Privacy Policy 88cuci — Our Commitment to Protecting Your Data

1. Introduction

88cuci (hereinafter referred to as "we", "our platform", or "88cuci") operates as a registered online entertainment and casino platform in Malaysia. We understand that your trust is our most valuable asset, and protecting your personal data is a core part of our responsibility.

This Privacy Policy explains in detail how we collect, process, store, share, and protect your personal information when you use the website, mobile app, and all services provided by 88cuci. This Policy applies to all users regardless of access method — whether via web browser, Android app, or iOS app.

By registering an account or continuing to use the 88cuci platform after reading this Privacy Policy, you are deemed to have understood and agreed to all terms contained herein. If you do not agree with any part of this Policy, you have the right to discontinue use of our services.

2. Data We Collect

We collect personal data across several categories depending on your interactions with the 88cuci platform. Below is a comprehensive overview of the types of data we collect:

2.1 Data You Provide Directly

• Identity Information: Full name, identification number (MyKad/Passport), date of birth, gender;
• Contact Information: Malaysian phone number, email address, residential address;
• Financial Information: Bank account number, bank name, account holder name, e-wallet details (Touch 'n Go eWallet, GrabPay, Boost, DuitNow);
• KYC Documents: ID card image, selfie for verification, bank statement (if required);
• Communications: Customer support chat records, emails, and feedback you have submitted to us.

2.2 Data Collected Automatically

• Technical Data: IP address, browser type, operating system, device model, app version;
• Usage Data: Pages visited, time spent, click actions, navigation paths;
• Gaming Data: Wagering records, game history, wins and losses, gaming patterns;
• Location Data: Approximate location based on IP address for legal compliance purposes;
• Cookie Data: Session cookies, preference cookies, and analytics cookies (detailed in Section 9).

3. How We Use Your Data

The personal data we collect is used for lawful and transparent purposes. Below is a summary table of how your data is used:

We will not use your data for any purpose other than those stated above without obtaining your consent first, unless required by law.

4. Legal Basis for Data Processing

In accordance with Malaysia's PDPA 2010, all processing of your personal data by 88cuci is carried out on a clear legal basis. We rely on the following grounds:

• Consent: For marketing communications, non-essential cookies, and optional data processing. You may withdraw your consent at any time;
• Contract Performance: To provide the services you request — account registration, payment processing, and support services;
• Legal Obligation: To comply with KYC requirements, anti-money laundering (AML) obligations, and reporting to the relevant authorities;
• Legitimate Interest: For platform security, fraud prevention, and service improvement — provided these interests do not override your privacy rights.

5. Data Sharing with Third Parties

88cuci does not sell, rent, or disclose your personal data to third parties for their own marketing purposes. However, we may share your data in the following limited circumstances:

5.1 Trusted Service Providers

We work with carefully selected third-party service providers to support platform operations. These include:

• Licensed payment gateway providers (for processing deposits and withdrawals);
• KYC identity verification services;
• Cloud and computing infrastructure providers;
• Analytics and fraud prevention services;
• Licensed gaming software providers.

All these providers are bound by strict data protection agreements and are only permitted to use your data for purposes we have specified.

5.2 Authorities and Regulatory Bodies

We may disclose your data to government authorities, law enforcement, or regulatory bodies when required by Malaysian law — including for financial crime investigations, anti-money laundering purposes, or court orders.

6. Data Security

We invest seriously in technical and organizational security to protect your personal data from unauthorized access, loss, misuse, or accidental disclosure. Our key security measures include:

• Encryption in Transit: TLS 1.3 protocol for all communications between your browser/app and our servers;
• Static Encryption: Sensitive data is stored in encrypted format using AES-256 standards;
• Access Controls: Principle of least privilege — only staff who require access to your data may do so, and every access is logged and monitored;
• Security Audit: Penetration testing and security assessments are conducted periodically by independent parties;
• 24/7 Monitoring: Real-time threat detection system that monitors unusual activity around the clock;
• Two-Factor Authentication (2FA): Available to all member accounts as an additional layer of protection.

