Privacy Policy cuci21 – Our Commitment to Protecting Your Personal Data

This Privacy Policy is issued by cuci21 ("cuci21", "We", "Platform") and applies to all users, visitors, and members of the cuci21 platform based in Malaysia. This document sets out in detail our personal data management practices and your rights as a data subject under Malaysia's Personal Data Protection Act 2010 (PDPA).

Cuci21 adopts a Privacy by Design approach – meaning privacy considerations are built into every aspect of our systems and processes from the initial design stage, rather than being added as an afterthought.

01Introduction & Scope of Privacy Policy

This Privacy Policy applies to all personal data collected, processed, and stored by cuci21 through the following channels:

• The official cuci21 website at cuci21.biz and all associated subdomains.
• The cuci21 mobile platform and application (where available).
• Cuci21 email, Live Chat, and customer support channels.
• Account registration and identity verification (KYC) process.
• Financial transactions including deposits via Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow and FPX (Maybank2u, CIMB Clicks).
• Gaming and betting activities on the cuci21 platform.

This policy does not apply to third-party websites that may be linked from the cuci21 platform. cuci21 is not responsible for the privacy practices of those external sites.

02Types of Personal Data Collected by cuci21

2.1 Data You Provide Directly

When registering and using the cuci21 platform, you may provide us with the following personal data:

2.2 Automatically Collected Data

When you use the cuci21 platform, our systems automatically log the following technical data:

• Device Data: Device type, operating system, phone model, screen resolution.
• Network Data: IP address, internet connection type, approximate geographic location (state/city within Malaysia).
• Browsing Data: Pages visited, time spent, links clicked, referral source.
• Gaming Activity Data: Betting records, game results, and transaction history within the cuci21 platform.
• Session Data: Login and logout times, active session duration.

03Data Collection & Processing Purposes

Cuci21 collects and processes your personal data solely for the following legitimate purposes:

3.1 Primary Purposes (Contract & Legal Obligations)

• Creation and management of cuci21 member accounts.
• Identity verification (KYC) as required by licensing and AML regulations.
• Deposit processing via Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, Maybank2u (FPX) and CIMB Clicks (FPX).
• Processing of withdrawals and payment recipient verification.
• Providing online gaming, Sports Betting, and Live Casino services.
• Compliance with anti-money laundering (AML) reporting requirements and fraud prevention.

3.2 Service Purposes (Legitimate Interests)

• Providing effective customer support in Bahasa Melayu.
• Analysing usage patterns to improve the cuci21 platform.
• Detecting and preventing fraudulent activity, money laundering and account abuse.
• Ensuring the security and integrity of the cuci21 platform.
• Resolution of disputes relating to betting or transactions.

3.3 Marketing Purposes (With Your Consent)

• Sending promotional information, bonuses, and special offers from cuci21 via email or SMS – only where you have given consent.
• Contacting you about VIP programmes and personalised offers based on your activity on the cuci21 platform.

04Sharing & Disclosure of Personal Data

Cuci21 does not sell, rent, or trade members' personal data to third parties for their own marketing purposes. Personal data may be shared with the following parties only, and only to the extent necessary:

4.1 Third-Party Service Providers

• Payment Processors: Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, and FPX platform providers, enabling financial transactions to be completed securely.
• Game Providers: Game software providers supplying slots, baccarat, roulette, and other games to the cuci21 platform – only data necessary to enable gameplay is shared.
• Identity Verification Services: Third-party KYC providers that assist cuci21 in verifying members' identity documents.
• Technology Infrastructure: Cloud service providers that store our data in a secure, encrypted environment.

All third-party service providers working with cuci21 are required to uphold data protection standards equivalent to or higher than those of cuci21, and are not permitted to use your data for their own purposes.

4.2 Disclosure to Authorities

Cuci21 may be required to disclose personal data to authorities such as the police, courts, or regulatory bodies where:

• Required to do so under applicable Malaysian law.
• Required to comply with legal process, a court order, or a regulatory body's request.
• Required to protect the rights, property or safety of cuci21, its members or the public.
• Required for fraud investigations or financial crime proceedings.

05cuci21 Data Security Measures

Cuci21 implements a range of technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration or destruction:

5.1 Technical Security

• 256-bit SSL/TLS Encryption: All communications between your device and cuci21's servers are encrypted using bank-grade encryption technology.
• Data-at-Rest Encryption: Sensitive data stored in cuci21's databases is encrypted using AES-256.
• Layered Access Controls: Access to members' personal data is restricted to staff with a legitimate business need only, backed by two-factor authentication (2FA).
• 24/7 Security Monitoring: Threat detection systems and abnormal activity monitoring operate around the clock.
• Periodic Penetration Testing: cuci21's infrastructure undergoes regular security testing by independent security experts.

5.2 Data Breach Response

In the event of a data breach affecting cuci21 members' personal data, we are committed to:

• Notifying affected members within 72 hours from the time a breach is detected, in accordance with PDPA requirements.
• Taking immediate action to contain and limit the breach.
• Reporting to Malaysia's Department of Personal Data Protection where required.
• Providing clear information on the type of data affected and the steps that have been taken.

06Your Rights as a Data Subject in Malaysia

Under Malaysia's Personal Data Protection Act 2010 (PDPA), you as a data subject have the following rights regarding your personal data held by cuci21:

07Use of Cookies & Tracking Technologies

Cuci21 uses cookies and similar tracking technologies to enhance the user experience on our platform. The following are the types of cookies we use:

You can manage your cookie preferences through your web browser settings. Please note that disabling certain cookies may affect the functionality of the cuci21 platform.

08Protection of Children's Data

The cuci21 platform is strictly intended for individuals aged 18 years and above only. cuci21 does not knowingly collect or process personal data from individuals under the age of 18.

09Amendments to the Privacy Policy

Cuci21 reserves the right to amend this Privacy Policy at any time to reflect changes in our practices, legal requirements, or technology. When amendments are made:

• The "Last Updated" date at the top of this page will be revised accordingly.
• For significant amendments, cuci21 will notify members via their registered email address or through an in-platform notification.
• Continued use of the cuci21 platform after the effective date of any amendment constitutes acceptance of the updated Privacy Policy.

We recommend reviewing this Privacy Policy page periodically to stay informed of cuci21's latest privacy practices.

10Contact cuci21's Data Privacy Officer

Cuci21 has appointed a Data Protection Officer responsible for ensuring PDPA compliance and handling all privacy-related enquiries from Malaysian members. For privacy data enquiries, complaints, or requests:

• Privacy Email: privacy@cuci21.biz
• General Support Email: support@cuci21.biz
• Live Chat: Available 24/7 within the cuci21 platform
• Response Time: Privacy enquiries are responded to within 72 hours; data rights requests are processed within 30 business days

For enquiries related to responsible platform use, visit Responsible Gaming cuci21. For general platform terms of use, please refer to Terms & Conditions cuci21.