Privacy Policy — 100cui

1. Who We Are

100cui ("we", "us", "our", "the Company") operates the online gaming and sports betting platform accessible at 100cui.app ("the Platform"). The Company is the data controller in respect of all personal data processed in connection with the Platform and the services it provides.

For all privacy-related enquiries, including data subject rights requests, please contact us at [email protected] with the subject line "Privacy Enquiry".

2. Personal Data We Collect

The categories of personal data 100cui may collect, depending on how you interact with the Platform, are set out in the table below.

We do not intentionally collect special category personal data (such as data revealing racial or ethnic origin, health data, or biometric data) unless strictly required for identity verification purposes and only with your explicit consent.

3. How We Collect Your Data

3.1 Data You Provide Directly

You provide data directly when you: register an account on the Platform; complete KYC verification by submitting identity documents; make a deposit or request a withdrawal; contact our support team via live chat or email; participate in promotional campaigns or surveys; or update your account profile or preferences.

3.2 Data Collected Automatically

When you access the Platform, our servers and analytics infrastructure automatically record Technical Data and Usage Data, including your IP address, browser fingerprint, device identifiers, pages visited, time spent on each page, and in-game activity. This data is collected through server logs, session tokens, and first-party analytics tools operated by 100cui.

3.3 Data from Third Parties

We may receive data about you from third parties, including: payment processors and eWallet providers (Touch n Go, Boost, Maybank, CIMB, Public Bank) in connection with payment processing; fraud detection and identity verification service providers; and regulatory bodies where disclosure is required by law.

4. How We Use Your Personal Data

100cui processes personal data for the following purposes:

• Account Management: Creating, maintaining, and administering your 100cui account, including authentication and session management;
• Transaction Processing: Processing deposits, withdrawals, and bonus credits in Malaysian Ringgit (MYR) via your chosen payment method;
• Identity Verification (KYC): Verifying your identity and age to comply with anti-money laundering (AML) obligations and our 21+ age policy;
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent transactions, account takeover attempts, and abuse of promotional offers;
• Responsible Gaming: Monitoring gameplay patterns to identify potential problem gambling indicators and enforcing deposit limits, self-exclusion requests, and account restrictions where applicable;
• Customer Support: Responding to your enquiries, resolving complaints, and maintaining support interaction records;
• Legal & Regulatory Compliance: Meeting obligations under applicable gaming regulations, AML legislation, tax reporting requirements, and other applicable law;
• Platform Improvement: Analysing aggregated usage data to improve game offerings, Platform performance, and user experience;
• Communications: Sending transactional communications (account notifications, withdrawal confirmations, security alerts) and, where you have consented, promotional communications about 100cui offers.

100cui does not use personal data for automated profiling that produces legal or similarly significant effects without human review.

5. Legal Basis for Processing

For each processing purpose described in Section 4, 100cui relies on one of the following legal bases:

• Contractual Necessity: Processing required to perform our contract with you (i.e., providing the Platform and associated services) — covers account management, transaction processing, and customer support;
• Legal Obligation: Processing required to comply with applicable law — covers KYC/AML obligations, age verification, and regulatory reporting;
• Legitimate Interests: Processing necessary for our legitimate business interests, where those interests are not overridden by your privacy rights — covers fraud prevention, security monitoring, responsible gaming oversight, and Platform analytics;
• Consent: Processing based on your freely given, specific, and informed consent — covers promotional communications and any optional data processing clearly identified as consent-based at the point of collection. You may withdraw consent at any time without affecting prior processing.

6. Data Sharing & Disclosure

100cui does not sell your personal data to third parties. We do not share your data with advertising networks or data brokers. Personal data may be shared only in the following circumstances:

6.1 Service Providers

We engage third-party service providers who process data on our behalf under written data processing agreements, including: payment processors and eWallet operators; identity verification and KYC providers; fraud detection and cybersecurity vendors; cloud infrastructure providers; and customer support platform providers. These parties process your data only for the specific purposes for which they are engaged and under binding confidentiality obligations.

