cucicuci Privacy Policy

1. Introduction & Scope

cucicuci ("cucicuci", "we", "us", "our") operates the online gaming platform accessible at cucicuci.win and through associated mobile applications (collectively, the "Platform"). cucicuci is an online gaming brand operating under international gaming authority licensing.

This Privacy Policy ("Policy") describes how cucicuci collects, uses, discloses, and safeguards personal data provided by or collected about users of the Platform ("Members", "you"). It applies to all personal data processed in connection with your use of cucicuci, regardless of how you access the Platform — whether through a web browser on your phone in Kuala Lumpur, the cucicuci Android app on a device in Penang, or any other access method.

This Policy should be read alongside our Terms & Conditions and our Responsible Gaming policy. Terms not defined in this Policy have the meanings given in the Terms & Conditions.

By using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and use of your personal data as described herein.

2. Categories of Personal Data We Collect

cucicuci collects the following categories of personal data about you:

cucicuci does not collect sensitive personal data such as racial or ethnic origin, religious beliefs, health information, or political opinions, except where required by applicable law or our regulatory obligations.

3. How Personal Data Is Collected

cucicuci collects personal data through the following means:

• Direct provision by you — when you register an account, complete KYC verification, make deposits or withdrawals, contact our support team, or participate in promotions;
• Automated technical collection — through cookies, log files, and platform analytics tools that record your technical interactions with the Platform (see Section 9);
• Payment processors — transaction data is shared with cucicuci by payment service providers such as FPX, Touch n Go eWallet, Boost, and cryptocurrency processing services when you initiate a financial transaction;
• Identity verification services — cucicuci may use third-party KYC and identity verification services, which may collect and return verification outcomes to cucicuci;
• Fraud prevention providers — technical and behavioural data may be processed by anti-fraud systems to detect suspicious account activity.

4. Purposes of Personal Data Processing

cucicuci processes your personal data for the following purposes:

• Creating and maintaining your cucicuci account;
• Verifying your identity and age to comply with the 21+ age requirement and regulatory obligations;
• Processing deposits and withdrawals via your chosen Malaysian payment method;
• Detecting and preventing fraud, money laundering, and other illegal activity;
• Providing customer support and resolving disputes;
• Administering bonuses, promotions, and loyalty programmes;
• Monitoring gaming activity for responsible gambling purposes, including enforcing deposit limits and self-exclusion;
• Complying with licensing conditions, anti-money laundering (AML) obligations, and applicable law;
• Improving the Platform and personalising your experience;
• Sending account notifications, security alerts, and (where consent is given) promotional communications.

5. Legal Basis for Processing

cucicuci processes your personal data on the following legal grounds:

• Contract performance — processing necessary to provide the gaming services you have contracted for, including account management, payment processing, and customer support;
• Legal obligation — processing required to comply with AML laws, licensing conditions, KYC requirements, and other applicable regulatory obligations;
• Legitimate interests — processing for fraud prevention, platform security, responsible gaming monitoring, and improvement of cucicuci services, where these interests are not overridden by your privacy rights;
• Consent — processing for direct marketing and non-essential cookies, where you have provided specific, informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Third-Party Disclosure

6.1 Service Providers

cucicuci shares personal data with third-party service providers who assist in operating the Platform, including payment processors (FPX, Touch n Go, Boost, cryptocurrency processors), KYC verification services, IT infrastructure providers, customer support software providers, and fraud detection systems. All such providers are contractually bound to process data only as directed by cucicuci and to maintain appropriate security standards.

6.2 Gaming Software Providers

Certain personal data (such as username, account ID, and game session data) is shared with licensed gaming software providers (including slot, live casino, and sports betting platform providers) to the extent necessary to deliver the relevant gaming services.

6.3 Regulatory & Law Enforcement

cucicuci may disclose personal data to regulatory authorities, licensing bodies, and law enforcement agencies where required by applicable law, court order, or our licensing conditions. This includes mandatory reporting under AML regulations.

6.4 No Sale of Data

cucicuci does not sell, rent, or trade your personal data to third parties for their own marketing purposes. Any data sharing is strictly limited to the purposes described in this Policy.

7. Data Retention

cucicuci retains personal data for the following periods:

• Active account data — retained for the duration of your account's active status plus a minimum of five (5) years following account closure, in compliance with AML and licensing retention requirements;
• KYC documents — retained for a minimum of five (5) years from the date of submission or account closure, whichever is later;
• Transaction records — retained for a minimum of seven (7) years to satisfy financial record-keeping obligations;
• Customer support communications — retained for three (3) years from the date of the communication;
• Marketing consent records — retained until consent is withdrawn or for two (2) years following the last marketing interaction, whichever is earlier.