7. Data Retention Period

We do not retain your personal data longer than necessary for the purposes stated in this Privacy Policy or as required by law. General data retention periods are as follows:

• Active Account Data: For the duration your account is active plus 7 years after account closure (financial compliance requirement);
• Financial Transaction Records: Minimum 7 years as required by the Malaysian Companies Act and financial regulations;
• KYC Documents: For the lifetime of the account and 5 years after closure or termination;
• Support Communication Logs: 3 years from the date of last interaction;
• Anonymous Analytics Data: May be retained indefinitely as it contains no personal identifiers;
• Session Cookie Data: Deleted when the session ends or the browser is closed.

Once the retention period expires, your data will be securely deleted or anonymised so that it can no longer be linked to your identity.

8. Your Rights as a Data Subject

Under Malaysia's PDPA 2010, you have the following rights regarding your personal data held by 88cuci:

8.1 How to Exercise Your Rights

To exercise any of the above rights, you may contact our privacy team via:

• Email: [email protected] with the subject line "Privacy Rights Request";
• Live chat within the platform by stating your purpose;
• Via the account settings section for access requests and basic corrections.

We will process your request within 21 working days from the date of receipt. For complex requests, this period may be extended up to 60 days with prior notification to you. Identity verification may be required before we process any request.

9. Cookies and Tracking Technologies

88cuci uses cookies and similar tracking technologies to ensure the platform functions properly, enhance the user experience, and understand usage patterns. The following are the types of cookies we use:

• Essential Cookies: Required for core platform functions such as login authentication and session security. Cannot be disabled;
• Preference Cookies: Saves your settings such as preferred language and display theme. Can be disabled;
• Analytics Cookies: Collects anonymous usage data to help us understand how the platform is used and improve the user experience. Can be disabled;
• Security Cookies: Helps detect suspicious activity and protect your account from unauthorized access. Cannot be disabled.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect platform functionality. For mobile app users, permission management is handled through your device settings.

10. Children's Data Protection

The 88cuci platform is exclusively for users aged 18 and above. We do not intentionally collect, store, or process any personal data from individuals under the age of 18.

If we identify that personal data of a minor has been collected inadvertently, we will take immediate steps to delete that data and close the associated account. If you believe your child may have registered or provided data to us, please contact us immediately at [email protected].

11. International Data Transfers

In the course of its operations, 88cuci may transfer your personal data to servers or service providers located outside Malaysia. This includes the use of cloud infrastructure from leading providers that may have data centres in multiple countries.

When data is transferred outside Malaysia, we ensure protection equivalent to Malaysia's PDPA standards through the following mechanisms:

• Legally binding data transfer agreements with data recipients;
• Internationally recognized standard data protection clauses;
• Verification that the recipient country maintains an adequate level of data protection;
• Use of data anonymisation techniques for transfers that do not require personal identification.

12. Changes to This Privacy Policy

88cuci reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our privacy practices, legal requirements, or platform service updates. The latest version of this Privacy Policy is always available on this page, with the "Updated" date clearly displayed at the top.

For material and significant changes that affect your privacy rights, we will notify you via:

• In-platform notifications upon login;
• Email to the address registered in your account;
• Information banners displayed on our website.

Your continued use of the 88cuci platform after any changes take effect will be considered your acceptance of the updated Privacy Policy. If you disagree with the changes, you may close your account and contact us to request data deletion.

13. Contact Our Privacy Officer

If you have any questions, concerns, or complaints regarding this Privacy Policy or how 88cuci handles your personal data, please do not hesitate to contact us. Our Data Protection Officer (DPO) is ready to address every enquiry with care and full attention.

• Privacy Email: [email protected] (please mark the subject: "Privacy Enquiry");
• Live Chat: Available 24/7 via the support icon at the bottom corner of the platform;
• Response Time: We aim to respond to all privacy inquiries within 3 business days.

You also have the right to lodge a complaint with the Malaysian Communications and Multimedia Commission (MCMC) or the relevant data protection authority if you believe your privacy rights have been violated and have not been satisfactorily resolved by us.