cowboy38 Privacy Policy

1. General Information

This Privacy Policy ("Policy") is issued by cowboy38 ("we", "platform", or "cowboy38"), an online betting platform operating under international licensing. This Policy applies to all users who access the cowboy38 website at cowboy38.org and all related services we offer.

By registering an account, using our services or continuing to access the cowboy38 platform, you agree to the terms in this Privacy Policy. We encourage you to read this document thoroughly before continuing to use the platform.

This Policy explains the types of information we collect, how it is used, who may receive it, how it is protected, and your rights regarding that personal data. If you have any questions after reading this Policy, please contact our customer service team via 24/7 live chat or email.

2. Information We Collect

cowboy38 collects various categories of information to enable us to provide services that are safe, orderly and compliant with international licensing requirements. The information we collect includes:

Account Registration Information:

• Full name as stated on your identity card (MyKad) or passport
• Date of birth for age verification purposes (players must be 21 years of age or older)
• Active email address and mobile phone number
• Username and password chosen during registration
• Nationality and country of residence

Identity Verification Information:

• Copy of valid identity card (MyKad) or passport
• Proof of current residential address (utility bill or bank statement)
• Payment method information used for verification purposes

Platform Usage Information:

• Deposit and withdrawal transaction history
• Game activity and betting records
• Game selections, bonuses used and winning records
• Device and browser information used for access
• IP address and general location data
• Session logs and account activity timestamps

3. How We Use Your Information

All collected information is used solely for platform operations and legal compliance. cowboy38 uses your personal data for the following purposes:

• Creating and managing your player account, including identity verification (KYC)
• Processing financial transactions including deposits and withdrawals securely
• Verifying age eligibility and ensuring players are 21 years of age or older
• Preventing fraud, money laundering and other suspicious activities
• Complying with reporting requirements under cowboy38's international licensing
• Sending important notifications related to your account, transactions and policy changes
• Providing effective customer support via live chat and email
• Improving service quality based on usage patterns and player feedback
• Sending promotional information and bonuses — subject to your preferences
• Enforcing Terms & Conditions and ensuring fair use of the platform

We will not use your data for any other purpose without obtaining your consent first, unless required by law or by direction of a competent authority.

4. Disclosure of Information to Third Parties

cowboy38 does not sell or rent your personal data to any third party. However, in the context of legitimate operations, we share certain information with the following parties:

Payment Service Providers:

To process financial transactions via Touch 'n Go eWallet, DuitNow, FPX, Boost, ShopeePay and cryptocurrency (USDT, BTC, ETH), your payment information is shared with the relevant payment processors. All payment processors are bound by strict confidentiality agreements.

Game Software Providers:

Game providers such as PG Soft, Pragmatic Play, JILI and Spribe may receive game data required for technical functions. They do not receive your full personal identification information.

Authorities and Regulatory Bodies:

When required by law, court order, or international licensing requirements, cowboy38 will disclose the necessary information to the competent authorities. We will notify you if this occurs, unless we are legally prohibited from doing so.

5. Data Security

Protecting your personal data is a top priority for cowboy38. We implement a range of appropriate technical and organisational security measures to prevent unauthorised access, loss, alteration or disclosure of data.

• 256-bit SSL encryption for all communication between your browser and our servers
• Password storage using cryptographic hashing — your password cannot be read by anyone
• Two-factor authentication (2FA) is available and encouraged for all players
• Continuous 24/7 security monitoring to detect suspicious activity
• Employee access to player data is restricted based on job requirements only
• Regular security assessments and system vulnerability testing by independent experts

While we take all reasonable steps, no digital system is entirely risk-free. We therefore encourage you to also protect your account by using a strong password and not sharing your login credentials with anyone.

6. Cookies and Tracking Technologies

cowboy38 uses cookies and similar tracking technologies to improve the user experience on our platform. Cookies are small data files stored on your device when you visit our website.

Types of cookies we use:

• Essential Cookies: Required for core platform functions such as login, game sessions and security. These cookies cannot be disabled.
• Performance Cookies: Collect information about how you use the platform to help us improve our services.
• Functional Cookies: Store your preferences such as language and display settings for ease of use.
• Marketing Cookies: Used to display relevant promotions and offers. You may opt out of these cookies.

You can manage or disable cookies through your browser settings. Please note that disabling essential cookies may affect the functionality of the cowboy38 platform.

7. Your Rights as a Player

As the owner of your personal data, cowboy38 recognises and respects the following rights, which you may exercise at any time:

• Right of Access: You have the right to obtain a copy of the personal information we hold about you.
• Right to Rectification: You may request correction of any information that is inaccurate or incomplete.
• Right to Erasure: Under certain circumstances, you may request the deletion of your personal data ("right to be forgotten").
• Right to Restriction of Processing: You may request that we limit how we process your data in certain situations.
• Right to Object: You may object to the processing of your data for direct marketing purposes at any time.
• Right to Data Portability: You may request your data in a structured, machine-readable format.

To exercise any of these rights, please contact the cowboy38 customer service team via 24/7 live chat or email at [email protected]. We will process your request in accordance with the appropriate identity verification procedures.

8. Data Retention Period

cowboy38 retains your personal data for as long as your account is active or as long as necessary to provide our services. After account closure, certain records may be retained for the period required to fulfil legal obligations, resolve disputes, and enforce our agreements.

• Financial transaction records are retained for the minimum period stipulated by international licensing requirements
• Account activity logs are retained for security audit and compliance purposes
• Identity verification documents (KYC) are retained in accordance with applicable anti-money laundering guidelines
• Customer support communications are retained to improve service quality

When data is no longer needed, it will be securely deleted or anonymised using established procedures.

9. Protection of Minors

cowboy38 takes seriously the responsibility of ensuring our platform is not accessible to minors. All cowboy38 services are strictly for individuals aged 21 and above only.

We apply strict age verification procedures during account registration. If we suspect that a player is underage, the account will be suspended until verification is complete. If the player is confirmed to be underage, the account will be closed immediately and all funds in the account will be handled in accordance with established procedures.

cowboy38 does not intentionally collect personal data from individuals under the age of 21. If you believe we have inadvertently collected such data, please contact us immediately so that appropriate action can be taken.

10. Amendments to the Privacy Policy

cowboy38 reserves the right to update or amend this Privacy Policy at any time. Any material changes will be communicated to you through one of the following methods:

• In-platform notifications via your account dashboard
• Email to the address registered to your account
• Updates to the Privacy Policy page on cowboy38.org with a new effective date

Your continued use of the cowboy38 platform after the effective date of any such amendment will be considered your acceptance of the updated terms. We encourage you to review this page periodically to stay informed about how we protect your information.

11. Contact Us Regarding Privacy

If you have any questions, concerns or complaints regarding cowboy38's Privacy Policy or how we process your personal data, our customer service team is ready to assist:

• 24/7 live chat — available directly through the cowboy38 platform in Malay and English
• Email: [email protected] — please include the subject "Privacy Enquiry" for faster processing

We are committed to responding to every privacy-related enquiry with seriousness and care. Your satisfaction and trust as a cowboy38 player is our priority.