cuci12 Privacy Policy

1. Introduction

1.1 cuci12 ("cuci12", "we", "us", or "our") is committed to protecting the privacy and personal data of every individual who uses the cuci12 platform at cuci12.win ("Platform"). We recognise that trust is the foundation of any long-term relationship with our Members, and we take our data protection obligations seriously.

1.2 This Privacy Policy describes in plain terms how cuci12 collects, uses, stores, shares, and protects your personal data when you register an Account, access the Platform, make a deposit or withdrawal, place a bet, claim a promotion, or contact our support team.

1.3 By registering a cuci12 Account or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this policy, you should not register an Account or use cuci12 services.

1.4 This Privacy Policy should be read alongside the cuci12 Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2. Data Controller

2.1 For the purposes of applicable data protection legislation, cuci12 is the data controller responsible for the personal data collected through the Platform. cuci12 operates under international gaming licensing and is subject to the data protection requirements of its licensing jurisdiction.

2.2 Malaysian Members should note that the Personal Data Protection Act 2010 (PDPA) of Malaysia governs the processing of personal data in commercial transactions within Malaysia. cuci12 is committed to handling the personal data of Malaysian Members in a manner consistent with the principles established under the PDPA.

3. Personal Data We Collect

3.1 cuci12 collects personal data that is necessary to provide our services, comply with our legal and licensing obligations, and improve the cuci12 platform experience. The categories of data we collect include:

3.2 cuci12 does not collect or store full payment card numbers. All payment card transactions, where applicable, are handled by PCI-DSS compliant payment processors. cuci12 receives only tokenised references from these processors.

4. How We Collect Your Data

4.1 Directly from you. The majority of personal data held by cuci12 is provided directly by you during the registration process, KYC verification, deposit and withdrawal requests, contact with our support team, and responses to promotional communications.

4.2 Automatically through Platform use. When you access the cuci12 Platform, we automatically collect technical data through server logs, cookies, and similar tracking technologies. This includes your IP address, device identifiers, and session activity data. Please refer to Section 8 (Cookies & Tracking) for full details.

4.3 From third-party verification services. To fulfil our KYC and anti-money laundering obligations, cuci12 may verify identity information against third-party databases, including government identity registries and commercially available identity verification platforms. We may also receive fraud-risk scores from payment processors during deposit and withdrawal processing.

4.4 From our gaming providers. Game providers integrated into the cuci12 Platform may share aggregated gameplay statistics and technical event logs with us for the purpose of game performance monitoring and dispute resolution. These providers operate under strict data processing agreements with cuci12.

5. How We Use Your Personal Data

5.1 cuci12 uses your personal data for the following purposes:

• Account Management: Creating, maintaining, and securing your cuci12 Account, verifying your identity and age, and managing your Account settings and preferences.
• Service Delivery: Processing deposits and withdrawals, crediting and debiting game outcomes, applying bonus funds, and fulfilling promotional commitments.
• Legal & Regulatory Compliance: Fulfilling our obligations under international gaming licensing requirements, anti-money laundering regulations, and applicable data protection laws, including the Malaysian PDPA.
• Fraud Prevention & Security: Detecting and preventing fraudulent activity, unauthorised account access, bonus abuse, and money laundering. This includes automated risk scoring and manual account reviews.
• Responsible Gaming: Monitoring gameplay patterns to identify potential problem gambling behaviours, administering self-imposed limits and exclusions, and providing intervention support where appropriate.
• Customer Support: Responding to enquiries, resolving disputes, and maintaining records of support interactions for quality assurance and compliance purposes.
• Marketing Communications: Sending you promotional offers, bonus notifications, and platform updates via email or SMS, where you have consented to receive such communications. You may opt out at any time by contacting [email protected].
• Platform Improvement: Analysing aggregated, anonymised usage data to improve the cuci12 platform experience, game selection, and promotional programmes.

5.2 cuci12 will not use your personal data for any purpose that is incompatible with the purposes described in this section without first obtaining your explicit consent or establishing a separate lawful basis for doing so.

6. Legal Basis for Processing

6.1 cuci12 processes your personal data on the following legal grounds:

• Contractual necessity: Processing required to perform our contractual obligations to you under the cuci12 Terms & Conditions, including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable laws and regulations, including KYC requirements, anti-money laundering obligations, and gaming licence conditions.
• Legitimate interests: Processing carried out for cuci12's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your rights and interests.
• Consent: Processing based on your explicit consent, primarily in the context of direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7. Data Sharing & Disclosure

7.1 cuci12 does not sell your personal data to third parties. We share personal data only in the circumstances described below, and only to the minimum extent necessary for the stated purpose:

• Payment Processors: Your financial data is shared with our payment processing partners (including those facilitating Touch n Go eWallet, Boost, and bank transfer transactions) for the sole purpose of processing your deposits and withdrawals.
• Identity Verification Providers: Identity and document data is shared with our KYC and anti-money laundering compliance service providers for the purpose of verifying your identity and age.
• Gaming Providers: Limited account and session data is shared with integrated game providers to enable gameplay functionality, dispute resolution, and regulatory auditing.
• Regulatory Authorities: cuci12 may be required to disclose personal data to gaming regulators, tax authorities, financial intelligence units, or law enforcement agencies in response to lawful requests or to fulfil our regulatory reporting obligations.
• Corporate Transactions: In the event of a merger, acquisition, or sale of all or substantially all of cuci12's assets, your personal data may be transferred to the relevant successor entity, subject to the same privacy protections described in this policy.

