Privacy Policy
cucicuci is committed to protecting the personal data of every player on our platform. This Privacy Policy explains what information we collect, how we use it, who we share it with, and the rights you have over your own data as a user of cucicuci.cam.
Key Privacy Commitments
cucicuci does not sell, rent, or trade your personal information to any third-party marketing organisations or data brokers. Your data is processed solely for the purpose of operating and improving your account experience.
All data transmitted between your browser and cucicuci's servers is protected by industry-standard 256-bit SSL encryption. Financial data including payment credentials and e-wallet details are never stored in plaintext.
You have the right to access, correct, export, and request deletion of your personal data at any time. Submit a data subject request through our support team and we will respond within the timeframes specified in this Policy.
We collect only the data that is strictly necessary for platform operation, payment processing, and regulatory compliance. We do not collect data we do not have a legitimate purpose to hold.
Where we share data with third parties — such as payment processors like DuitNow, FPX, Touch 'n Go, Boost, and GrabPay — we do so only under contractual data processing agreements that require them to protect your information.
If you have consented to receive promotional communications, you may withdraw that consent at any time by updating your preferences in your account settings or by contacting our support team. Opt-out requests are processed within 48 hours.
- 1. Introduction
- 2. Definitions
- 3. Data Controller
- 4. Data We Collect
- 5. How We Use Your Data
- 6. Legal Basis for Processing
- 7. Data Sharing & Disclosure
- 8. Payment Data Processing
- 9. Cookies & Tracking
- 10. Data Retention
- 11. Data Security
- 12. International Transfers
- 13. Your Rights
- 14. Children & Minors
- 15. Changes to This Policy
- 16. Contact Us
Introduction
This Privacy Policy ("Policy") describes how cucicuci ("Company", "We", "Us", "Our"), the operator of the online gaming platform at cucicuci.cam ("Platform"), collects, processes, stores, and discloses personal data relating to individuals who access or use the Platform ("Users", "Players", "You", "Your").
cucicuci operates as an online casino and sports betting platform serving users primarily in Malaysia and surrounding jurisdictions. As part of our operations, we necessarily collect and process personal data in order to provide our services, meet our regulatory obligations, and protect the integrity of our platform.
This Policy should be read in conjunction with our Terms & Conditions and Responsible Gambling Policy, both of which contain additional provisions that may be relevant to how we handle data in specific contexts.
Your Consent: By registering an account on cucicuci or continuing to use the Platform after the effective date of this Policy, you acknowledge that you have read and understood its contents and agree to the processing of your personal data as described herein.
Definitions
For the purposes of this Policy, the following definitions apply:
| Term | Meaning |
|---|---|
| "Personal Data" | Any information relating to an identified or identifiable natural person, including name, identification number, contact details, financial information, or online identifiers. |
| "Processing" | Any operation performed on personal data, including collection, storage, use, disclosure, alteration, or deletion. |
| "Data Controller" | The entity that determines the purposes and means of processing personal data. cucicuci is the Data Controller for data processed on this Platform. |
| "Data Processor" | A third party that processes personal data on behalf of the Data Controller, subject to contractual data processing obligations. |
| "Sensitive Data" | A subset of personal data requiring heightened protection, including financial account details, government-issued identification numbers, and data relating to health or problem gambling status. |
| "Cookie" | A small text file placed on a User's device by the Platform to enable functionality, analytics, and session management. |
Data Controller
cucicuci, as the operator of cucicuci.cam, acts as the Data Controller in respect of all personal data collected from Users of the Platform. This means that cucicuci determines the purposes for which your personal data is collected and the manner in which it is processed.
Where cucicuci engages third-party service providers — such as payment processors, fraud prevention services, and customer communication platforms — those providers act as Data Processors under written agreements that bind them to process your data only as instructed by cucicuci and to maintain appropriate security standards.
If you have any queries regarding the identity of the Data Controller or wish to exercise your data rights, please contact us at the details set out in Section 16 of this Policy.
Data We Collect
cucicuci collects personal data in several ways: directly from you when you register an account or use Platform features; automatically through your use of the Platform; and in some cases, from third-party sources as part of our verification and fraud prevention processes.
4.1 Registration Data
When you create a cucicuci account, we collect:
- Full legal name
- Date of birth (for age verification — 21+ requirement)
- Email address
- Malaysian mobile phone number
- Residential address (including city — e.g., Kuala Lumpur, Petaling Jaya, Johor Bahru, Penang, Shah Alam)
- Username and encrypted password
- Preferred currency (MYR)
4.2 Identity Verification (KYC) Data
As part of our Know Your Customer (KYC) compliance obligations, we may collect:
- Copy of government-issued photo identity document (e.g., MyKad, passport, or Malaysian driver's licence)
- Proof of residential address (e.g., utility bill, bank statement)
- Proof of payment method ownership
- Source of funds documentation for high-value accounts
4.3 Financial Transaction Data
When you make deposits or withdrawals, we collect:
- Transaction amounts and timestamps
- Payment method type (e.g., Touch 'n Go eWallet, Boost, Maybank FPX, CIMB, DuitNow, GrabPay, USDT TRC20)
- Transaction reference numbers
- Account balance history
We do not store full bank account numbers, card numbers, or e-wallet PINs. Payment authentication is handled directly by the relevant payment processor.
