123cuci Privacy Policy

1. Introduction & Scope

This Privacy Policy describes how 123cuci ("we", "us", "our") collects, uses, stores, and protects personal data in connection with the operation of the 123cuci Platform at 123cuci.net. It applies to all individuals who access or use the Platform, including registered Players, visitors, and persons who contact 123cuci support.

123cuci is committed to handling personal data responsibly and in compliance with applicable data protection laws and the data protection requirements imposed by the international gaming authority under whose framework 123cuci operates. This Policy should be read alongside the 123cuci Terms & Conditions.

By registering an Account on the 123cuci Platform or by using the Platform as a visitor, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

2. Data Controller

For the purposes of applicable data protection legislation, the data controller in respect of personal data processed through the 123cuci Platform is the licensed operator of 123cuci.net. As the data controller, 123cuci determines the purposes and means of processing personal data collected through the Platform.

If you have any questions about data controllership or wish to direct a data subject request to the appropriate entity, please contact the 123cuci support team using the contact details provided in Section 15 of this Policy.

3. Personal Data We Collect

3.1 Registration Data

When you create a 123cuci Account, we collect the personal data you provide during the registration process, including:

• Full legal name;
• Date of birth (for age verification — you must be 21 or older to register);
• Residential address (including state and postcode);
• Email address;
• Mobile phone number.

3.2 Identity Verification (KYC) Data

As part of our Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations, we may collect copies of government-issued identification documents such as your Malaysian National Identity Card (MyKad), passport, or other official photo ID, as well as proof of address documentation.

3.3 Financial & Transaction Data

We collect information about your deposits and withdrawals on the Platform, including transaction amounts, timestamps, payment method identifiers (such as your registered Touch n Go eWallet account reference or FPX bank reference), and transaction status records. We do not store full card numbers or bank account numbers on the 123cuci Platform; payment processing is handled by regulated payment service providers.

3.4 Gaming Activity Data

We collect records of your gaming activity on the Platform, including game sessions played, wagers placed, outcomes, bonus usage, and session duration. This data is used for regulatory compliance, responsible gaming monitoring, and Platform improvement purposes.

3.5 Technical & Usage Data

When you access the Platform, we automatically collect certain technical data, including your IP address, device type, operating system, browser type and version, referring URL, pages visited, and session timestamps. This data is used for security monitoring, fraud detection, and Platform performance analysis.

3.6 Communications Data

We retain records of communications between you and the 123cuci support team, including Live Chat transcripts and email correspondence, for quality assurance, dispute resolution, and regulatory compliance purposes.

4. How We Collect Your Data

123cuci collects personal data through the following means:

• Directly from you — when you register an Account, complete KYC verification, make a deposit or withdrawal, contact support, or update your account profile;
• Automatically — through server logs, cookies, and similar tracking technologies when you access and navigate the Platform (see Section 9 for details);
• From third-party service providers — such as KYC/AML verification services that may supplement or verify the information you provide during registration or withdrawal processing;
• From payment processors — transaction confirmation and status data received from payment service providers such as Touch n Go eWallet, Boost, and FPX bank partners.

5. Purposes & Legal Bases for Processing

123cuci processes your personal data for the following purposes, each supported by a corresponding legal basis:

• Account registration and management — necessary for the performance of the contract between you and 123cuci as constituted by the Terms & Conditions;
• Payment processing and financial reconciliation — necessary for contractual performance and compliance with financial regulatory obligations;
• Identity verification and age verification — necessary for compliance with international gaming authority licensing requirements, including the strict 21+ age restriction applicable to all 123cuci accounts;
• Fraud detection, security, and AML monitoring — necessary for compliance with applicable legal obligations and in our legitimate interests as a licensed operator;
• Responsible gaming monitoring and intervention — necessary for compliance with our obligations under international gaming authority responsible gaming standards, and in the vital interests of players who may be at risk;
• Customer support and dispute resolution — necessary for contractual performance and in our legitimate interests in maintaining service quality;
• Platform improvement and analytics — in our legitimate interests in maintaining and improving the quality and security of the 123cuci Platform;
• Marketing communications — where you have provided explicit consent to receive promotional communications from 123cuci. You may withdraw this consent at any time by contacting support.

6. Sharing of Personal Data

123cuci does not sell, rent, or trade your personal data to any third party. We share personal data only in the following limited circumstances:

• Payment processors: We share necessary transaction data with regulated payment service providers (including Touch n Go eWallet, Boost, FPX participating banks, and cryptocurrency processing partners) to facilitate deposits and withdrawals. These providers process data strictly as required to complete your transactions.
• KYC and AML service providers: We engage regulated identity verification and anti-money laundering service providers to assist with our compliance obligations. These providers process data under contractual data protection obligations.
• Game providers: Your gaming activity data may be shared with our licensed game providers for the purpose of operating game sessions and resolving technical disputes. Game providers are contractually prohibited from using this data for any other purpose.
• Regulatory and law enforcement authorities: We will disclose personal data to regulators, gaming authorities, law enforcement agencies, or courts where we are legally required to do so or where disclosure is necessary to comply with our licensing obligations.
• Group companies and successors: In the event of a corporate restructuring, merger, acquisition, or sale of assets, personal data held by 123cuci may be transferred to a successor entity, subject to equivalent data protection standards.

All third parties with whom 123cuci shares personal data are required to process that data only for the specified purpose and in accordance with applicable data protection requirements.