7.2 All third parties with whom cuci12 shares personal data are required to maintain appropriate technical and organisational security measures and to process personal data only in accordance with cuci12's instructions and applicable data protection law.

8. Cookies & Tracking Technologies

8.1 The cuci12 Platform uses cookies and similar technologies to deliver, maintain, and improve our services. By continuing to use the Platform, you consent to our use of cookies as described in this section.

8.2 cuci12 uses the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies that maintain your logged-in state, security tokens, and cookies that remember your language and currency preferences. These cannot be disabled.
• Performance & Analytics Cookies: Used to collect anonymised information about how Members use the Platform — which pages are visited most frequently, where errors occur, and how load times compare across device types. This data is used exclusively to improve the cuci12 experience.
• Functional Cookies: Remember your preferences and customisations, such as your preferred game categories, table limits, and responsible gaming settings.

8.3 You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair Platform functionality and may prevent login.

8.4 cuci12 does not use cookies for cross-site behavioural advertising or share cookie data with advertising networks.

9. Data Retention

9.1 cuci12 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, including the satisfaction of any legal, accounting, or reporting requirements.

9.2 Specific retention periods applied by cuci12 are as follows:

• Account and identity data: Retained for the duration of your Account and for a minimum of 5 years following Account closure, in accordance with anti-money laundering record-keeping requirements.
• Transaction and gameplay records: Retained for a minimum of 5 years from the date of each transaction, in compliance with gaming licence and financial regulatory obligations.
• Support communication records: Retained for 3 years from the date of the final communication in a support thread.
• Technical and log data: Retained for 12 months from collection, unless retained longer due to an ongoing investigation or dispute.
• Marketing consent records: Retained for the duration of your consent and for 3 years thereafter as evidence of consent.

9.3 Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with cuci12's data destruction procedures.

10. Data Security

10.1 cuci12 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• TLS 1.3 encryption with 256-bit AES ciphers for all data in transit between your browser and cuci12 servers;
• Encryption of sensitive data fields (including identity document data and financial account identifiers) at rest;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Continuous server monitoring with anomaly detection and intrusion prevention systems;
• Regular penetration testing by qualified independent security assessors;
• PCI-DSS compliant payment processing for all financial transactions.

10.2 In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, cuci12 will notify affected Members without undue delay, in accordance with applicable data breach notification obligations.

11. Your Rights as a Data Subject

11.1 Subject to applicable law, you have the following rights with respect to your personal data held by cuci12. Requests may be submitted to [email protected] with the subject line "Data Subject Request":

• Right of Access: You may request a copy of the personal data cuci12 holds about you, together with information about how it is being used.
• Right of Correction: You may request correction of inaccurate or incomplete personal data. You may also update certain data directly through your Account settings.
• Right of Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to cuci12's legal retention obligations.
• Right to Restrict Processing: You may request that cuci12 restricts the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data.
• Right to Data Portability: You may request a machine-readable copy of personal data you have provided to cuci12, for transfer to another controller.
• Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes. For marketing opt-out, contact [email protected] at any time.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

11.2 cuci12 will respond to verifiable data subject requests within 30 days of receipt. Identity verification will be required before processing any request that could expose or affect another individual's data.

12. Children & Minors

12.1 The cuci12 Platform is strictly intended for adults aged 21 years and above. cuci12 does not knowingly collect personal data from any person under the age of 21.

12.2 If cuci12 becomes aware that personal data has been collected from an individual under the age of 21, the relevant Account will be immediately suspended, all associated personal data will be deleted, and any funds will be returned to the source payment method following verification.

12.3 If you believe that cuci12 may have inadvertently collected data from a minor, please contact us immediately at [email protected].

13. Cross-Border Data Transfers

13.1 As cuci12 operates under international gaming licensing, your personal data may be transferred to and processed in countries outside Malaysia, including the jurisdiction in which cuci12's licensing authority and certain service providers are located.

13.2 Where personal data is transferred internationally, cuci12 ensures that appropriate safeguards are in place to protect your data to a standard at least equivalent to that required under the Malaysian PDPA, including contractual protections with data recipients.

13.3 By using the cuci12 Platform, you acknowledge and consent to the transfer of your personal data in the circumstances described in this section.

14. Changes to This Privacy Policy

14.1 cuci12 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or our services. The effective date at the top of this page will be updated with each revision.

14.2 Where changes are material, cuci12 will notify Members by email at the registered address or by displaying a prominent notice on the Platform. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

14.3 We encourage you to review this Privacy Policy periodically to stay informed about how cuci12 is protecting your data.

15. Contact & Complaints

15.1 For any questions, concerns, or requests relating to this Privacy Policy or cuci12's handling of your personal data, please contact us at:

15.2 cuci12 will acknowledge all privacy-related correspondence within 3 business days and aims to resolve all enquiries within 30 days of receipt.

15.3 If you are not satisfied with cuci12's response to your privacy complaint, you may escalate the matter to the relevant data protection authority in your jurisdiction or to the dispute resolution body designated under cuci12's gaming licence.