Privacy Policy 365cuci vip – How We Protect Your Information

1. Introduction and Purpose of This Policy

365cuci vip ("we", "Platform" or "365cuci vip") takes your privacy seriously. This Privacy Policy explains how we collect, use, store, disclose and protect your personal information when you use our website at 365cucivip.org and our official mobile app.

This document is drafted in accordance with Malaysia's Personal Data Protection Act 2010 (PDPA) and international best practices for data protection. We review and update this Privacy Policy periodically to ensure it accurately reflects our current practices and relevant legal developments.

2. Information We Collect

We collect various types of information depending on how you interact with our platform. Generally, the information collected falls into two main categories:

2.1 Information You Provide Directly

• Registration Information: Full name, date of birth, email address, phone number and password upon account registration
• Identity Verification (KYC): Copy of identity card (MyKad), passport, proof of address, and any other additional information required for compliance
• Financial Information: Bank account details, e-wallet account numbers (TNG, Boost, GrabPay, ShopeePay) used for deposits and withdrawals
• Communications: Any messages, complaints, or feedback you submit to our support team
• Marketing Preferences: Communication preferences and promotional offers you have set in your account profile

2.2 Information Collected Automatically

• Device Data: Device type, operating system, phone model, unique device identifier and app version
• Network Data: IP address, internet service provider (ISP), general geographic location based on IP
• Usage Data: Pages visited, time spent, games played, login frequency and navigation patterns
• Transaction Data: Complete records of all deposits, withdrawals, wagering, and wins on the platform
• Cookies and Similar Technologies: Data collected via cookies, tracking pixels and your web browser's local storage

3. How We Use Your Information

Every piece of information we collect has a clear and lawful purpose. The following are the primary ways we use your personal data:

4. Data Sharing and Disclosure

365cuci vip does not sell or rent your personal data to any third party. However, there are limited situations where we may need to share your information with certain parties:

4.1 Trusted Service Providers

We share data with service providers who assist us in operating the platform, such as payment processors, cloud service providers and identity verification companies. All such providers are bound by strict data protection agreements and are only permitted to use your data for specified purposes.

4.2 Legal Requirements

We may disclose your information to government authorities or law enforcement if required by applicable law, court order, or to protect the rights and safety of our platform's users.

4.3 Business Transfers

In the event of a merger, acquisition, or asset sale, your personal data may be transferred as part of that transaction. You will be notified in advance and given the option to opt out before your data becomes subject to a different privacy policy.

5. Cookie Policy and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device when you visit our website.

The types of cookies we use are as follows:

• Necessary Cookies: Required for core platform functions such as login verification and session security. These cookies cannot be disabled.
• Analytics Cookies: Helping us understand how users interact with the platform for continuous improvement purposes.
• Functional Cookies: Saving your preferences such as language, display settings and game preferences for ease of use.
• Marketing Cookies: Used to display relevant offers and promotions. You may opt out of these cookies via your account settings.

You can control and manage cookies through your web browser settings. Please note that disabling certain cookies may affect platform functionality.

6. Data Security and Protection Measures

Protecting your data from unauthorised access, loss or misuse is our top technical and operational priority. Among the security measures we implement:

• End-to-End Encryption: All data communications are protected by TLS 1.3 protocol and AES-256 encryption
• Multi-Layer Firewall: Our infrastructure is protected by advanced firewall systems and intrusion detection mechanisms
• Strict Access Controls: Access to member data is restricted to authorised staff with mandatory two-factor authentication (2FA)
• 24-Hour Monitoring: Our security team monitors network activity around the clock to detect unusual threats
• Secure Backups: Data is backed up regularly and stored in a secure, separate location
• Regular Security Testing: We conduct regular penetration testing and vulnerability assessments by independent auditors

7. Data Retention Period

We retain your personal data only for as long as necessary for the stated purposes or as required by applicable law. General guidelines for retention periods are as follows:

• Active Account Data: For as long as your account is active and for a period of six years after account closure for audit purposes
• Financial Transaction Records: A minimum of seven years in line with Malaysia's financial legal requirements
• KYC Documents: A minimum of five years after the business relationship ends
• Support Communication Logs: Two years from the date of last interaction
• Anonymous Analytics Data: May be retained indefinitely as it cannot be re-identified to any individual

Once the retention period expires, your data will be securely deleted using methods that ensure it cannot be recovered.

8. Your Rights as a User

Under Malaysia's PDPA and the data protection principles we practise, you have the following rights regarding your personal data:

To exercise any of the above rights, please contact our data protection team by email at [email protected]. We will process your request within 30 business days from the date of receipt.

9. Children's Privacy

The 365cuci vip platform is strictly for adult users aged 18 and above. We do not knowingly collect or process personal data of individuals under the age of 18. Should we discover that we have inadvertently collected information from someone under 18, the account will be closed immediately and all related data will be deleted.

If you are a parent or guardian and believe that your underage child has registered on our platform, please contact us immediately so that we can take the appropriate action.

10. Amendments to This Privacy Policy

365cuci vip reserves the right to amend this Privacy Policy from time to time to reflect changes in our practices, legal requirements or platform improvements. When significant amendments are made, we will:

• Updating the "Last Updated" date at the top of this document
• Sending you notifications via your registered email or in-app notifications
• Displaying a clear notice on the platform's home page for at least 30 days

Your continued use of our platform after the effective date of any amendment constitutes acceptance of the updated Privacy Policy. We encourage you to review this page periodically.

11. Contact Our Data Protection Officer

If you have any questions, concerns or complaints regarding your privacy and personal data management, please contact us through the following channels:

• Privacy Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 via the chat button on the platform
• Response Time: We are committed to responding to all privacy-related enquiries within 3 business days