cucirm Privacy Policy

1. Who We Are

This Privacy Policy is issued by cucirm ("cucirm", "we", "us", "our", "the Operator"), the operator of the online sports betting and casino platform accessible at cucirm.win. cucirm acts as the data controller in respect of personal data collected from users of the platform ("you", "User", "Member").

This Privacy Policy applies to all personal data collected through the cucirm website, mobile-optimised site, customer support channels, and any related services provided by the cucirm platform to registered members in Malaysia and other permitted jurisdictions. By registering a cucirm account or using the Services, you acknowledge that you have read and understood this Privacy Policy.

2. Personal Data We Collect

cucirm collects the following categories of personal data from platform users:

2.1 Identity & Contact Data

• Full legal name as it appears on your Malaysian Identity Card (MyKad) or passport;
• Date of birth;
• Residential address (including city, state, and postcode);
• Email address;
• Malaysian mobile phone number.

2.2 Financial Data

• Payment method details (e-wallet account references, bank account numbers as needed for FPX verification — card numbers are not stored on cucirm servers);
• Transaction history including deposit amounts, withdrawal amounts, dates, and payment channels used;
• Account balance history.

2.3 Account & Activity Data

• Username and encrypted password hash;
• Login timestamps and session durations;
• Betting history (markets wagered on, stake amounts, outcomes);
• Game history (slots played, casino games accessed, RTP contributions);
• Bonus and promotion claims and wagering history;
• Responsible gaming settings and limit history.

2.4 Technical & Device Data

• IP address at time of registration and each login;
• Device type, operating system, and browser version;
• Geolocation data (country and approximate city, derived from IP);
• Session identifiers and access tokens.

2.5 Communications Data

• Customer support chat transcripts and email correspondence;
• Survey responses and feedback submitted to cucirm;
• Records of marketing preference choices (opt-in / opt-out).

2.6 Identity Verification (KYC) Documents

• Copies of government-issued photo identification (MyKad, passport);
• Proof of address documents (utility bills, bank statements);
• Selfie photographs submitted for liveness verification where required.

3. How We Collect Your Data

cucirm collects personal data through the following channels:

• Direct submission: Information you provide when registering your cucirm account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or completing a form or survey on the platform.
• Automated technical collection: Data collected automatically when you access the cucirm platform, including IP address, device identifiers, session data, and browsing behaviour on the site — collected via server logs, cookies, and similar tracking technologies.
• Third-party payment providers: Transaction confirmation data received from payment processors including Touch 'n Go eWallet, Boost, FPX banking partners (Maybank, CIMB, Public Bank), and others as required to process your financial transactions.
• Identity verification partners: Data returned from third-party KYC and identity verification service providers engaged by cucirm to validate the authenticity of documents you submit.
• Fraud prevention and AML monitoring: Risk signals and flagging data received from third-party anti-fraud and anti-money-laundering screening services.

4. How We Use Your Personal Data

cucirm uses the personal data we collect for the following purposes:

• To create, maintain, and administer your cucirm account;
• To verify your identity and age in compliance with Know Your Customer (KYC) obligations under international gaming authority requirements;
• To process deposit and withdrawal transactions and maintain accurate financial records;
• To detect, investigate, and prevent fraud, money laundering, match-fixing, bonus abuse, and other prohibited conduct;
• To personalise your experience on the cucirm platform, including recommending games and promotions that may be of interest;
• To administer promotional offers, loyalty programmes, and bonuses;
• To provide customer support and respond to your enquiries and complaints;
• To send you account-related communications (e.g., deposit confirmations, security alerts, responsible gaming notifications);
• To send you marketing communications where you have opted in to receive them;
• To monitor and enforce compliance with our Terms & Conditions and Responsible Gaming Policy;
• To comply with legal obligations imposed by gaming regulators, tax authorities, law enforcement, and applicable law;
• To improve the cucirm platform through analysis of aggregate usage data and performance monitoring.

5. Legal Basis for Processing

cucirm processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and cucirm — specifically, to operate your betting account, process transactions, and provide the Services you have requested.
• Legal obligation: Processing required to comply with applicable legal obligations, including KYC/AML requirements mandated by our international gaming authority licence, and cooperation with law enforcement requests.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming enforcement, and improvement of our Services — where such interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for marketing communications, where you have provided explicit opt-in consent. You may withdraw consent at any time by contacting our support team or adjusting your communication preferences in Account Settings.

6. Data Sharing & Disclosure

cucirm does not sell your personal data to third parties. We may share your personal data with the following categories of recipients where necessary and proportionate:

• Payment processors: To facilitate deposits and withdrawals via Touch 'n Go eWallet, Boost, FPX, and other approved payment channels. These processors are contractually bound to handle your data securely and only for the stated transaction purpose.
• KYC and identity verification providers: Third-party identity verification services engaged to authenticate your registration documents.
• Game software providers: Platform providers (e.g., live casino operators) who supply the games accessible through cucirm may receive limited account and session data necessary to deliver the game service.
• Fraud prevention and AML screening services: To detect and prevent financial crime and prohibited platform activity.
• Regulatory and law enforcement authorities: Where cucirm is legally obliged to disclose personal data in response to a valid legal request, court order, or regulatory directive from our licensing authority.
• Professional advisors: Legal, accounting, and audit firms engaged by cucirm, subject to professional confidentiality obligations.

