Privacy Policy — cuci365

cuci365 ("we", "us", "our", "the Platform") respects the privacy of every individual who interacts with our platform. This Privacy Policy ("Policy") describes our practices with respect to the collection, use, storage, disclosure, and protection of personal data obtained from members, visitors, and prospective users of the cuci365 website and associated services (collectively, "the Services").

This Policy applies to all personal data collected through the cuci365 website at cuci365.cam, our mobile-optimised platform, customer support communications, and any other channels through which we receive information from or about you in connection with the Services.

This Policy is to be read in conjunction with our Terms & Conditions and Responsible Gambling Policy. Defined terms not otherwise defined in this Policy carry the meanings given to them in the Terms & Conditions.

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

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, identification number, contact details, financial information, location data, and online identifiers.
• "Processing" means any operation performed on personal data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure, or destruction.
• "Data Subject" means the individual to whom personal data relates — in most contexts under this Policy, this means a cuci365 Member or website visitor.
• "Data Controller" means the entity that determines the purposes and means of processing personal data. For the purposes of this Policy, the Data Controller is cuci365.
• "Data Processor" means a third party that processes personal data on behalf of cuci365 under a written data processing agreement.
• "Cookies" means small text files placed on a user's device by a website to store session information, preferences, and tracking data.
• "KYC" (Know Your Customer) means the identity verification process conducted by cuci365 in connection with regulatory obligations and fraud prevention.
• "MYR" means Malaysian Ringgit, the primary transaction currency on the cuci365 platform for Malaysian Members.

cuci365 acts as the Data Controller with respect to the personal data of its Members and website visitors. As Data Controller, cuci365 is responsible for determining the purposes for which your personal data is collected and the manner in which it is processed.

For all privacy-related enquiries, requests to exercise your data subject rights, or concerns regarding the handling of your personal data, please contact our designated Privacy Officer using the contact details provided in Section 15 of this Policy.

cuci365 collects personal data in the following categories, depending on how you interact with the platform:

cuci365 does not collect sensitive personal data (such as data revealing racial or ethnic origin, political opinions, religious beliefs, or health data) unless explicitly required for the fulfilment of responsible gambling obligations (e.g., self-exclusion based on a self-declared vulnerability).

cuci365 processes your personal data for the following purposes:

• Account Management: Creating and maintaining your Member account, verifying your identity, processing KYC documentation, and ensuring the security and integrity of your account.
• Transaction Processing: Facilitating MYR deposits and withdrawals via approved Malaysian payment channels (Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong Bank, USDT TRC20), verifying transaction legitimacy, and maintaining complete financial records.
• Service Delivery: Providing access to the game library, sports betting markets, live casino products, and all other platform services. Personalising your platform experience based on your preferences and activity history.
• Regulatory Compliance: Meeting anti-money laundering (AML), counter-terrorism financing (CTF), and KYC obligations applicable to licensed gaming operators. Retaining transaction records for the minimum period required by applicable law.
• Responsible Gambling: Monitoring gaming patterns for indicators of problem gambling, enforcing deposit limits and self-exclusion requests, and administering the cuci365 responsible gambling programme in accordance with our Responsible Gambling Policy.
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent activity, account abuse, money laundering, and other prohibited conduct. Monitoring for suspicious technical activity.
• Customer Support: Responding to your enquiries, resolving disputes, processing complaints, and maintaining records of support interactions for quality and training purposes.
• Marketing Communications: Sending promotional emails, bonus notifications, and VIP programme updates to Members who have not opted out of marketing communications. You may opt out at any time by updating your communication preferences in account settings or by contacting Support.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve platform performance, game selection, payment processing speeds, and user experience.

cuci365 processes your personal data on one or more of the following legal bases:

• Contractual Necessity: Processing is necessary for the performance of the contract between cuci365 and you as a Member (i.e., the Terms & Conditions). This covers account management, transaction processing, and service delivery.
• Legal Obligation: Processing is required for cuci365 to comply with applicable legal requirements, including AML/CTF obligations, KYC verification mandates, and data retention requirements under gaming regulations.
• Legitimate Interests: Processing is necessary for the legitimate interests of cuci365, such as fraud prevention, platform security, and product improvement — provided that those interests are not overridden by your rights and interests as a Data Subject.
• Consent: Where cuci365 relies on your consent as the legal basis for processing (e.g., for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

cuci365 does not sell your personal data to third parties. We do not disclose your personal data to external organisations for their own marketing purposes. Personal data may be shared with third parties only in the following circumstances:

• Payment Processors and Financial Institutions: Your financial data is shared with the relevant payment gateway operators (such as FPX, DuitNow processors, e-wallet providers) to the minimum extent necessary to complete your deposit or withdrawal transaction.
• Identity Verification Providers: KYC documentation (e.g., MyKad images, selfie photographs, proof of address) may be shared with licensed identity verification service providers engaged by cuci365 to perform document authentication and liveness checks.
• Regulatory and Law Enforcement Authorities: cuci365 may be required by law to disclose personal data to relevant governmental authorities, financial intelligence units, or law enforcement agencies in connection with AML/CTF investigations or other legal proceedings.
• Technology and Infrastructure Providers: Certain technical service providers — including cloud hosting providers, cybersecurity platforms, and platform infrastructure vendors — may process personal data on cuci365's behalf as Data Processors under binding data processing agreements.
• Professional Advisers: Legal advisers, auditors, and compliance consultants engaged by cuci365 may access personal data to the extent required to provide their professional services, subject to confidentiality obligations.