4.4 Usage and Technical Data
Automatically collected data when you use the Platform includes:
- IP address and approximate geolocation
- Device type, operating system, and browser version
- Session duration, pages visited, and features accessed
- Betting and gaming activity logs
- Login timestamps and security event logs
4.5 Communications Data
When you contact our support team via live chat or email, we retain records of those communications, including the content of messages, timestamps, and any attachments submitted as part of a support request or complaint.
How We Use Your Data
cucicuci processes your personal data only for defined, legitimate purposes. The table below sets out the primary purposes for which we use your data and the category of data involved in each case.
| Purpose | Data Categories Used |
|---|---|
| Account Registration & Management | Registration data, identity verification data, communications data |
| Payment Processing | Financial transaction data, identity verification data |
| KYC & AML Compliance | Identity verification data, financial transaction data, usage data |
| Fraud Prevention & Security | Technical data, usage data, financial transaction data |
| Responsible Gambling Monitoring | Usage data, betting activity logs, account history |
| Customer Support | Communications data, registration data, transaction data |
| Platform Improvement & Analytics | Technical data, usage data (aggregated and anonymised where possible) |
| Marketing Communications (with consent) | Registration data, usage data, preferences |
| Legal & Regulatory Obligations | All categories as required by applicable law |
Legal Basis for Processing
cucicuci processes personal data on the following legal bases, depending on the specific processing activity:
- Contractual Necessity: Processing necessary to perform our obligations under the Terms and Conditions you have agreed to — including account creation, payment processing, and game service delivery.
- Legal Obligation: Processing required for cucicuci to comply with applicable anti-money laundering (AML), counter-terrorism financing (CTF), and responsible gambling regulatory requirements.
- Legitimate Interests: Processing for fraud prevention, platform security, and improvement of our services — where such interests are not overridden by your data protection rights.
- Consent: Processing for marketing communications, where you have given us your explicit consent. You may withdraw this consent at any time.
Data Sharing & Disclosure
cucicuci does not sell, rent, or trade your personal data. We share your data only in the following limited and controlled circumstances:
7.1 Payment Service Providers
To process your deposits and withdrawals, we share transaction-relevant data with licensed payment processors. These include operators of e-wallet services (Touch 'n Go eWallet, Boost, GrabPay), banking payment gateways (DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong), and cryptocurrency transaction facilitators for USDT TRC20 transactions. These providers are contractually bound to protect your data.
7.2 Identity Verification Providers
To comply with KYC obligations, we may share identity documents and personal information with licensed identity verification service providers. Such providers process data solely for verification purposes and are bound by strict confidentiality and data protection obligations.
7.3 Regulatory and Law Enforcement Bodies
cucicuci may disclose personal data to competent regulatory authorities, law enforcement agencies, or courts where required to do so by applicable law, including in connection with investigations into suspected financial crime, fraud, or other unlawful activities.
7.4 Corporate Transactions
In the event of a merger, acquisition, or sale of all or part of cucicuci's business operations, personal data held by cucicuci may be transferred to the relevant successor entity. You will be notified of any such transfer through a notice posted on the Platform prior to completion.
Payment Data Processing
cucicuci places particular emphasis on the security of financial data. All payment transactions on the Platform are processed through encrypted channels. We do not store full bank account numbers, credit card numbers, e-wallet PINs, or cryptocurrency private keys on our servers at any time.
When you initiate a deposit via Touch 'n Go eWallet, Boost, GrabPay, Maybank FPX, CIMB, or other supported methods, the authentication and payment confirmation step takes place entirely within the respective payment provider's secure environment. cucicuci receives only a transaction confirmation and reference number upon successful payment — not your authentication credentials.
USDT TRC20 Deposits: Cryptocurrency deposit wallet addresses provided to you are unique, session-specific addresses. cucicuci does not hold or manage private keys to any cryptocurrency wallet. All on-chain transaction data is publicly visible on the TRON blockchain by its nature.
Cookies & Tracking Technologies
cucicuci uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies are used:
- Strictly Necessary Cookies: Essential for the Platform to function. These include session management cookies that keep you logged in during your visit. These cannot be disabled without affecting Platform functionality.
- Functional Cookies: Enable the Platform to remember your preferences, such as language settings and game lobby display options.
- Analytics Cookies: Allow us to understand how users navigate the Platform so we can improve the user experience. These cookies collect aggregated, anonymised data and do not identify individual users.
- Security Cookies: Help cucicuci detect and prevent fraudulent activity, including the identification of suspicious login attempts and automated account access.
cucicuci does not use third-party advertising or retargeting cookies. You can manage cookie preferences through your browser settings. Disabling cookies may affect your ability to use certain features of the Platform, including maintaining an active login session.