Data is securely deleted or anonymised upon expiry of applicable retention periods. Where data must be retained beyond the primary use period solely for legal compliance, it will be stored in a restricted-access archive and will not be used for any other purpose.

8. Data Security

cucicuci implements technical and organisational security measures appropriate to the nature and sensitivity of the personal data we process. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and cucicuci servers;
• Encryption of sensitive data at rest, including KYC documents and payment method references;
• Access controls limiting employee access to personal data on a strict need-to-know basis;
• Multi-factor authentication requirements for staff accessing systems containing personal data;
• Regular security assessments and penetration testing by independent third parties;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

No electronic transmission over the internet is completely secure. While cucicuci takes all commercially reasonable steps to protect your data, we cannot guarantee absolute security. In the event of a data breach affecting your rights, cucicuci will notify you as required by applicable law.

9. Cookies & Tracking Technologies

cucicuci uses cookies and similar tracking technologies on the Platform for the following purposes:

• Strictly necessary cookies — essential for the Platform to function, including maintaining your login session, remembering language and display preferences, and security tokens. These cannot be disabled without affecting core Platform functionality.
• Analytical cookies — used to understand how Members use the Platform, which pages are visited most frequently, and where technical errors occur, enabling cucicuci to improve Platform performance. These are activated only with your consent.
• Functional cookies — used to personalise your experience, such as remembering your preferred game categories or last-visited sections. Activated with your consent.

You can manage your cookie preferences through your browser settings. Disabling non-essential cookies will not affect your ability to access your cucicuci account or place bets, but may affect personalisation features.

10. Your Data Rights

Subject to applicable law and certain exceptions related to our regulatory obligations, you have the following rights in relation to your personal data held by cucicuci:

• Right of Access — You may request a copy of the personal data cucicuci holds about you, along with information about how it is being used.
• Right to Rectification — You may request correction of any inaccurate or incomplete personal data. For account details, you can update basic information directly through account settings.
• Right to 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 retention obligations under our licensing and AML requirements.
• Right to Restrict Processing — You may request that cucicuci restricts processing of your data in certain circumstances, such as where you contest its accuracy.
• Right to Data Portability — Where processing is based on your consent or contract performance, you may request your data in a structured, machine-readable format.
• Right to Object — You may object to processing based on legitimate interests, including direct marketing. All marketing communications include an unsubscribe option.
• Right to Withdraw Consent — Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact cucicuci at [email protected] with the subject line "Data Rights Request". We will respond within thirty (30) days. We may need to verify your identity before processing the request.

11. Minors & Age Policy

cucicuci does not knowingly collect personal data from persons under the age of 21. The Platform is strictly for adult players aged 21 and above. All registration processes include an age declaration, and cucicuci conducts age verification as part of the KYC process before processing withdrawals.

If cucicuci discovers or has reason to believe that a registered account belongs to a person under 21, the account will be closed immediately, all pending withdrawals will be suspended pending investigation, and any personal data collected in connection with the underage account will be deleted in accordance with our data retention schedule, except where retention is required by law.

If you are a parent or guardian and believe your child has accessed the cucicuci Platform without authorisation, please contact our support team immediately at [email protected].

12. International Data Transfers

cucicuci operates under international gaming authority licensing and may process or store personal data in jurisdictions outside Malaysia. Where personal data is transferred internationally, cucicuci implements appropriate safeguards to ensure that the data receives a level of protection consistent with applicable privacy standards, including through contractual arrangements with data processors and sub-processors.

Specifically, personal data shared with KYC verification services, gaming software providers, and cloud infrastructure providers may be processed outside Malaysia. cucicuci takes reasonable steps to ensure that all such international transfers are subject to appropriate data processing agreements.

13. Amendments to This Policy

cucicuci reserves the right to update this Privacy Policy at any time. Material changes will be notified to active Members via email or a prominent notice on the Platform before the changes take effect. The "Last updated" date at the top of this page indicates the date of the most recent revision.

Your continued use of the Platform following notification of a material change constitutes your acknowledgement of the updated Policy. If you do not agree with the updated Policy, you should close your account before the changes take effect.

14. Contact & Data Protection Enquiries

For any privacy-related questions, data rights requests, or concerns about how cucicuci handles your personal data, please contact us through the following channels:

cucicuci will not respond to privacy enquiries submitted through channels other than those listed above. Please do not send sensitive account information such as passwords or full payment details over email.