and encouraged for all Borneo338 Member Accounts to prevent unauthorised login.
• Fraud Monitoring: Continuous automated monitoring of transactions and login activity to detect and respond to anomalous patterns indicative of fraud or account compromise.
• Incident Response: A documented data breach response procedure is in place. Affected data subjects will be notified promptly in the event of a breach that poses a material risk to their rights or interests.

Whilst Borneo338 takes all reasonable steps to protect your personal data, no internet transmission or digital storage system is completely impenetrable. You are responsible for keeping your account credentials secure and for notifying us immediately if you suspect any compromise.

The Borneo338 website uses cookies and similar tracking technologies to ensure the platform functions correctly, to improve performance, and — where consent has been provided — to personalise your experience.

9.1 Types of Cookies Used

• Strictly Necessary Cookies: Required for the platform to function. These cannot be disabled and include session authentication tokens and security cookies. No consent is required for these.
• Performance Cookies: Collect anonymised data on how users interact with the platform (pages visited, load times, errors encountered) to help us identify areas for improvement.
• Functional Cookies: Remember your preferences such as language settings, currency display, and responsible gambling tool configurations.
• Marketing Cookies (consent only): Used to deliver relevant promotional content. Activated only where you have provided explicit consent at account registration or through your cookie preference settings.

Subject to applicable law, you hold the following rights with respect to your personal data held by Borneo338. To exercise any of these rights, please contact our Data Protection team at [email protected] with the subject line "Data Rights Request". We will acknowledge your request within 7 calendar days and respond in full within 30 calendar days.

• Right to Access: You may request a copy of all personal data we hold about you, along with information about how it is processed.
• Right to Rectification: You may request that inaccurate or incomplete personal data be corrected. Account details such as your registered email address can also be updated via your account settings.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of personal data we hold about you, subject to our legal retention obligations. Requests will be evaluated on a case-by-case basis.
• Right to Restrict Processing: You may request that we limit processing of your data in certain circumstances, for example while the accuracy of data is disputed.
• Right to Data Portability: Where processing is based on consent or contract, you may request that your personal data be provided to you in a structured, commonly used, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests grounds, including processing for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based solely on your consent, you may withdraw that consent at any time without prejudice to any processing already carried out on that basis.

Borneo338 is strictly an adult platform. Access to real-money gaming services is limited to individuals who are 21 years of age or older. We do not knowingly collect or process personal data from persons under the age of 21.

Age verification is a mandatory step in the account registration and KYC process. Where we become aware that personal data has been collected from a person under the minimum age, the associated account will be closed immediately, all data will be securely deleted, and any funds held in the account will be returned to the original deposit source.

In the course of providing services to Malaysian players, Borneo338 may transfer certain personal data to service providers and partners located outside Malaysia. This may include cloud infrastructure providers, fraud detection services, and game content providers whose servers are located in other jurisdictions.

Where such transfers occur, Borneo338 ensures that appropriate safeguards are in place — including contractual clauses that require the recipient to maintain data protection standards equivalent to those we apply — to protect your personal data from unauthorised access or misuse in the destination jurisdiction.

Data transfers to Malaysian payment partners — including the operators of Touch 'n Go eWallet, Boost, GrabPay, DuitNow, Maybank, CIMB, and Public Bank — remain within Malaysia and are subject to domestic financial data protection requirements applicable to licensed Malaysian financial service providers.

Borneo338 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform functionality. The updated Policy will be published on this page with a revised effective date.

Where a material change is made to the Policy — for example, the introduction of a new purpose for processing or a change in data sharing arrangements — we will notify registered members via the email address associated with their account prior to the change taking effect, and provide a reasonable opportunity to review the update.

Continued use of the Borneo338 platform following publication of an updated Privacy Policy constitutes acceptance of the revised terms. We encourage you to review this page periodically to remain informed of how your data is being handled.

If you have any questions, concerns, or requests in connection with this Privacy Policy or the handling of your personal data by Borneo338, please contact us using the details below. We are committed to responding to all privacy-related enquiries within 7 business days.

• Email: [email protected] — please use the subject line "Privacy Enquiry" or "Data Rights Request"
• Live Chat: Available 24/7 via the chat widget on any Borneo338 page — use the keyword "privacy" or "data request" for routing to our data team
• Response Time: Privacy enquiries acknowledged within 7 calendar days; substantive responses provided within 30 calendar days as required