Privacy Policy — How 100cucu Handles Your Personal Data

1.Data Controller

For the purposes of applicable data protection law, the data controller in respect of personal data collected through the 100cucu Platform (https://100cucu.org) is 100cucu ("100cucu", "we", "us", "our"). 100cucu is the operator of the Platform and determines the purposes and means of processing your personal data.

This Privacy Policy applies to all personal data collected from users ("you", "your") who register for an account, access the Platform, or otherwise interact with 100cucu's services. It should be read alongside the 100cucu Terms & Conditions, which incorporate this Privacy Policy by reference.

By registering a 100cucu account or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree, you must not use the 100cucu Platform.

2.Personal Data We Collect

100cucu collects personal data from you in the following categories, depending on how you interact with the Platform:

100cucu does not collect or process special categories of sensitive personal data (such as biometric data, health information or political opinions) unless required by a specific regulatory obligation.

3.How We Use Your Personal Data

100cucu uses your personal data for the following purposes:

• Account Administration: Creating, maintaining and managing your 100cucu player account, including verifying your identity, processing deposits and withdrawals, and providing access to all Platform features.
• Service Delivery: Enabling you to participate in casino games, sportsbook betting, crash games, lottery draws and all other 100cucu gaming products.
• Regulatory Compliance: Meeting our obligations under anti-money laundering (AML) legislation, Know Your Customer (KYC) requirements, and the conditions of our international gaming authority licence — including maintaining transaction records and reporting as required by law.
• Fraud Prevention & Security: Detecting, preventing and investigating fraudulent activity, account compromise, money laundering, bonus abuse and other activities that breach our Terms & Conditions or applicable law.
• Responsible Gaming: Monitoring gaming patterns to identify indicators of problem gambling and to apply responsible gaming interventions as required by our licensing conditions, including enforcing self-exclusion and deposit limit settings.
• Customer Support: Responding to your queries, complaints and requests via live chat and email.
• Platform Improvement: Analysing anonymised usage data to understand how players use the 100cucu Platform and to improve functionality, design and game content.
• Marketing (with consent): Sending promotional offers, bonus notifications and platform updates to users who have opted in to marketing communications.

4.Legal Basis for Processing

100cucu processes your personal data on the following legal bases:

• Contract Performance: Processing necessary to provide the services you have requested when creating a 100cucu account and entering into a player agreement with us.
• Legal Obligation: Processing required to comply with AML/KYC regulations, gaming authority licensing conditions and applicable Malaysian and international law.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring and anonymised analytics — where our legitimate interests are not overridden by your rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have given us explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

5.Data Sharing

100cucu does not sell, rent or trade your personal data to third parties for their own marketing purposes. We share personal data only in the following limited circumstances:

• Payment Processors: Financial data is shared with our approved payment partners (including Touch 'n Go eWallet, Boost, Maybank FPX, CIMB and other payment providers) to process deposits and withdrawals. These partners are contractually required to handle your data securely and only for the purpose of payment processing.
• Identity Verification Providers: KYC data including identity documents and address verification is shared with certified third-party identity verification services engaged by 100cucu for regulatory compliance.
• Gaming Authority & Regulatory Bodies: 100cucu may be required to disclose player data to our licensing authority, financial intelligence units or other regulatory and law enforcement bodies in response to lawful requests or as required under our licence conditions.
• Technology Service Providers: Data may be processed by our hosting, infrastructure, analytics and customer support technology providers, all of whom are bound by data processing agreements that restrict use to the purposes specified.
• Business Transfers: In the event of a merger, acquisition or transfer of all or part of 100cucu's business, player data may be transferred as part of that transaction. We will notify affected users in advance.

6.International Data Transfers

Due to the global nature of 100cucu's technology infrastructure and third-party service providers, your personal data may be transferred to and processed in countries outside Malaysia. Where such transfers occur, 100cucu ensures that appropriate safeguards are in place — including standard contractual clauses, data processing agreements, or transfers to jurisdictions recognised as providing an adequate level of data protection. You may contact us for further information about the specific safeguards applicable to a given transfer.

