Privacy Policy — m1cuci

1Introduction

This Privacy Policy ("Policy") is issued by m1cuci ("we", "us", "our", or "the Platform") and applies to all personal data collected from users ("you", "User", "Member", or "Player") who access and use the online gaming and sports betting services available at https://m1cuci.cam (the "Website" or "Platform").

m1cuci is committed to protecting the privacy and personal data of all members, with particular care given to the data of Malaysian players. This Policy has been prepared in accordance with applicable personal data protection legislation and sets out in clear terms what personal data we collect from you, the purposes for which we process it, the legal bases on which we rely, and the rights available to you as a data subject.

This Policy should be read alongside our Terms & Conditions and our Responsible Gambling Policy. By registering an account on m1cuci, you confirm that you have read and understood this Privacy Policy and consent to the data processing practices described herein to the extent that such processing is based on your consent.

2Definitions

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, identification number, contact details, location data, online identifiers and financial information.
• "Processing" means any operation or set of operations performed on Personal Data, whether or not by automated means, including collection, recording, storage, adaptation, retrieval, use, disclosure, restriction or deletion.
• "Data Controller" means m1cuci, as the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of m1cuci pursuant to a written data processing agreement.
• "KYC" means Know Your Customer — the identity and age verification process required by m1cuci for account holders prior to enabling withdrawal privileges.
• "Cookies" means small text files placed on your device by the Platform to facilitate session management, analytics and security functions.
• "MYR" or "RM" means Malaysian Ringgit, the lawful currency of Malaysia and the primary transaction currency of the Platform.

3Personal Data We Collect

m1cuci collects the following categories of Personal Data in the course of providing our services to you:

3.1 Registration and Account Data

• Full legal name as per your Malaysian MyKad, passport or other government-issued identification
• Date of birth (used for age verification — you must be 21 years or older)
• Residential address, including city (e.g., Kuala Lumpur, Petaling Jaya, Penang, Johor Bahru, Shah Alam)
• Email address and Malaysian mobile phone number
• Username and encrypted password credentials
• Preferred language and communication preferences

3.2 Identity Verification (KYC) Data

• Copy of government-issued photo identification (Malaysian MyKad, passport)
• Proof of address documentation (utility bill, bank statement dated within 3 months)
• In some cases, a selfie photograph for liveness verification purposes

3.3 Financial and Transaction Data

• Deposit and withdrawal transaction records, including amounts in MYR and timestamps
• Payment method identifiers (e.g., masked bank account numbers, e-wallet account references for Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, RHB, Hong Leong)
• Cryptocurrency wallet addresses for VIP Diamond members using BTC or USDT
• Bonus credits, wagering activity and withdrawal history

3.4 Gaming and Behavioural Data

• Game session history, bet amounts, wager outcomes and account balance movements
• Sports betting selections, live betting activity and sportsbook interaction logs
• Responsible gambling tool usage (deposit limits set, self-exclusion requests, session reminders activated)

3.5 Technical and Device Data

• IP address, device type, operating system, browser type and version
• Approximate geolocation data derived from IP address
• Session timestamps, page navigation data and Platform interaction logs
• Cookie identifiers and session tokens

3.6 Communication Data

• Customer support chat transcripts, email correspondence and call records (where applicable)
• Feedback, complaint submissions and dispute correspondence

4How We Collect Your Data

m1cuci collects Personal Data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or respond to a promotion
• Automatically — through cookies, server logs and analytics tools when you browse or use the Platform
• From payment service providers — transaction confirmation data from Malaysian payment partners including DuitNow, FPX and major bank integrations when you initiate a deposit or withdrawal
• From identity verification partners — where we engage third-party KYC verification services to validate the authenticity of identity documents you submit
• From fraud prevention and security services — data shared by fraud detection partners to help us identify and prevent account fraud, money laundering and other illicit activity

5Legal Basis for Processing

m1cuci processes your Personal Data on the following legal bases:

6How We Use Your Personal Data

m1cuci uses the Personal Data we collect for the following purposes:

6.1 Service Delivery

To create and manage your account, process deposits and withdrawals in MYR via your chosen Malaysian payment method, deliver gaming services, calculate and credit bonuses (including birthday bonuses and referral rewards), and provide customer support.

6.2 Verification and Compliance

To verify your identity and age (21+ requirement), conduct KYC checks, screen transactions against anti-money-laundering obligations, and comply with all applicable regulatory requirements. m1cuci takes its compliance obligations seriously and will not process withdrawals for any account that has not completed satisfactory KYC verification.

6.3 Security and Fraud Prevention

To detect and prevent fraudulent account activity, unauthorised access, bonus abuse, multi-accounting and other prohibited conduct as defined in our Terms & Conditions. We use a combination of automated monitoring and manual review by our compliance team to investigate suspicious activity.