Data Retention
cucicuci retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:
| Data Category | Retention Period |
|---|---|
| Account & Registration Data | Duration of account + 5 years post-closure (regulatory requirement) |
| KYC & Identity Documents | 5 years from date of submission or account closure, whichever is later |
| Financial Transaction Records | 7 years (AML compliance requirement) |
| Betting & Gaming Activity Logs | 5 years post-account closure |
| Customer Support Communications | 3 years from date of communication |
| Technical & Usage Data | 13 months from collection (rolling) |
| Marketing Preference Records | 3 years from last interaction or opt-out date |
Upon the expiry of applicable retention periods, cucicuci will securely delete or anonymise personal data so that it can no longer be associated with an identifiable individual.
Data Security
cucicuci implements a layered approach to information security, incorporating both technical and organisational controls to protect personal data against unauthorised access, disclosure, alteration, or destruction. Our security measures include:
- Encryption in Transit: All data transmitted between your device and cucicuci's servers is encrypted using TLS 1.2 or higher (256-bit SSL).
- Encryption at Rest: Sensitive personal data stored on cucicuci's infrastructure is encrypted at rest using AES-256 encryption.
- Access Controls: Access to personal data is restricted on a need-to-know basis. Staff with access to personal data are subject to confidentiality obligations and regular security training.
- Two-Factor Authentication (2FA): Available for all Player accounts and mandatory for cucicuci staff with access to production systems.
- Intrusion Detection & Monitoring: Real-time monitoring for anomalous activity, including brute-force login attempts, unusual transaction patterns, and unauthorised data access.
- Regular Security Audits: cucicuci conducts periodic security assessments of its platform infrastructure and data handling practices.
While cucicuci takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You also have a responsibility to protect your own account by using a strong, unique password and enabling 2FA where available.
International Data Transfers
cucicuci's primary operations are designed to serve Malaysian users, and our principal data processing infrastructure is hosted in facilities that apply recognised international security standards. In some cases, personal data may be processed by our service providers in jurisdictions outside Malaysia.
Where such transfers occur, cucicuci ensures that appropriate safeguards are in place, including contractual data processing agreements that require receiving parties to protect your data to a standard at least equivalent to that described in this Policy. cucicuci does not transfer personal data to jurisdictions that do not provide adequate data protection without implementing appropriate supplementary safeguards.
Your Rights
As a data subject, you have the following rights in relation to the personal data that cucicuci holds about you. To exercise any of these rights, please contact us using the details in Section 16.
You have the right to request a copy of the personal data cucicuci holds about you. We will provide this within 30 days of a verified request.
If any personal data we hold is inaccurate or incomplete, you have the right to request that it be corrected or updated promptly.
You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected — subject to our legal retention obligations (see Section 10).
Where processing is based on your consent or contractual necessity, you have the right to receive your personal data in a structured, machine-readable format for transfer to another controller.
You have the right to object to processing of your personal data where it is based on legitimate interests, including for direct marketing purposes.
In certain circumstances, you have the right to request that we restrict the processing of your personal data while a dispute or review is pending.
cucicuci will respond to all verified data subject requests within 30 calendar days. Where a request is complex or involves a large volume of data, this period may be extended by a further 60 days, of which you will be notified. We may need to verify your identity before processing a data rights request.
Children & Minors
The cucicuci Platform is strictly prohibited for use by individuals under the age of 21 years. We do not knowingly collect personal data from any person under 21. If cucicuci becomes aware that personal data has been collected from a person under this minimum age, we will immediately suspend the relevant account, delete the data, and return any deposited funds to the payment source.
Parents and guardians who believe that a minor may have registered on the Platform should contact us immediately at the details in Section 16.
Age Restriction: cucicuci is strictly for players aged 21 and above. Underage gambling is prohibited and harmful. If you know someone under 21 using this Platform, please report it to our support team immediately.
Changes to This Privacy Policy
cucicuci reserves the right to update or revise this Privacy Policy at any time. Material changes to this Policy will be communicated to registered users via email notification and/or through a prominent notice displayed on the Platform prior to the changes taking effect. The effective date at the top of this document will be updated to reflect the date of each revision.
Your continued use of the Platform following notification of any changes constitutes your acceptance of the revised Policy. If you do not accept the updated terms, you should cease using the Platform and may request account closure in accordance with the Terms and Conditions.
Previous versions of this Privacy Policy are available upon request by contacting our support team.
Contact Us
If you wish to exercise any of your data rights, have a question about this Privacy Policy, or wish to raise a concern about how cucicuci processes your personal data, please contact our Privacy and Data Protection team using the details below.
For formal data subject access requests, please include your full name, account registered email address, and a clear description of the right you wish to exercise. cucicuci will verify your identity before processing any data rights request. Responses will be provided within 30 calendar days.
Privacy Understood. Play with Confidence on cucicuci.
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