Privacy Policy – How 99cuci Handles Your Personal Data

1 Introduction

99cuci ("the Platform", "we", "us", "our") is committed to protecting the privacy and personal data of all registered members and visitors to the 99cuci platform. This Privacy Policy ("Policy") describes how 99cuci collects, uses, stores, shares, and protects personal information in connection with your use of the platform, including all betting, gaming, payment, and customer support services.

This Policy applies to all personal data processed by 99cuci in connection with the operation of the platform and is intended to be read alongside the Terms & Conditions and Responsible Gaming Policy, both of which form part of the overall agreement between you and 99cuci.

By registering an account on 99cuci or continuing to use the platform, you confirm that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you should not create an account or continue using the platform.

99cuci takes its obligations under applicable data protection legislation seriously. Our data handling practices are designed to align with internationally recognised principles of data minimisation, purpose limitation, accuracy, storage limitation, integrity, confidentiality, and accountability.

2 Personal Data We Collect

99cuci collects personal data in two primary ways: information you provide directly, and information collected automatically through your use of the platform.

Information you provide directly:

• Registration data: Full legal name, Malaysian mobile phone number, email address, date of birth, and chosen username and password
• KYC / identity verification data: Photograph or scan of your MyKad, passport, or other government-issued identity document; proof of address documentation; source of funds declaration where required by our AML compliance obligations
• Payment information: Bank account details, eWallet identifiers (Touch n Go, Boost, GrabPay), FPX transaction references, and cryptocurrency wallet addresses (for USDT transactions). Note: 99cuci does not store full card numbers as the platform does not accept card payments
• Communications data: The content of live chat transcripts, WhatsApp messages, and email correspondence with 99cuci customer support
• Responsible gaming data: Any deposit limits, cooling-off periods, or self-exclusion requests you submit

Information collected automatically:

• Device and access data: IP address, browser type and version, operating system, device type (desktop, mobile, tablet), screen resolution, and referring URL
• Session and activity data: Login timestamps, pages visited, game sessions initiated, bets placed (type, stake, odds, outcome), and session duration
• Cookies and similar technologies: See Section 6 for full details on cookie usage
• Geolocation data: Approximate geographic location derived from IP address, used solely for regulatory compliance purposes (access restriction from prohibited jurisdictions)

3 How We Use Your Personal Data

99cuci uses the personal data it collects for the following specific purposes:

• Account creation and management: To register your account, verify your identity, maintain your account records, and process login authentication
• Service delivery: To provide access to sports betting, live casino, slots, and all other platform services; to process deposit and withdrawal transactions; to apply bonuses and promotions to your account
• KYC and AML compliance: To verify your identity before processing withdrawals; to monitor transaction patterns for money laundering indicators; to fulfil 99cuci's obligations under applicable anti-money laundering and counter-terrorism financing regulations
• Fraud prevention and security: To detect and prevent unauthorised access to accounts, fraudulent transactions, multi-accounting, and abuse of bonus offers; to investigate and resolve security incidents
• Responsible gaming: To implement and enforce the deposit limits, cooling-off periods, and self-exclusion requests you have set; to identify accounts exhibiting patterns associated with problem gambling and take appropriate protective action
• Customer support: To respond to your enquiries, resolve disputes, and process complaints
• Legal and regulatory compliance: To meet 99cuci's obligations under applicable gaming, financial, and data protection regulations; to cooperate with lawful requests from regulatory authorities and law enforcement agencies
• Platform improvement: To analyse aggregated, anonymised usage data to improve the platform's functionality, performance, and user experience. Individual user data is not used for this purpose without anonymisation
• Communications: To send you transactional communications (account activity alerts, withdrawal confirmations, security notifications) and, where you have given separate consent, promotional communications about bonuses and offers

99cuci does not use your personal data for automated individual decision-making that produces legal or similarly significant effects without human review.

4 Legal Basis for Processing

99cuci processes your personal data on the following legal grounds depending on the purpose of processing:

• Performance of a contract: The majority of processing activities — account management, transaction processing, service delivery — are necessary for the performance of the contract between you and 99cuci (as set out in the Terms & Conditions)
• Legal obligation: KYC identity verification, AML monitoring, and cooperation with regulatory and law enforcement authorities are required by law and cannot be opted out of
• Legitimate interests: Fraud detection, security monitoring, and platform improvement based on anonymised analytics are carried out on the basis of 99cuci's legitimate business interests, where those interests are not overridden by your privacy rights
• Consent: Promotional communications (marketing emails, bonus notifications) are sent only where you have given explicit, informed consent. You may withdraw this consent at any time via your account settings or by contacting support

5 Data Sharing & Third-Party Disclosure

99cuci does not sell, rent, or trade your personal data to third parties for their own marketing purposes. Personal data may be shared with third parties only in the following circumstances:

• Game content providers: Providers such as Evolution Gaming, Pragmatic Play, Playtech, PG Soft, and others receive limited session data necessary to deliver and authenticate game content. These providers are contractually required to process this data only for the purpose of delivering services to 99cuci
• Payment processors: Banks, eWallet operators (Touch n Go, Boost, GrabPay), FPX infrastructure, and cryptocurrency processing services receive the transaction and identity data necessary to complete deposits and withdrawals
• KYC verification services: Third-party identity verification providers may process your identity document data to assist with KYC checks. These providers operate under strict data processing agreements and are not permitted to use your data for any purpose beyond the verification service
• Regulatory authorities: 99cuci will disclose personal data to relevant gaming regulators, financial intelligence units, and law enforcement agencies where required to do so by applicable law or a valid legal order
• Professional advisors: Legal, accounting, and audit firms acting as professional advisors to 99cuci may access personal data to the minimum extent necessary for the provision of their professional services, under confidentiality obligations
• Business transfers: In the event of a merger, acquisition, or sale of substantially all of 99cuci's assets, personal data held by 99cuci may be transferred to the acquiring entity. You will be notified of any such transfer via the contact details on your account

Any third party with whom personal data is shared is required to implement appropriate data protection measures and is prohibited from using the data for any purpose beyond that for which it was shared.

