Privacy Policy 365 Cuci – Malaysia Member Data Protection

365 Cuci is a digital entertainment platform operating in Malaysia, offering online gaming services that include Live Casino (baccarat, blackjack, roulette), video slots, Sports Betting (Malaysia Super League, EPL, badminton, cricket, e-sports), and a variety of other games for registered members aged 18 and above.

This Privacy Policy applies to all personal data processing carried out by 365 Cuci through:

• The official website at 365cuci.biz and all its subdomains
• Any mobile applications or software associated with 365 Cuci
• Interactions with our customer support team via Live Chat, email, or other channels
• All financial transactions including deposits via Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, Maybank2u, CIMB Clicks, and FPX

365 Cuci collects various types of personal data depending on how you interact with our platform. Below is a detailed table of the data we collect:

We may also collect data you voluntarily provide through customer satisfaction surveys, friend referral programmes, or participation in any 365 Cuci promotional activities.

Personal data collected by 365 Cuci is used solely for the following purposes:

• Account Management: Creating, verifying, and maintaining your member account on the 365 Cuci platform.
• Transaction Processing: Securely processing deposits and withdrawals via your preferred Malaysian payment methods.
• Identity Verification (KYC): Fulfil the legal obligation to verify member identities and prevent fraud and money laundering.
• Service Provision: Grants you access to all games and features on the 365 Cuci platform.
• Customer Support: Responding to enquiries, resolving complaints, and providing technical assistance.
• Platform Security: Detecting and preventing fraud, unauthorised access, and suspicious activity.
• Product Improvement: Analysing usage patterns to improve the player experience and develop new features.
• Marketing Communications: Sending promotional information, bonuses, and special offers from 365 Cuci – only to members who have given their consent.
• Legal Compliance: Fulfil all legal and regulatory obligations applicable in Malaysia.

365 Cuci processes your personal data based on one or more of the following legal grounds as provided under Malaysia's Personal Data Protection Act 2010 (PDPA):

• Consent: You have given explicit consent at the time of account registration and for specific marketing purposes.
• Contractual Necessity: Processing is necessary to fulfil the service agreement between you and 365 Cuci — including the processing of deposits, withdrawals, and account management.
• Legal Obligation: Certain processing is required to comply with applicable Malaysian laws, including anti-money laundering (AML) requirements and identity verification (KYC).
• Legitimate Interests: Processing for platform security, fraud prevention, and service improvement purposes is based on 365 Cuci's legitimate interests, which do not override your rights and freedoms.

365 Cuci does not sell your personal data. We only share data in the following limited circumstances:

• Third-Party Service Providers: We work with payment service providers (such as FPX, TNG, and GrabPay gateways), gaming software providers (such as Pragmatic Play and Evolution Gaming), and cloud service providers that support the operation of our platform. All such third parties are bound by strict data protection agreements and may only use your data for the purposes specified.
• Malaysian Authorities: We will disclose data to Malaysian authorities (PDRM, Bank Negara Malaysia, LHDN) when required by court order or applicable legislation.
• Fraud Prevention: In cases of suspected fraud, we may share the necessary information with relevant financial institutions or authorities.
• Business Transfers: In the event that 365 Cuci is involved in any merger, acquisition, or asset sale, your personal data may be transferred as part of that transaction. You will be notified before any such transfer takes place.

365 Cuci retains your personal data only for as long as necessary to fulfil the purposes described in this Policy, or as required by Malaysian law:

• Active Account Data: Retained for the duration your account is active and up to 7 years after account closure for legal compliance purposes.
• Financial Transaction Records: Retained for a minimum of 7 years in accordance with Malaysia's Anti-Money Laundering Act (AMLA) requirements.
• Security Logs: Retained for 2 years for security investigation and fraud prevention purposes.
• Customer Support Data: Retained for 3 years from the date of last interaction.
• Marketing Data: Retained until you withdraw consent or request deletion.

After the specified retention period, your data will be securely deleted or anonymised so that it can no longer be linked to you.

365 Cuci implements comprehensive technical and organisational security measures to protect your personal data against unauthorised access, misuse, loss, or destruction:

• Encryption in Transit: All data in transit is protected with 256-bit SSL/TLS encryption.
• Storage Encryption: Sensitive data is stored in encrypted form within protected databases.
• Access Control: Access to personal data is granted only to staff who require it to carry out their designated responsibilities, in accordance with the principle of least privilege.
• Two-Factor Authentication: 365 Cuci's internal systems containing personal data are secured with multi-factor authentication.
• Regular Security Audits: Our systems are regularly audited by independent cybersecurity firms to identify and address any vulnerabilities.
• Staff Training: All 365 Cuci staff undergo regular data security awareness training.

As a data subject under Malaysia's Personal Data Protection Act 2010, you have the following rights, which you may exercise at any time:

To exercise any of the above rights, please contact our Privacy Officer at privacy@365cuci.biz. We will respond within 14 working days. Certain rights may be subject to limitations based on our legal obligations.

365 Cuci uses 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.

You can manage your cookie settings through your web browser settings or via the cookie management banner that appears on your first visit to the 365 Cuci platform.

The 365 Cuci platform is exclusively for individuals aged 18 years and above. We do not knowingly collect personal data from children or individuals under the age of 18.

Should we discover that we have collected personal data from an individual under the age of 18, we will take immediate steps to delete that data and close the associated account. If you become aware that a minor has registered on our platform, please notify us promptly via privacy@365cuci.biz.

365 Cuci reserves the right to update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the protections we offer. We are committed to keeping you informed of any material changes:

• A written notice will be sent to your registered email address at least 14 days before the changes take effect.
• A notification banner will be displayed on the 365 Cuci platform's homepage.
• The "Last Updated" date at the top of this document will be revised accordingly.

Your continued use of the 365 Cuci platform after the effective date of any changes constitutes your acceptance of the amended Privacy Policy.

If you have any questions, concerns, or complaints regarding this Privacy Policy or how 365 Cuci handles your personal data, please contact our Privacy Officer through the following channels:

You also have the right to lodge a complaint with the Personal Data Protection Commissioner of Malaysia if you believe that the processing of your personal data has violated the provisions of PDPA 2010.