6.2 Legal & Regulatory Disclosure

We will disclose personal data where required to do so by applicable law, court order, or regulatory directive, including to gaming regulatory authorities, financial intelligence units, and law enforcement agencies. Where legally permitted, we will notify you of such disclosure.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of the Company's assets, personal data held by 100cui may be transferred to the successor entity, subject to the successor's agreement to honour the terms of this Privacy Policy.

7. International Data Transfers

Some of the third-party service providers engaged by 100cui may process personal data in jurisdictions outside Malaysia. Where such transfers occur, 100cui ensures that appropriate safeguards are in place in accordance with applicable data protection law, including standard contractual clauses or equivalent mechanisms approved by the relevant regulatory authority. By using the Platform, you acknowledge that your data may be transferred and processed internationally for the purposes described in this Policy.

8. Data Retention

100cui retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following:

• Active Accounts: Personal data is retained for the duration of your account relationship with 100cui;
• Closed Accounts: Following account closure, personal data (including transaction records and identity verification documents) is retained for a minimum of five (5) years to comply with AML and gaming regulatory record-keeping obligations;
• Support Records: Customer support interaction records are retained for three (3) years;
• Technical / Analytics Data: Anonymised or aggregated analytics data may be retained indefinitely for Platform improvement purposes, as it no longer constitutes personal data once anonymisation is applied.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data destruction procedures.

9. Your Data Rights

Subject to applicable law, you have the following rights in respect of personal data that 100cui holds about you:

• Right of Access: You may request a copy of the personal data 100cui 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, subject to our legal retention obligations;
• Right to Restrict Processing: You may request that we limit processing of your data in certain circumstances;
• Right to Data Portability: Where processing is based on consent or contract and carried out by automated means, you may request transfer of your data in a machine-readable format;
• Right to Object: You may object to processing based on legitimate interests, including direct marketing;
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time.

To exercise any of the above rights, please submit a written request to [email protected] with the subject line "Data Rights Request". We will respond within 30 days. We may require identity verification before processing rights requests.

10. Cookies & Tracking Technologies

The 100cui Platform uses first-party cookies and similar session technologies to operate core Platform functions, including authentication session management, fraud detection tokens, and user preference storage. We do not use third-party advertising cookies or cross-site tracking technologies.

The types of cookies used by 100cui include:

• Strictly Necessary Cookies: Required for login session persistence, security tokens, and core Platform functionality. These cannot be disabled without breaking Platform functionality;
• Functional Cookies: Used to store your language, display, and game preferences between sessions;
• Analytics Cookies: First-party analytics used to understand aggregate Platform usage patterns. No personally identifiable information is shared with third-party analytics vendors.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to log in and use the Platform.

11. Children's Privacy

The 100cui Platform is strictly for individuals aged 21 years and above. We do not knowingly collect personal data from individuals under 21. If we become aware that a minor has registered an account or provided personal data, we will immediately suspend the account, delete the personal data, and void any associated transactions. If you believe a minor has registered on the Platform, please contact us at [email protected] immediately.

12. Data Security

100cui implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, or alteration. Measures in place include:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers;
• AES-256 encryption for sensitive data at rest, including identity verification documents and financial data;
• Bcrypt hashing for all account passwords — passwords are never stored in recoverable form;
• Role-based access controls limiting internal access to personal data on a need-to-know basis;
• Real-time intrusion detection and anomaly monitoring on all Platform infrastructure;
• Regular third-party security audits and penetration testing.

Despite these measures, no internet-based platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying 100cui immediately if you suspect a security breach affecting your account.

13. Changes to This Privacy Policy

100cui reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, Platform functionality, or applicable law. Material changes will be communicated to registered players via email to their registered address and/or via an on-Platform notification at least 14 days before the changes take effect. The updated Policy will be posted at 100cui.app/privacy-policy with a revised "Last Updated" date. Continued use of the Platform following the effective date of a revised Policy constitutes your acceptance of the updated terms.

14. Contact Us

For all privacy-related enquiries, data subject rights requests, or complaints regarding 100cui's data practices, please contact us using the following details:

• Email: [email protected] (subject line: "Privacy Enquiry")
• Live Chat: Available 24/7 from your 100cui Account dashboard

We will acknowledge all written privacy enquiries within 2 business days and provide a substantive response within 30 days. If you are not satisfied with our response, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.