Privacy Policy

1. Introduction

Super88 (hereinafter referred to as "Super88", "we", "us", or "our") operates the online gaming and sports betting platform accessible at https://super88.cam. We are committed to protecting the privacy and personal data of all individuals who use our platform (hereinafter referred to as "you", "the User", or "the Player").

This Privacy Policy sets out the manner in which Super88 collects, processes, stores, discloses, and protects personal data in connection with your use of the Platform. It has been prepared in accordance with applicable data protection principles and our obligations as an internationally licensed online gaming operator serving players across Malaysia, including Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, and Shah Alam.

By registering an Account on the Super88 Platform, you confirm that you have read this Privacy Policy, that you understand how your personal data will be processed, and that you consent to such processing where consent is the applicable legal basis. If you do not agree with any part of this Privacy Policy, you must not create an Account or continue using the Platform.

This Privacy Policy should be read in conjunction with our Terms & Conditions, which govern your use of the Platform more broadly. In the event of any inconsistency between these documents regarding data matters, this Privacy Policy shall prevail.

2. Definitions

The following defined terms are used throughout this Privacy Policy:

"Personal Data"

Any information that relates to an identified or identifiable natural person. This includes, but is not limited to, name, identification number, contact details, financial information, and online identifiers such as IP addresses and cookie identifiers.

"Processing"

Any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, transmission, erasure, or destruction, whether or not carried out by automated means.

"Data Controller"

Super88, as the entity that determines the purposes and means of the processing of your Personal Data collected through the Platform.

"Data Processor"

Any third-party service provider that processes Personal Data on behalf of Super88 pursuant to a written data processing agreement, including payment processors and KYC verification service providers.

"KYC Data"

Identity and address verification documents submitted by Players in accordance with Super88's Know Your Customer procedures, including but not limited to copies of the Malaysian IC (MyKad), passport, driver's licence, and proof of address documentation.

"Cookies"

Small text files placed on your device by the Platform that store session or preference information to improve your browsing experience and enable core platform functionality.

3. Data We Collect

Super88 collects the following categories of Personal Data from Players and Platform visitors:

Category	Examples	When Collected
Identity Data	Full name, date of birth, nationality, gender, Malaysian IC / Passport number	At registration and KYC verification
Contact Data	Email address, mobile phone number, residential address	At registration; updated by the Player
Financial Data	Payment method details (e-wallet IDs, bank account numbers), transaction history, deposit and withdrawal records in MYR	When deposits or withdrawals are initiated
KYC Documents	Scanned copies of MyKad, passport, driver's licence; proof of address; selfie photographs with ID	During KYC verification process
Technical Data	IP address, browser type and version, device type, operating system, session timestamps	Automatically upon Platform access
Usage Data	Pages visited, games played, bets placed, bet amounts, game session duration, features accessed	Continuously during Platform use
Communication Data	Records of live chat transcripts, support emails, and any other written correspondence with Super88	When you contact support
Marketing Preferences	Consent status for promotional communications, communication channel preferences	At registration or as updated

Super88 does not collect special categories of sensitive personal data (e.g., health information, racial or ethnic origin, political opinions, religious beliefs) unless required by specific regulatory obligations. Responsible gambling self-assessments are treated as confidential and used solely for player protection purposes.

4. How Personal Data Is Collected

Super88 collects Personal Data through the following means:

Directly from you: When you complete the registration form, submit KYC documents, make a deposit or withdrawal request, contact customer support, or update your Account profile.
Automatically: Technical and Usage Data is collected automatically via server logs, cookies, and similar technologies when you access or interact with the Platform. This data does not require any active input from you.
From third-party payment processors: When you initiate a deposit or withdrawal via Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, or any other supported payment method, your payment provider shares transaction confirmation data with Super88 to credit your Account or process your payout.
From identity verification service providers: Super88 may use regulated third-party KYC verification providers to assist in validating the identity documents you submit. These providers process your data strictly under Super88's instructions and in accordance with data processing agreements.
From fraud prevention and AML screening services: Super88 may check your details against publicly available watchlists, sanctions databases, and politically exposed persons (PEP) registers for anti-money laundering compliance purposes.

5. Data Processing & Use

Super88 processes your Personal Data for the following purposes:

Account management: To create, maintain, and administer your Super88 Account, verify your identity at registration and login, and communicate account-related notifications to you.
Service delivery: To provide you with access to the gaming and sports betting services available on the Platform, to process your bets, and to calculate and credit winnings to your Account balance.
Payment processing: To process deposits and withdrawals in Malaysian Ringgit (MYR) via your chosen payment method, to verify payment source ownership, and to maintain accurate transaction records.
KYC and regulatory compliance: To verify your identity and age (21+), comply with anti-money laundering (AML) and counter-terrorism financing (CTF) obligations, and report to regulatory authorities where legally required.
Responsible gambling: To monitor gaming patterns for signs of problem gambling behaviour, to facilitate the implementation of deposit limits, session time reminders, cool-off periods, and self-exclusion requests, and to contact Players at risk where appropriate.
Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, account takeovers, bonus abuse, and other prohibited conduct on the Platform.
Platform improvement: To analyse Usage Data and player feedback in order to improve Platform performance, fix technical issues, and develop new features and game offerings.
Marketing communications: Where you have provided explicit consent, to send you promotional offers, bonus notifications, and updates about new games or features. You may withdraw marketing consent at any time.
Legal and dispute resolution: To respond to legal requests from competent authorities, to defend Super88 in legal proceedings, and to resolve disputes raised by Players in accordance with our Terms & Conditions.