6 Cookies & Tracking Technologies

99cuci uses cookies and similar tracking technologies to operate and improve the platform. The types of cookies used are:

• Strictly necessary cookies: Essential for platform operation — session authentication tokens, CSRF protection tokens, and load-balancing cookies. These cannot be disabled without preventing core platform functionality
• Functional cookies: Store your preferences such as language settings, preferred deposit method, and display options to personalise your experience on return visits
• Analytics cookies: Collect anonymised data about how members use the platform — which pages are visited, how long sessions last, and which features are most used. This data is aggregated and does not identify individuals
• Security cookies: Support fraud detection and account security by allowing 99cuci to identify suspicious patterns of access or unusual device fingerprints

99cuci does not use third-party advertising cookies or allow advertising networks to place cookies on the platform. You can manage cookie preferences through your browser settings, though disabling strictly necessary cookies will impair your ability to use the 99cuci platform.

7 Data Retention

99cuci retains personal data for as long as is necessary for the purposes for which it was collected, subject to the following minimum retention periods:

• Account and identity data: Retained for a minimum of 5 years following account closure, in compliance with applicable AML record-keeping requirements
• Transaction records: Retained for a minimum of 5 years following each transaction, for financial regulatory compliance purposes
• Customer support communications: Retained for 2 years following resolution of the relevant query or complaint
• Gaming activity records: Retained for 5 years, required for regulatory audit purposes and dispute resolution
• Marketing consent records: Retained until consent is withdrawn, plus 2 years for legal documentation purposes

Following the expiry of applicable retention periods, personal data is securely deleted or anonymised so that it can no longer be attributed to an identifiable individual.

8 Data Security

99cuci implements technical and organisational measures designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• HTTPS / TLS encryption for all data transmitted between your device and the 99cuci platform
• Encryption at rest for sensitive personal data fields including identity document data and payment identifiers
• Role-based access controls limiting staff access to personal data on a need-to-know basis
• Two-factor authentication requirements for staff accessing member data
• Regular penetration testing and vulnerability assessments conducted by independent security firms
• Intrusion detection systems and real-time monitoring of access logs
• Formal incident response procedures for data security breaches, including notification obligations

While 99cuci takes all reasonable precautions, no security system is completely impenetrable. In the event of a data breach that poses a material risk to your rights, 99cuci will notify affected members as required by applicable law. You can help protect your account by using a strong, unique password and enabling two-factor authentication in your account security settings.

9 Your Data Rights

Subject to applicable law and the legitimate interests of 99cuci in operating a secure, compliant platform, you have the following rights with respect to your personal data:

• Right of access: You may request a copy of the personal data 99cuci holds about you. Requests will be fulfilled within 30 days of receipt
• Right to rectification: You may request correction of inaccurate or incomplete personal data. Basic account data can be updated directly through your account settings
• Right to erasure: You may request deletion of your personal data in certain circumstances. Note that data required for legal compliance (AML records, transaction history) cannot be deleted before the applicable retention period expires
• Right to restrict processing: You may request that 99cuci limit the processing of your personal data in certain circumstances, such as while a dispute about data accuracy is being resolved
• Right to data portability: You may request your personal data in a structured, commonly used, machine-readable format where technically feasible
• Right to withdraw consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal
• Right to object: You may object to processing of your personal data carried out on the basis of legitimate interests, where your particular circumstances give grounds for such an objection

To exercise any of these rights, contact 99cuci customer support via live chat or email at [email protected] (plain text — not a hyperlink). Requests will be responded to within 30 days.

10 Children's Privacy

The 99cuci platform is strictly intended for persons who are 21 years of age or older. 99cuci does not knowingly collect, use, or store personal data from persons under 21. If 99cuci becomes aware that personal data has been collected from an individual under the age of 21, all associated data will be permanently deleted and the account will be closed immediately.

If you are a parent or guardian and believe that a minor in your care has registered an account on 99cuci, please contact support immediately via live chat so that we can take prompt action.

11 Changes to This Privacy Policy

99cuci reserves the right to update this Privacy Policy at any time. Material changes — those that substantively affect how your personal data is collected, used, or shared — will be communicated to registered members via the email address on file and/or a prominent notice on the platform no fewer than 7 days before the changes take effect.

Non-material changes, such as formatting updates or clarifications that do not alter the substance of any processing activity, may be made without advance notice. The "Last updated" date at the top of this Policy will always reflect the most recent revision. Your continued use of the 99cuci platform after the effective date of any change constitutes acceptance of the revised Policy.

12 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by 99cuci, please contact us through any of the following channels:

• Live Chat: Available 24/7 through the member portal — fastest response channel
• WhatsApp: Number displayed within your 99cuci account after login
• Email: [email protected] — plain text, not a clickable link

Data-related requests (access, erasure, portability) should be submitted in writing via email with the subject line "Data Rights Request" to ensure they are routed to the appropriate team. You will receive an acknowledgement within 24 hours and a substantive response within 30 days.