Privacy Policy — cuci100

1 Introduction

cuci100 ("we", "us", "our", "the Platform") operates the online casino and sports betting platform accessible at https://cuci100.cam. We are committed to protecting the privacy and personal data of all individuals who interact with our Platform, including registered Members, prospective users, and general visitors.

This Privacy Policy ("Policy") describes in detail what personal data we collect, the purposes for which we process it, the legal bases that permit such processing, and the rights you hold over your data. This Policy applies to all data collected through the Platform, our mobile application, live chat service, email communications, and any other interaction you have with cuci100.

By registering a cuci100 account or continuing to use the Platform, you confirm that you have read, understood, and agreed to the terms of this Privacy Policy. This Policy should be read alongside our Terms & Conditions.

2 Definitions

For the purposes of this Policy, the following terms have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person ("data subject"), including name, identification number, contact details, financial data, and online identifiers.
• "Processing" means any operation or set of operations performed on Personal Data, including collection, recording, storage, use, disclosure, transmission, or deletion.
• "Data Controller" means cuci100, which determines the purposes and means of processing Personal Data collected through the Platform.
• "Data Processor" means any third party that processes Personal Data on behalf of cuci100 under a contractual arrangement and our instruction.
• "Member" means any individual who has registered a verified account on the cuci100 Platform.
• "Cookies" means small text files placed on your device by the Platform to store preference data, session identifiers, and analytics information.
• "KYC" means Know Your Customer — the identity and document verification process applied to Member accounts to comply with applicable anti-money laundering obligations.

3 Data We Collect

3.1 Data You Provide Directly

When you register an account, complete KYC verification, contact our support team, or use Platform features, you may provide the following categories of Personal Data:

• Full legal name;
• National identity number (MyKad number) or passport number;
• Date of birth (used for age verification — minimum 21 years);
• Residential address, including city and postcode (e.g., Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam);
• Email address and mobile phone number;
• Payment method details (bank account numbers, e-wallet identifiers for Maybank, CIMB, Public Bank, Hong Leong, Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX);
• Identity documents uploaded during KYC review;
• Communications sent to our support team via live chat or email.

3.2 Data Collected Automatically

When you access and use the Platform, we automatically collect certain technical and behavioural data, including:

• IP address and approximate geographic location;
• Device type, operating system, and browser information;
• Session duration, pages visited, and navigation patterns;
• Betting history, game activity logs, and transaction records;
• Login timestamps and security event logs;
• Cookie and tracking technology data (see Section 8).

3.3 Data from Third Parties

In certain circumstances, cuci100 may receive Personal Data about you from third-party sources, including identity verification service providers engaged for KYC purposes, payment processors confirming transaction status, and fraud detection services. Such data is used solely in the context of the purposes set out in this Policy.

Data Category	Examples	Primary Purpose
Identity Data	Name, MyKad/passport number, date of birth	Account registration, KYC compliance, age verification
Contact Data	Email address, phone number, residential address	Account communication, support, notifications
Financial Data	Bank account details, e-wallet identifiers, transaction history	Deposit and withdrawal processing, anti-money laundering
Technical Data	IP address, device type, browser, session logs	Platform security, fraud prevention, service improvement
Behavioural Data	Betting history, game activity, navigation patterns	Service personalisation, responsible gambling monitoring
Communications Data	Live chat transcripts, email correspondence	Support resolution, quality assurance, dispute records

4 How We Use Your Data

cuci100 processes your Personal Data for the following purposes:

• Account Management: Creating and maintaining your Member account, verifying your identity, and enabling access to Platform features.
• Transaction Processing: Facilitating deposits and withdrawals in MYR via supported Malaysian payment channels, including FPX, DuitNow, Touch 'n Go eWallet, Boost, GrabPay, and major banks.
• Regulatory Compliance: Meeting anti-money laundering (AML) obligations, KYC requirements, and any other applicable legal or regulatory duties.
• Security and Fraud Prevention: Detecting, investigating, and preventing fraudulent activity, account compromise, or any misuse of the Platform.
• Service Delivery and Improvement: Providing the gaming and betting services you access, resolving technical issues, and continuously improving Platform performance and user experience.
• Responsible Gambling: Monitoring betting patterns to identify potential problem gambling behaviour and applying responsible gambling tools where warranted.
• Customer Support: Responding to queries, complaints, and requests submitted via live chat, email, or other support channels.
• Communications: Sending transactional notifications (e.g., deposit confirmations, withdrawal updates, security alerts) and, where you have opted in, promotional communications about cuci100 offers and events.
• Analytics: Analysing aggregated usage data to understand Platform performance and Member preferences in order to improve our services.

5 Legal Basis for Processing

Where applicable privacy law requires cuci100 to identify a legal basis for each processing activity, we rely on the following:

• Contractual Necessity: Processing required to perform our contract with you as a cuci100 Member — including account management, transaction processing, and service delivery.
• Legal Obligation: Processing required to comply with applicable laws, including KYC requirements, AML regulations, and financial reporting obligations.
• Legitimate Interests: Processing necessary for our legitimate business interests — including fraud prevention, Platform security, and service improvement — where such interests are not overridden by your rights and interests.
• Consent: Where you have provided explicit consent, for example to receive marketing communications. You may withdraw consent at any time by contacting our support team.