6. Legal Basis for Processing

Super88 processes your Personal Data on the following legal bases, depending on the purpose of processing:

Contractual necessity: Processing required to perform the contract between Super88 and you — including Account registration, payment processing, and service delivery — is carried out on the basis that it is necessary for the performance of our agreement.
Legal obligation: Processing required for KYC verification, AML/CTF compliance, record-keeping, and reporting to regulatory authorities is carried out on the basis of Super88's legal obligations under applicable laws and licensing conditions.
Legitimate interests: Processing carried out for fraud prevention, platform security, responsible gambling monitoring, and service improvement is conducted on the basis of Super88's legitimate interests, provided those interests are not overridden by your rights and interests.
Consent: Processing for marketing communications is conducted solely on the basis of your explicit, freely given consent. Where consent is the legal basis, you have the right to withdraw it at any time without penalty.

7. Data Sharing & Disclosure

Super88 does not sell, rent, or trade your Personal Data to third parties for commercial purposes. Personal Data is disclosed only in the following limited circumstances:

Payment processors: Transaction data is shared with your selected payment provider (e.g., Touch 'n Go eWallet, Boost, GrabPay, DuitNow/FPX, Maybank, CIMB, Public Bank, USDT TRC20 processors) solely to the extent necessary to process your deposit or withdrawal request.
KYC and identity verification providers: Where Super88 engages regulated third-party providers to assist with identity verification, your KYC documents are shared with those providers under strict data processing agreements that prohibit any secondary use.
Fraud prevention and AML screening services: Relevant data may be shared with licensed fraud detection and financial crime screening services to fulfil Super88's compliance obligations.
Game software providers: Limited usage data (such as session IDs and game outcomes) is shared with licensed game content providers to facilitate game delivery and resolve game disputes. No personally identifiable information beyond what is technically necessary is shared.
Legal and regulatory authorities: Super88 will disclose Personal Data to law enforcement agencies, regulators, or courts where required to do so by applicable law, court order, or regulatory directive — and only to the extent required.
Professional advisers: Super88 may share data with its legal advisers, auditors, or accountants in connection with specific professional services, subject to confidentiality obligations.
Business transfers: In the event of a merger, acquisition, or sale of all or a material part of Super88's business assets, Player data may be transferred to the acquirer, subject to the same privacy protections described in this Policy.

Our commitment: All third parties with whom Super88 shares Personal Data are contractually bound to handle that data in accordance with applicable privacy laws and Super88's data protection standards. Super88 remains responsible for ensuring appropriate safeguards are in place.

8. Data Retention

Super88 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 or regulatory obligations. The following general retention periods apply:

Data Category	Retention Period	Basis
Account & Identity Data	Duration of Account + 5 years post-closure	AML / legal obligation
KYC Documents	Duration of Account + 5 years post-closure	AML / regulatory compliance
Transaction Records	Duration of Account + 7 years post-closure	Financial record-keeping obligation
Game & Betting Logs	Duration of Account + 3 years post-closure	Dispute resolution / legitimate interest
Support Communications	3 years from last interaction	Dispute resolution / legitimate interest
Marketing Consent Records	Until consent is withdrawn + 1 year	Consent / legal obligation
Technical / Log Data	13 months from collection	Platform security / legitimate interest

Upon expiry of the applicable retention period, Personal Data will be securely deleted or irreversibly anonymised. Where data is anonymised rather than deleted, it may be retained for statistical and analytical purposes without any ongoing privacy obligation.

9. Security Measures

Super88 implements appropriate technical and organisational security measures designed to protect your Personal Data against accidental loss, unauthorised access, alteration, disclosure, or destruction. These measures include, but are not limited to:

256-bit SSL/TLS encryption for all data transmitted between your device and Super88 servers.
Encrypted data storage for sensitive information including KYC documents and financial data, using AES-256 encryption at rest.
Access controls: Internal access to Personal Data is restricted on a strict need-to-know basis. Staff with data access are subject to confidentiality obligations and regular security training.
Two-factor authentication (2FA) available for all Player Accounts and mandatory for internal administrative access.
Regular penetration testing and third-party security audits conducted by independent cybersecurity firms.
Intrusion detection and monitoring systems to identify and respond to security incidents in real time.
Data breach response procedures: In the event of a confirmed data breach that poses a risk to your rights, Super88 will notify affected Players without undue delay and take all appropriate remedial action.

