1. Introduction
cuci100 ("we", "us", "our") operates the online gaming platform accessible at cuci100.club (the "Platform"). This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by cuci100. We are committed to protecting and respecting your privacy in accordance with applicable data protection principles.
By registering an account on cuci100 or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and use of your personal data as described herein. If you do not agree with this Privacy Policy, please discontinue your use of the cuci100 Platform.
This Privacy Policy should be read alongside our Terms & Conditions, which govern your overall use of the cuci100 Platform and are available at cuci100.club/terms-conditions.
2. Personal Data We Collect
cuci100 collects and processes the following categories of personal data:
2.1 Data You Provide Directly
- Registration data: Full legal name, date of birth, email address, and any other information submitted when creating your cuci100 account.
- Identity verification data: Government-issued identification documents (e.g., Malaysian MyKad, passport), proof of address, and payment method ownership documentation, collected as part of our Know Your Customer (KYC) obligations.
- Financial data: Information related to your deposit and withdrawal transactions, including payment method details (e.g., e-wallet account identifiers, bank account details). cuci100 does not store full card numbers or banking credentials directly — these are processed through our certified payment processors.
- Communications: Records of your interactions with cuci100 customer support, including live chat transcripts and any correspondence submitted by email.
2.2 Data Collected Automatically
- Technical data: IP address, device type, operating system, browser type and version, screen resolution, and time zone settings.
- Usage data: Pages visited, features used, games played, session duration, click patterns, and navigation paths within the cuci100 Platform.
- Cookie data: Data collected via cookies and similar tracking technologies, as described in Section 6 of this Policy.
- Transaction logs: A complete record of all deposits, withdrawals, bets placed, and game results associated with your cuci100 account.
3. How We Use Your Personal Data
cuci100 uses the personal data we collect for the following purposes:
- Account management: To create, maintain, verify, and administer your cuci100 account, including identity verification and age confirmation.
- Service delivery: To enable you to access and use all features of the cuci100 Platform, including the casino, sportsbook, virtual games, and all related products.
- Payment processing: To facilitate deposits, withdrawals, and the detection and prevention of fraudulent financial transactions.
- Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance related to your cuci100 account.
- Legal and regulatory compliance: To comply with our Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and Know Your Customer (KYC) obligations, and to fulfil any requirements imposed by gaming regulatory authorities.
- Responsible gaming: To monitor account activity for indicators of problem gambling and to administer self-exclusion, cooling-off, and deposit limit tools as requested by users.
- Platform improvement: To analyse usage patterns, identify technical issues, and improve the performance, features, and user experience of the cuci100 Platform.
- Communications: To send you account-related notifications, transaction confirmations, promotional offers (where you have consented), and important updates regarding these Terms or this Privacy Policy.
- Security: To protect the integrity of the cuci100 Platform, detect and prevent fraud, collusion, and the use of automated tools, and to enforce our Terms & Conditions.
4. Legal Basis for Processing
cuci100 processes your personal data on the following legal grounds:
- Contractual necessity: Processing required to perform the contract between you and cuci100 — specifically, the operation of your account and the delivery of the cuci100 Platform's services.
- Legal obligation: Processing necessary to comply with applicable legal requirements, including AML, KYC, and gaming regulatory obligations.
- Legitimate interests: Processing carried out in cuci100's legitimate interests in operating a secure, fair, and commercially viable gaming platform, where those interests do not override your fundamental rights and freedoms.
- Consent: Where you have given explicit consent for a specific processing activity, such as receiving promotional communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
5. Data Sharing & Disclosure
cuci100 does not sell, rent, or trade your personal data. We may share your personal data with third parties only in the following circumstances:
- Service providers: Trusted third-party vendors who provide services on cuci100's behalf, including payment processors (e.g., e-wallet operators, banks), identity verification services, IT infrastructure providers, and customer support platforms. These parties are contractually bound to process data only as instructed by cuci100 and in accordance with applicable data protection standards.
- Game providers: Licensed game studios and content providers whose games are accessible on the cuci100 Platform may receive pseudonymous gameplay data for the purpose of technical operation and reporting.
- Regulatory authorities: Where required by law or gaming regulatory authority, cuci100 may disclose personal data to relevant government bodies, law enforcement agencies, or licensed gaming regulators.
- Fraud and security: cuci100 may share data with fraud prevention agencies or other gaming operators where there is a reasonable basis to believe that a user is engaged in fraudulent activity, money laundering, or other prohibited conduct.
- Corporate transactions: In the event of a merger, acquisition, or sale of all or part of cuci100's business, personal data may be transferred as part of that transaction, subject to appropriate confidentiality undertakings.
6. Cookies & Tracking Technologies
cuci100 uses cookies and similar technologies (such as web beacons and local storage) to operate and improve the Platform. Cookies are small text files placed on your device when you visit a website. They serve several functions on the cuci100 Platform:
- Essential cookies: Required for the Platform to function correctly, including session management, login authentication, and security features. These cannot be disabled without affecting Platform functionality.