7. International Data Transfers

Given the international nature of the online gaming industry, personal data processed by 123cuci may be transferred to and processed in countries outside Malaysia. Where such transfers occur, 123cuci takes appropriate measures to ensure that the receiving party provides adequate data protection, including through contractual safeguards and, where applicable, reliance on recognised transfer mechanisms.

If you have questions about the safeguards applicable to any specific international transfer of your data, you may contact 123cuci support for further information.

8. Data Retention

123cuci retains personal data for as long as is necessary to fulfil the purposes for which it was collected, having regard to the following considerations:

• Active accounts: Personal data associated with an active 123cuci Account is retained for the duration of the account relationship and for a period of at least five (5) years following account closure, in order to comply with AML, KYC, and gaming regulatory record-keeping requirements.
• Transaction records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction in accordance with applicable financial regulatory requirements.
• Support communications: Customer support records are retained for three (3) years from the date of the last communication, or longer if required for ongoing dispute or regulatory purposes.
• Technical and usage data: Aggregated and anonymised technical data may be retained indefinitely for Platform analytics and security purposes. Non-anonymised log data is typically retained for twelve (12) months.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 123cuci's data disposal procedures.

9. Cookies & Tracking Technologies

9.1 Types of Cookies Used

123cuci uses the following categories of cookies on the Platform:

• Strictly necessary cookies: Required for the Platform to function. These include session management cookies that keep you logged in to your 123cuci Account during your visit and security cookies that protect against cross-site request forgery (CSRF).
• Performance and analytics cookies: Used to collect anonymised information about how visitors use the Platform, including which pages are visited most frequently and how visitors navigate between sections. This data is used in aggregate form to improve Platform performance.
• Functional cookies: Used to remember your preferences on the Platform, such as language settings and display preferences.

9.2 No Third-Party Advertising Cookies

123cuci does not deploy third-party advertising cookies, retargeting pixels, or cross-site tracking technologies on the Platform. Your browsing behaviour on 123cuci is not shared with advertising networks.

9.3 Cookie Management

Strictly necessary cookies cannot be disabled as they are essential to Platform functionality. You may manage performance and functional cookies through your browser's cookie settings. Please note that disabling certain cookies may affect the functionality of your 123cuci Account experience.

10. Security Measures

123cuci implements appropriate technical and organisational security measures to protect personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data in transit between the user's browser and the 123cuci Platform;
• Encryption at rest for sensitive personal data stored in 123cuci systems;
• Access controls limiting internal access to personal data on a strict need-to-know basis;
• Regular security assessments and penetration testing of the Platform infrastructure;
• Two-factor authentication (2FA) available to all Players for account access;
• Rate-limited login attempts and automated fraud detection to prevent unauthorised account access.

While 123cuci takes all reasonable steps to protect your data, no internet transmission or electronic storage system is entirely secure. You are responsible for maintaining the security of your own 123cuci Account login credentials.

11. Your Rights as a Data Subject

Subject to applicable data protection laws and any overriding legal obligations (such as regulatory retention requirements), you have the following rights in respect of your personal data held by 123cuci:

• Right of access: You may request a copy of the personal data 123cuci holds about you.
• Right to rectification: You may request correction of inaccurate or incomplete personal data.
• 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 our legal retention obligations.
• Right to restrict processing: You may request that we restrict the processing of your data in certain circumstances.
• Right to data portability: Where processing is based on your consent or on contractual necessity, you may request a copy of your data in a machine-readable format.
• Right to withdraw consent: Where processing is based on your consent (such as marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to object: You may object to processing carried out on the basis of our legitimate interests, subject to our demonstrating compelling grounds that override your interests.

To exercise any of the above rights, please contact 123cuci support via the channels set out in Section 15. We aim to respond to all data subject requests within thirty (30) days of receipt. Complex requests may require additional time, in which case we will notify you of the extended timeframe.

12. Children's Privacy

The 123cuci Platform is strictly intended for adults aged 21 years and above. 123cuci does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from an individual who does not meet the minimum age requirement, we will take prompt steps to delete that data and close the associated Account.

If you are a parent or guardian and believe that a minor has registered on the 123cuci Platform, please contact support immediately using the details in Section 15.

13. Links to Other Pages & Services

The 123cuci Platform contains links to other internal pages of the site (such as our Responsible Gaming and About Us pages). This Privacy Policy applies to all pages of the 123cuci Platform at 123cuci.net.

The 123cuci Platform does not contain links to external third-party websites except where required for payment processing. 123cuci is not responsible for the privacy practices of payment service provider platforms that you may access during the deposit or withdrawal process. We encourage you to review the privacy policies of any third-party services you use in connection with your 123cuci transactions.

14. Changes to This Policy

123cuci may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable laws, or Platform features. Material updates will be communicated to registered Players via a notification on the Platform or by email to your registered address. The "Last updated" date at the top of this Policy reflects the date of the most recent revision.

Continued use of the 123cuci Platform following notification of changes constitutes your acceptance of the updated Privacy Policy. If you do not agree to any updated provisions, you must cease using the Platform and may request Account closure as described in the Terms & Conditions.

15. Contact & Data Enquiries

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 123cuci, please contact the support team through the following channels:

• Live Chat: Available 24/7 within the Platform after login — the fastest channel for all enquiries including data subject requests.
• Email: [email protected]
• WhatsApp: Displayed within the Platform after login.

123cuci aims to acknowledge all data-related enquiries within two (2) business days and to resolve substantive requests within thirty (30) days. If you are not satisfied with our response to a data subject request, you may refer the matter to the relevant data protection authority or the gaming regulatory body under whose framework 123cuci operates.