Your responsibility: While Super88 takes extensive measures to secure the Platform, you are also responsible for maintaining the security of your Account credentials. Never share your password with anyone. Super88 will never ask for your password by email or live chat. Enable 2FA for an additional layer of Account protection.

10. Cookies & Tracking Technologies

Super88 uses cookies and similar tracking technologies to operate core Platform functionality, analyse usage patterns, and improve the player experience. The following categories of cookies are used:

Strictly Necessary Cookies

Essential for the Platform to function. These include session authentication cookies, load-balancing cookies, and security cookies. These cannot be disabled without impairing Platform functionality.

Performance & Analytics Cookies

Used to collect aggregated, anonymised data about how Players use the Platform — which pages are visited, how long sessions last, and which features are most used. This data is used solely to improve Platform performance and content.

Functionality Cookies

Store your Platform preferences such as language settings, display preferences, and remembered login details (if you have enabled this option). These improve your experience on return visits.

Super88 does not use third-party advertising cookies, retargeting pixels, or cross-site behavioural tracking technologies. You may manage or delete cookies through your browser settings at any time. Note that disabling strictly necessary cookies may result in degraded Platform functionality or loss of session continuity.

11. Your Data Rights

Subject to applicable law and certain limited exceptions (such as where data must be retained for legal compliance purposes), you hold the following rights in respect of your Personal Data held by Super88:

Right of Access: You have the right to request a copy of the Personal Data Super88 holds about you, together with information about how that data is processed. We aim to respond to access requests within 14 business days.
Right of Rectification: If any Personal Data held about you is inaccurate or incomplete, you have the right to request that it be corrected. You may update certain Account details directly within your Account settings without contacting support.
Right to Erasure ("Right to Be Forgotten"): You may request that Super88 delete your Personal Data. This right is subject to limitations — for example, where retention is required by AML legislation or where the data is needed to resolve a pending dispute. Super88 will inform you of any applicable limitations at the time of your request.
Right to Restrict Processing: You may request that Super88 restrict the processing of your data in certain circumstances — for example, while a dispute about data accuracy is being resolved, or where you have objected to processing pending verification of Super88's legitimate grounds.
Right to Data Portability: Where processing is based on consent or contract and is carried out by automated means, you may request a copy of your data in a structured, commonly used, machine-readable format.
Right to Object: You have the right to object to processing carried out on the basis of Super88's legitimate interests. Super88 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests, or unless the processing is necessary for legal claims.
Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

To exercise any of the rights listed above, please contact Super88's compliance team using the contact details in Section 15. We will require verification of your identity before processing any rights request. All requests will be handled free of charge unless they are manifestly unfounded, excessive, or repetitive, in which case Super88 reserves the right to charge a reasonable administrative fee or decline the request.

12. Minors & Age Restriction

The Super88 Platform is strictly intended for use by persons who are 21 years of age or older. Super88 does not knowingly collect or process Personal Data from individuals under the age of 21. Where Super88 becomes aware that Personal Data has been submitted by a person under 21, that Account will be immediately closed, all data deleted, and any deposited funds returned to the payment source.

Age is verified during the registration process and again during KYC verification via the submission of a valid government-issued identity document. Parents and guardians who believe a minor may have created an Account or submitted data to Super88 should contact our support team immediately so that prompt remedial action can be taken.

21+ Only. Super88 employs robust age verification at multiple stages to enforce this requirement. We strongly encourage parents and guardians to use parental control software to prevent minors from accessing online gaming platforms.

13. Third-Party Links

The Super88 Platform may, in limited circumstances, contain references to or interactions with third-party services (for example, licensed game content providers or payment processors). Super88 is not responsible for the privacy practices of those third parties and this Privacy Policy does not apply to their services.

Super88 advises all Players to review the privacy policies of any third-party services they interact with independently of the Super88 Platform. Super88's inclusion of any third-party integration does not constitute an endorsement of that party's privacy or data security practices.

14. Policy Amendments

Super88 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, or our data processing practices. The date of the most recent revision is displayed at the top of this page.

Where changes to this Privacy Policy are material — for example, where a new category of data is collected or a new purpose of processing is introduced — Super88 will notify registered Players by email or via a prominent notice on the Platform prior to the change taking effect.

Your continued use of the Platform after the effective date of any revision constitutes your acknowledgement of the updated Privacy Policy. If you do not agree with any change, you should contact Super88 to close your Account before the revision takes effect.

15. Contact Us

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or wish to raise a concern about Super88's data handling practices, please contact our compliance team through any of the following channels:

Data Privacy Enquiries: [email protected]

Live Chat: Available 24 hours a day, 7 days a week via the Super88 Platform. Please specify "Data Privacy Request" at the start of your enquiry.

Super88 aims to acknowledge all data privacy enquiries within 2 business days and to provide a substantive response within 14 business days. For complex requests, we will notify you if additional time is required.