- Performance cookies: Collect anonymised information about how visitors use the cuci100 Platform — which pages are visited most frequently, where errors occur, and how users navigate between sections. This data helps cuci100 improve Platform performance.
- Functional cookies: Remember your preferences — such as language settings, display preferences, and recently played games — to provide a more personalised experience on cuci100.
- Analytics cookies: Used by cuci100 to analyse aggregate user behaviour and Platform usage patterns to inform product development decisions.
You may control cookie settings through your browser preferences. Please note that disabling certain categories of cookies may affect the functionality of the cuci100 Platform and your overall user experience.
7. Data Retention
cuci100 retains your personal data for as long as necessary to fulfil the purposes for which it was collected, as described in this Privacy Policy, and to comply with applicable legal and regulatory obligations.
In practice, this means:
- Account data and transaction records are retained for a minimum of five (5) years following account closure, in accordance with standard AML record-keeping requirements.
- Identity verification documents are retained for a minimum of five (5) years from the date of verification or the date of the last transaction, whichever is later.
- Customer support communications are retained for a minimum of two (2) years from the date of the last interaction.
- Where a legal dispute is ongoing or reasonably anticipated, relevant data will be retained until that dispute is fully resolved.
Following the expiry of the applicable retention period, personal data will be securely deleted or anonymised so that it can no longer be associated with an identifiable individual.
8. Data Security
cuci100 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:
- 256-bit SSL/TLS encryption for all data transmitted between your device and the cuci100 Platform.
- Encryption of sensitive data fields at rest within cuci100's databases.
- Strict access controls ensuring that personal data is accessible only to authorised cuci100 personnel with a documented need to access it.
- Regular security audits and penetration testing of cuci100's infrastructure.
- Staff training on data protection obligations and the handling of personal data.
Notwithstanding the foregoing, no security measure is entirely infallible. In the unlikely event of a data breach that poses a risk to your rights and freedoms, cuci100 will notify affected individuals and relevant authorities in accordance with applicable legal requirements.
9. Your Data Rights
Subject to applicable law and certain legal limitations, you have the following rights in respect of your personal data held by cuci100:
- Right of access: You may request a copy of the personal data cuci100 holds about you.
- Right to rectification: You may request that inaccurate or incomplete personal data be corrected. You may also update certain account details directly through your cuci100 account settings.
- Right to erasure: You may request that cuci100 delete your personal data where it is no longer necessary for the purposes for which it was collected, subject to cuci100's legal retention obligations.
- Right to restriction: You may request that cuci100 restrict the processing of your personal data in certain circumstances.
- Right to data portability: Where processing is based on consent or contractual necessity, and is carried out by automated means, you may request a machine-readable copy of your personal data.
- Right to withdraw consent: Where cuci100 processes your data based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.
- Right to object: You may object to processing carried out on the basis of cuci100's legitimate interests, or for direct marketing purposes.
To exercise any of the above rights, please contact cuci100 at [email protected]. cuci100 will respond to all valid requests within 30 days. Where a request is complex or numerous, this period may be extended by a further two months, and you will be informed accordingly.
10. Minors
The cuci100 Platform is strictly intended for individuals aged 21 years and above. cuci100 does not knowingly collect personal data from persons under the age of 21. If cuci100 becomes aware that it has inadvertently collected personal data from a minor, that data will be promptly deleted and the associated account will be closed.
If you are a parent or guardian and believe that your child has registered an account on cuci100, please contact us immediately at [email protected] so that we can take appropriate action.
11. International Data Transfers
cuci100 operates in the online gaming industry and, as a result, some of our service providers and technology partners may be located outside Malaysia. Where personal data is transferred to countries that may not offer the same level of data protection as Malaysia, cuci100 takes reasonable steps to ensure that appropriate safeguards are in place — such as standard contractual clauses or other legally recognised transfer mechanisms — to protect your personal data in accordance with the principles set out in this Privacy Policy.
12. Changes to This Privacy Policy
cuci100 reserves the right to update or amend this Privacy Policy at any time. Where changes are material, cuci100 will take reasonable steps to notify registered users — for example, by email or by displaying a prominent notice on the Platform. The date of the most recent revision is displayed at the top of this page.
Your continued use of the cuci100 Platform following the publication of a revised Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree with any changes, please discontinue your use of the Platform and contact us to close your account.
13. Contact Us
If you have any questions, concerns, or requests relating to this Privacy Policy or cuci100's data handling practices, please contact our Data Protection team. We aim to respond to all privacy-related enquiries within 5 business days.
Email: [email protected]
For general account support queries, our live chat team is available 24 hours a day, 7 days a week, directly through the cuci100 Platform.