6.4 Responsible Gambling

To monitor gambling behaviour patterns for signs of problem gambling, enforce deposit limits and session controls set by you, process self-exclusion requests, and ensure that players who have self-excluded do not receive promotional communications or are permitted to re-register during their exclusion period.

6.5 Platform Improvement

To analyse Platform usage patterns, improve game offerings and user experience, conduct A/B testing on new features, and optimise our Malaysian payment infrastructure for faster processing times.

6.6 Marketing Communications

Where you have opted in to receive promotional communications, to send you emails, SMS messages or Platform notifications about new games, promotions, bonuses and relevant sports betting content (e.g., EPL match previews, Liga Super Malaysia odds updates, UFC fight night promotions). You may withdraw your marketing consent at any time through your Account settings.

7Data Sharing & Third-Party Disclosure

m1cuci does not sell, rent or trade your Personal Data to third parties. We may share your data only in the following limited circumstances:

7.1 Payment Service Providers

We share necessary transaction data with our Malaysian payment partners — including DuitNow operators, FPX-participating banks (Maybank, CIMB, Public Bank, RHB, Hong Leong), and e-wallet providers (Touch 'n Go eWallet, Boost, GrabPay) — solely to process your deposit and withdrawal requests. These providers process your data under their own privacy policies and applicable financial regulations.

7.2 Identity Verification Partners

KYC document data may be shared with our designated third-party identity verification service provider to authenticate your identity documents. This provider operates under a data processing agreement with m1cuci and is contractually prohibited from using your data for any other purpose.

7.3 Game and Software Providers

Limited technical identifiers (such as anonymised player IDs) may be shared with our game software providers to enable game session management and RNG certification audits. These providers do not receive your full personal profile or financial details.

7.4 Legal and Regulatory Disclosure

m1cuci may be required to disclose Personal Data to law enforcement authorities, regulatory bodies or courts of competent jurisdiction where we receive a lawful request or are legally compelled to do so — for example, in the context of an anti-money-laundering investigation or a court order.

7.5 Business Transfers

In the event of a merger, acquisition, corporate restructuring or sale of all or substantially all of m1cuci's assets, your Personal Data may be transferred to the successor entity, subject to the same data protection obligations as set out in this Policy.

8Cookies & Tracking Technologies

m1cuci uses cookies and similar tracking technologies on the Platform for the following purposes:

m1cuci does not use third-party advertising cookies or cross-site behavioural tracking technologies. You may manage or delete cookies through your browser settings; however, disabling essential cookies may impair Platform functionality including secure login and payment processing.

9Data Retention

m1cuci retains your Personal Data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following retention principles:

• Active account data — retained for the duration of your account and for a period of 5 years following account closure, to support dispute resolution, regulatory audit and anti-money-laundering record-keeping obligations.
• KYC verification documents — retained for a minimum of 5 years from the date of submission or account closure (whichever is later), in accordance with applicable financial crime prevention regulations.
• Transaction records — retained for 7 years from the date of the transaction in accordance with financial record-keeping requirements applicable to the Platform's operations.
• Customer support communications — retained for 3 years from the date of the last interaction.
• Marketing consent records — retained until consent is withdrawn, plus 3 years thereafter to demonstrate regulatory compliance.
• Technical and access logs — retained for up to 12 months for security monitoring purposes, then deleted or anonymised.

Upon expiry of the applicable retention period, Personal Data will be securely deleted or irreversibly anonymised. Where data must be retained to comply with a legal obligation, it will be restricted from further active processing until the retention period expires.

10Data Security

m1cuci implements a comprehensive set of technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, destruction, alteration or disclosure. Our security infrastructure includes:

• 256-bit TLS/SSL encryption on all data transmissions between your device and the Platform
• AES-256 encryption at rest for all sensitive stored data, including KYC documents and financial records
• Role-based access controls limiting employee access to Personal Data strictly to those with a legitimate operational need
• Multi-factor authentication requirements for all administrative and compliance staff accounts
• Regular independent penetration testing and security audits of Platform infrastructure
• Automated intrusion detection and 24/7 security monitoring of all server environments
• Formal data breach response procedures with defined notification timelines

Notwithstanding the above measures, no internet transmission or electronic storage system can be guaranteed to be 100% secure. In the event of a data security incident that is likely to result in a high risk to your rights and freedoms, m1cuci will notify affected users without undue delay in accordance with applicable data protection legislation.

11Your Data Rights

As a data subject, you hold the following rights with respect to your Personal Data processed by m1cuci. To exercise any of these rights, please contact us at [email protected]. We will respond to all verified requests within 30 calendar days.