All third-party Data Processors engaged by cuci365 are required to implement appropriate technical and organisational security measures and to process personal data only on documented instructions from cuci365.

cuci365 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following retention periods apply as a general guide:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with cuci365's data disposal procedures.

cuci365 uses cookies and similar tracking technologies to enhance platform functionality, analyse usage patterns, and deliver a personalised experience. The following categories of cookies are used on the cuci365 platform:

• Strictly Necessary Cookies: Essential for the operation of the platform. These cookies enable core functions such as session management, account authentication, and security features. They cannot be disabled without impairing platform functionality.
• Functional Cookies: Used to remember your preferences and settings (such as language selection and responsible gambling limit configurations) to provide a consistent experience across sessions.
• Analytical Cookies: Used to collect aggregated, anonymised data on how Members navigate and interact with the platform, helping cuci365 identify areas for improvement in user experience and performance.
• Marketing Cookies: May be used to deliver relevant promotional content and bonus notifications to Members based on their activity on the platform. Marketing cookies are subject to your consent where required by applicable law.

You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies may prevent access to certain platform features. Analytical and marketing cookies may be opted out of without affecting core platform access.

cuci365 implements technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security framework includes:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and cuci365 servers is encrypted using industry-standard SSL/TLS protocols. Look for the padlock icon in your browser's address bar when accessing the platform.
• Secure Data Storage: Personal data is stored in access-controlled environments with strict internal access rights limiting data visibility to authorised personnel only.
• Two-Factor Authentication (2FA): cuci365 offers optional two-factor authentication for account login, providing an additional layer of security beyond username and password credentials.
• Regular Security Audits: The cuci365 platform undergoes periodic third-party security assessments and penetration testing to identify and remediate vulnerabilities.
• Fraud Monitoring: Automated and manual monitoring systems detect anomalous activity, unusual login patterns, and suspicious transaction behaviour in real time.

No data transmission over the internet or electronic storage system is entirely infallible. While cuci365 employs robust security practices, we cannot guarantee absolute security against all possible threats. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, cuci365 will notify affected Members without undue delay as required by applicable law.

As a Data Subject, you have the following rights with respect to your personal data held by cuci365. To exercise any of these rights, please contact our Privacy Officer using the contact details in Section 15. cuci365 will respond to verifiable requests within thirty (30) days of receipt.

• Right of Access: You have the right to request a copy of the personal data that cuci365 holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data. You may update certain account details (such as email address or contact number) directly through your account profile.
• Right to Erasure: You have the right to request deletion of your personal data in certain circumstances — for example, where the data is no longer necessary for the purposes for which it was collected, or where you have withdrawn consent. This right is subject to cuci365's legal obligations to retain certain data (see Section 8).
• Right to Restriction of Processing: You have the right to request that cuci365 restrict the processing of your personal data in certain circumstances, such as while a complaint or accuracy dispute is under investigation.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller, where technically feasible and where processing is based on consent or contract.
• Right to Object: You have the right to object to the processing of your personal data where cuci365 relies on legitimate interests as the legal basis for processing. You also have an absolute right to object to processing for direct marketing purposes at any time.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

cuci365 will not charge a fee for handling data subject requests made in good faith. However, we reserve the right to charge a reasonable fee or decline to act on requests that are manifestly unfounded, excessive, or repetitive.

The cuci365 platform is strictly intended for individuals aged 21 years and above. cuci365 does not knowingly collect personal data from individuals under the age of 21. The registration process requires applicants to confirm that they are aged 21 or above, and age verification is conducted as part of the KYC process.

If cuci365 becomes aware that personal data has been collected from an individual under the age of 21, the relevant account will be immediately suspended, all personal data associated with that account will be deleted (subject to any mandatory legal retention obligations), and any funds held in the account will be returned to the verified depositor.

If you believe that a minor may have registered an account on cuci365, please notify us immediately by contacting Support at the email address provided in Section 15.

The operation of the cuci365 platform may involve the transfer of your personal data to servers or third-party processors located outside Malaysia. In such cases, cuci365 takes appropriate steps to ensure that your personal data receives a level of protection equivalent to that which it would receive under applicable Malaysian data protection standards.

Where personal data is transferred to third-party processors operating in other jurisdictions, cuci365 requires such processors to enter into data processing agreements that impose binding data protection obligations consistent with this Policy. Transfers are conducted only to the extent necessary for the legitimate operational purposes of the platform.

cuci365 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform operations. When material changes are made, we will update the "Last Updated" date at the top of this page and, where appropriate, notify active Members via their registered email address or through an in-platform notice.

We encourage you to review this Policy periodically. Your continued use of the cuci365 platform following the publication of an updated Policy constitutes your acceptance of the revised terms. If you object to any changes, please contact our Support team to discuss your options, including account closure.

For all privacy-related matters, requests to exercise your data subject rights, or questions about this Privacy Policy, please contact the cuci365 Privacy Officer through the following channels:

For queries relating to our Terms & Conditions or Responsible Gambling policies, please refer to the respective dedicated pages or contact our Support team directly.