All third-party data processors engaged by cucirm are subject to data processing agreements that require them to implement appropriate technical and organisational security measures and to process personal data only on documented instructions from cucirm.

7. Cookies & Tracking Technologies

cucirm uses cookies and similar tracking technologies to operate the platform, maintain session state, prevent fraud, and improve user experience. The categories of cookies used on cucirm.win include:

• Strictly necessary cookies: Essential to the operation of the cucirm platform. These include session authentication tokens, CSRF protection cookies, and load-balancing identifiers. These cannot be disabled without impairing core functionality.
• Functional cookies: Remember your preferences and settings (e.g., language, display preferences) across sessions.
• Analytics cookies: Aggregate, anonymised data used to understand how users navigate the cucirm platform — which pages are visited, how long sessions last, and where technical errors occur. This data does not identify individual users.
• Security cookies: Used by our fraud detection systems to identify unusual access patterns associated with account compromise or automated bot activity.

cucirm does not use third-party advertising or behavioural retargeting cookies on the platform. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies will impair your ability to use the cucirm platform.

8. Data Retention

cucirm retains your personal data for as long as your account is active and for a period thereafter as required by our regulatory obligations and legitimate business interests. The following general retention principles apply:

• Account and transaction records are retained for a minimum of five (5) years following account closure, in compliance with anti-money-laundering record-keeping requirements.
• KYC identity verification documents are retained for a minimum of five (5) years from the date of the last transaction, or longer where required by the applicable gaming regulator.
• Responsible gaming records (self-exclusion requests, limit settings, player interaction logs) are retained indefinitely to prevent circumvention of self-exclusion by re-registration.
• Customer support correspondence is retained for three (3) years from the date of the last interaction.
• Marketing preference records are retained until you withdraw consent or close your account.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be attributed to an identifiable individual.

9. Your Data Subject Rights

Subject to applicable law and regulatory restrictions, you have the following rights in respect of your personal data held by cucirm:

Right	Description
Right of Access	Request a copy of the personal data cucirm holds about you and information on how it is processed.
Right to Rectification	Request correction of inaccurate or incomplete personal data held in your cucirm account.
Right to Erasure	Request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to regulatory retention obligations that may prevent full erasure.
Right to Restriction	Request that cucirm restrict the processing of your personal data in certain circumstances, such as during a dispute about data accuracy.
Right to Portability	Receive a copy of personal data you have provided to cucirm in a structured, machine-readable format where processing is based on consent or contractual necessity.
Right to Object	Object to processing of your personal data for direct marketing purposes at any time, with immediate effect.
Withdrawal of Consent	Withdraw consent for processing activities based on consent (e.g., marketing emails) at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact our customer support team via live chat or email as displayed in the footer of this page. cucirm will respond to valid requests within thirty (30) calendar days. We may require proof of identity before processing certain requests.

10. Data Security

cucirm implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Key measures include:

• TLS 1.3 with 256-bit AES encryption for all data transmitted between your browser or device and cucirm servers;
• Passwords stored exclusively as salted cryptographic hashes — plain-text passwords are never stored or accessible to cucirm staff;
• Two-Factor Authentication (2FA) available to all cucirm members and strongly recommended;
• Role-based access controls limiting staff access to personal data to those with a documented operational need;
• Regular penetration testing and vulnerability assessments of the cucirm platform;
• Player funds held in segregated accounts, separate from the Operator's operational funds;
• Automated anomaly detection monitoring login patterns for signs of account compromise or unauthorised access.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, cucirm will notify you and the relevant supervisory authority in accordance with applicable data protection law.

11. Children's Privacy

The cucirm platform is strictly for adults aged 21 and above. cucirm does not knowingly collect, use, or store personal data from individuals under the age of 21. If cucirm discovers that personal data has been submitted by a person under 21, the relevant account will be immediately closed, all funds returned to the payment source, and the data deleted in accordance with our retention policy.

If you believe that a person under 21 has registered a cucirm account, please contact our customer support team immediately so that appropriate action can be taken.

12. International Data Transfers

cucirm may transfer your personal data to third-party service providers or group entities located outside Malaysia, including jurisdictions where cucirm's gaming licences are held. Where such transfers occur, cucirm ensures that appropriate safeguards are in place — including standard contractual clauses approved by relevant data protection authorities — to provide a level of protection for your data substantially equivalent to that afforded within Malaysia.

Your personal data will not be transferred to jurisdictions that do not provide an adequate level of data protection without your explicit consent or unless cucirm is legally required to do so.

13. Amendments to This Privacy Policy

cucirm reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. When material changes are made, cucirm will provide advance notice to registered account holders via email or a prominent notice on the platform.

The date of the most recent revision is displayed at the top of this page. Your continued use of the cucirm platform following the effective date of any revision constitutes your acknowledgment of the updated Privacy Policy. We encourage you to review this Policy periodically.

14. Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or have a concern about how cucirm has handled your personal data, please contact our customer support team via live chat on the cucirm platform, available 24 hours a day, 7 days a week. Our official support email address is displayed in the footer of this page.

cucirm will acknowledge privacy-related enquiries within two (2) business days and provide a substantive response within thirty (30) calendar days. If you are not satisfied with our response, you may have the right to lodge a complaint with the supervisory authority responsible for data protection in your jurisdiction.