7.Data Retention

100cucu retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory and accounting obligations. Specific retention periods include:

• Account data and gaming records: retained for a minimum of 5 years from account closure, as required by AML/KYC regulations and gaming authority licence conditions.
• Financial transaction records: retained for a minimum of 7 years from the date of the transaction in accordance with applicable financial record-keeping requirements.
• Customer support records: retained for 3 years from the date of the last interaction.
• Marketing consent records: retained until consent is withdrawn and for a reasonable period thereafter as evidence of consent history.

Where retention is no longer required and no legal obligation prevents deletion, 100cucu will securely delete or anonymise your personal data.

8.Cookies & Tracking Technologies

The 100cucu Platform uses cookies and similar technologies to maintain session state, remember your preferences, and collect anonymised analytics data. The following cookie categories are used:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies and security tokens. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings and responsible gaming tool configurations between sessions.
• Analytics Cookies: Collect anonymised data about how users interact with the Platform to help us improve performance and user experience. No personally identifiable information is included in analytics data.

You can control non-essential cookies through your browser settings. Note that disabling certain cookies may affect Platform functionality. 100cucu does not use third-party advertising or tracking cookies.

9.Your Data Rights

Subject to applicable law and the retention obligations described in Section 7, you have the following rights in relation to your personal data held by 100cucu:

• Right of Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete personal data.
• Right to Erasure: Request deletion of your personal data where it is no longer necessary for the purpose it was collected and no legal retention obligation applies.
• Right to Restriction: Request that we restrict processing of your personal data in certain circumstances.
• Right to Data Portability: Request a copy of the personal data you have provided to us in a structured, machine-readable format.
• Right to Object: Object to processing of your personal data for direct marketing purposes or on the basis of legitimate interests.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact the 100cucu data team at [email protected]. We will respond to all verified requests within 30 days. We may need to verify your identity before processing a request.

10.Children's Privacy

The 100cucu Platform is strictly restricted to persons aged 21 years and above. 100cucu does not knowingly collect personal data from any person under the age of 21. If we become aware that personal data has been collected from a person under 21, we will promptly delete that data and close the associated account. If you believe that a person under 21 has registered on 100cucu, please notify us immediately at [email protected].

11.Security Measures

100cucu implements a multi-layered approach to data security commensurate with the sensitivity of the data processed and the requirements of our international gaming authority licence:

• All data in transit is protected by TLS 1.2 or higher encryption (SSL certificate visible in your browser).
• Sensitive data at rest — including identity documents and financial data — is encrypted using AES-256.
• Payment card and e-wallet details are tokenised; raw financial credentials are never stored on 100cucu servers.
• Access to production systems is restricted by role-based access controls and requires multi-factor authentication.
• Security systems are subject to regular penetration testing and vulnerability assessments.
• In the event of a data breach that affects your personal data, 100cucu will notify affected users and the relevant regulatory authority within the timeframes required by applicable law.

While 100cucu takes all reasonable measures to protect your personal data, no system is entirely immune to risk. You are also responsible for maintaining the security of your 100cucu account credentials.

12.Third-Party Links

The 100cucu Platform does not include links to third-party websites. To the extent that any third-party payment processor or verification service interface is accessed during your use of 100cucu, those services operate under their own privacy policies. 100cucu is not responsible for the data practices of third-party providers beyond the contractual protections in our data processing agreements with those providers.

13.Changes to This Privacy Policy

100cucu may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements or Platform features. Where a material change is made, 100cucu will notify registered users by email or in-Platform notification at least seven (7) days before the updated Policy takes effect. The "Last Updated" date at the top of this Policy will reflect the most recent revision. Your continued use of the 100cucu Platform following the effective date of any amendment constitutes acceptance of the updated Privacy Policy.

14.Contact & Data Enquiries

For any questions, concerns or requests relating to this Privacy Policy or to the personal data 100cucu holds about you, please contact us through the following channels:

• Email: [email protected]
• Live Chat: Available 24/7 via the in-Platform support widget

Please include "Privacy Request" in the subject line of email enquiries and provide sufficient detail to allow us to identify your account and process your request efficiently. We are committed to resolving all data-related enquiries promptly and transparently.