6 Data Sharing & Disclosure

cuci100 does not sell, rent, or trade your Personal Data to independent third parties. We may share your data only in the following limited circumstances:

• Payment Processors: We share necessary financial data with third-party payment processors (including banks and e-wallet providers such as Maybank, CIMB, Public Bank, Hong Leong, Touch 'n Go eWallet, Boost, GrabPay, DuitNow, and FPX) solely to process your deposit and withdrawal transactions.
• Identity Verification Providers: We engage third-party KYC service providers who process identity documents on our behalf for account verification purposes.
• Technology and Infrastructure Partners: We use third-party cloud, hosting, and cybersecurity providers who process technical data under strict data processing agreements and our instruction.
• Legal and Regulatory Authorities: We may disclose your Personal Data to relevant authorities where required by law, court order, or applicable regulatory obligation — including disclosures related to AML investigations or responses to lawful law enforcement requests.
• Business Transfers: In the event of a merger, acquisition, or restructuring of cuci100, your data may be transferred to the successor entity, subject to equivalent privacy protections.

7 Data Retention

cuci100 retains Personal Data only for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable legal and regulatory obligations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your active membership and for a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements.
• Transaction records: Retained for a minimum of seven (7) years from the date of the transaction.
• Support communications: Retained for three (3) years from the date of the interaction.
• Technical and log data: Retained for up to twelve (12) months, unless a longer period is required for an ongoing security investigation.

Where data is no longer required for any retained purpose, it is securely deleted or anonymised in accordance with our internal data disposal procedures.

8 Cookies & Tracking Technologies

cuci100 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files placed on your device when you access the Platform. They enable us to recognise your browser, maintain session continuity, and collect analytics data.

8.1 Types of Cookies We Use

• Essential Cookies: Strictly necessary for the Platform to function — including session authentication, security tokens, and load balancing. These cannot be disabled without impacting Platform functionality.
• Analytics Cookies: Used to collect aggregated data on how Members use the Platform — such as pages visited, session length, and navigation paths. This data helps us improve our services.
• Functionality Cookies: Store your preferences (such as language settings and display options) to personalise your experience.
• Security Cookies: Used to detect fraudulent activity, protect against account compromise, and support our security monitoring systems.

You may configure your browser to refuse or delete cookies. Please note that disabling essential cookies may prevent you from accessing certain Platform features or maintaining an active login session.

9 Data Security

cuci100 implements a comprehensive set of technical and organisational security measures to protect your Personal Data against unauthorised access, loss, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers;
• Encrypted storage of sensitive data, including identity documents and financial records;
• Two-factor authentication (2FA) available to all Members for account login;
• Role-based access controls limiting internal access to Personal Data on a need-to-know basis;
• Continuous security monitoring and intrusion detection systems;
• Regular third-party security audits and penetration testing;
• Staff training on data protection obligations and secure data handling practices.

Notwithstanding these measures, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials. If you suspect your account has been compromised, contact our support team immediately.

10 Your Rights

Subject to applicable law, you hold the following rights in relation to the Personal Data that cuci100 holds about you. To exercise any of these rights, please contact us using the details in Section 14.

• Right of Access: You have the right to request a copy of the Personal Data we hold about you, along with information on how it is processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete Personal Data we hold about you.
• Right to Erasure: In certain circumstances, you have the right to request deletion of your Personal Data. Note that this right may be limited where retention is required for legal compliance (e.g., AML record-keeping obligations).
• Right to Restrict Processing: You have the right to request that we restrict the processing of your Personal Data in certain circumstances — for example, while a rectification request is under review.
• Right to Data Portability: Where processing is based on your consent or a contractual relationship, you may request that your Personal Data be provided to you in a structured, machine-readable format.
• Right to Object: You have the right to object to processing based on legitimate interests, including direct marketing.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

cuci100 will respond to all data rights requests within a reasonable timeframe and in accordance with applicable legal requirements. Where we are unable to fulfil a request, we will explain our reasons in writing.

11 Minors & Age Verification

The cuci100 Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect or process Personal Data from individuals under the age of 21. Age verification is applied during the registration process and may be further verified during KYC review. Where cuci100 discovers that Personal Data has been collected from an individual below the minimum age, all associated data will be permanently deleted and the account closed without delay.

12 Third-Party Links & Services

The cuci100 Platform may reference or integrate third-party services — such as payment gateways and identity verification tools — whose privacy practices are governed by their own privacy policies. cuci100 is not responsible for the privacy practices of any third party and recommends that you review the relevant privacy policies before submitting Personal Data to any third-party service.

13 Policy Amendments

cuci100 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or operational requirements. Where amendments are material, we will notify registered Members via a Platform notification or email to the address on file. The revised Policy will display an updated "Last Updated" date at the top of this page.

Your continued use of the Platform following any such amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree to the revised terms, you must cease using the Platform and may request account closure by contacting our support team.

14 Contact Us

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

• Live Chat: Available daily, 8:00am – 2:00am MYT — accessible from the Platform interface.
• Email: [email protected] — please include "Privacy Request" in your subject line for prompt routing.

We aim to acknowledge all privacy-related requests within two business days and to provide a full response within 14 business days. For complex requests, we may require additional time and will inform you accordingly.