sinicuci Privacy Policy

1 Introduction

sinicuci ("we", "us", "our") is committed to protecting the privacy and personal data of all Members and visitors to the sinicuci platform. This Privacy Policy describes the categories of personal data we collect, the purposes for which that data is processed, the parties with whom it may be shared, and the rights available to you in relation to your personal data.

This Policy should be read alongside the sinicuci Terms & Conditions, which govern the general use of the Platform. Capitalised terms used but not defined in this Policy have the meanings given to them in the Terms and Conditions.

sinicuci processes personal data in accordance with applicable data protection legislation and the requirements of its international gaming authority licence. We take our obligations seriously, and this Policy is intended to give you genuine transparency over how your information is handled — not just satisfy a compliance checkbox.

2 Personal Data We Collect

sinicuci collects the following categories of personal data, to the extent necessary for the purposes described in this Policy:

3 How We Collect Your Data

3.1  Directly from you — when you register an account, complete identity verification, make a deposit or withdrawal, contact our support team, or submit any form on the sinicuci Platform.

3.2  Automatically — through cookies, session tracking, and server logs when you access the Platform. Technical data is collected passively as part of the normal operation of the website and mobile interface.

3.3  From third parties — including identity verification service providers (for KYC checks), payment processors (Maybank, CIMB, Public Bank, Touch n Go eWallet, Boost), fraud detection services, and gaming compliance providers. sinicuci engages these third parties to verify information you have provided and to fulfil our regulatory obligations.

4 How We Use Your Personal Data

sinicuci processes your personal data for the following purposes:

• Account administration: creating and managing your sinicuci account, verifying your identity, and maintaining accurate Member records;
• Service delivery: enabling access to all sinicuci Platform products including Sportsbook, Casino, Slots, E-Sports, and Toto 4D; processing bets and game outcomes;
• Payments: processing deposits and withdrawals via your registered payment methods (Touch n Go eWallet, Boost, Maybank, and others); maintaining transaction records;
• Regulatory compliance: fulfilling anti-money laundering (AML), counter-terrorism financing (CTF), and know-your-customer (KYC) obligations under our international gaming licence;
• Security and fraud prevention: detecting, investigating, and preventing fraudulent activity, account takeover, prohibited conduct, and other security threats;
• Responsible gaming: monitoring account activity for signs of at-risk behaviour; administering self-exclusion arrangements; fulfilling obligations to notify gaming authorities where required;
• Customer support: responding to queries, resolving disputes, and processing complaints;
• Platform improvement: analysing aggregated, anonymised usage data to improve the sinicuci Platform's performance, design, and feature set;
• Communications: sending service-related notifications (bet settlement, withdrawal status, security alerts) and, where you have opted in, promotional communications.

5 Legal Basis for Processing

5.1  Performance of a contract: the majority of sinicuci's processing is necessary to provide you with the services you have registered for and to administer your Account in accordance with the Terms and Conditions.

5.2  Legal obligation: AML, KYC, CTF, and responsible gaming obligations imposed by our licensing authority require us to collect, verify, and retain certain categories of data regardless of individual consent.

5.3  Legitimate interests: fraud prevention, security monitoring, and aggregated platform analytics are processed on the basis of sinicuci's legitimate interests in operating a secure and legally compliant platform, balanced against Members' privacy interests.

5.4  Consent: where sinicuci relies on consent as a legal basis — primarily for marketing communications — you may withdraw that consent at any time through your account settings or by contacting customer support. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

6 Data Sharing & Disclosure

sinicuci does not sell, rent, or trade your personal data to third-party marketing organisations. Your data may be shared with the following categories of recipients, strictly as necessary:

• Payment processors and e-wallet providers (Touch n Go eWallet, Boost, Maybank, CIMB, Public Bank) — to process deposits and withdrawals;
• Identity verification and KYC providers — to verify the identity and age of Members in accordance with regulatory requirements;
• Fraud and AML screening services — to screen transactions and account activity against sanctions lists and fraud databases;
• Gaming software providers (e.g., Evolution Gaming, Pragmatic Play, PG Soft) — to the extent technically necessary for game delivery; these providers process data under contractual data processing agreements with sinicuci;
• Regulatory and licensing authorities — where required by our international gaming licence or applicable law;
• Law enforcement and government bodies — where required by court order, legal process, or applicable regulatory obligation.

All third-party service providers engaged by sinicuci are contractually required to process personal data only for the specified purpose, to maintain appropriate security measures, and to comply with applicable data protection law.

7 International Data Transfers

7.1  sinicuci's infrastructure and certain third-party service providers may be located outside Malaysia. Where personal data is transferred internationally, sinicuci ensures that appropriate safeguards are in place in accordance with applicable data protection law, including contractual protections and, where applicable, adherence to adequacy frameworks recognised by relevant data protection authorities.

7.2  Members whose data is subject to international transfer will not experience a material reduction in the privacy protections afforded to them under this Policy as a result of that transfer.

8 Data Retention

8.1  sinicuci retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods imposed by our regulatory obligations:

• Account and transaction records: minimum five (5) years from account closure or last transaction (AML/KYC requirement);
• Identity verification documents: minimum five (5) years from the date of verification or account closure, whichever is later;
• Responsible gaming records: retained for the duration of any applicable self-exclusion and for a minimum of three (3) years thereafter;
• Support communications: two (2) years from ticket closure, unless required longer for dispute resolution purposes.

8.2  Once the applicable retention period expires and there is no legal basis for continued retention, personal data is securely deleted or irreversibly anonymised in accordance with sinicuci's data disposal procedures.

9 Cookies & Tracking Technologies

9.1  sinicuci uses cookies and similar tracking technologies to operate the Platform, maintain your session, detect fraud, and — where you have consented — analyse platform usage patterns for improvement purposes.

Types of Cookies Used

• Strictly necessary cookies: required for the Platform to function, including session authentication, security tokens, and load balancing. These cannot be disabled without rendering the Platform inoperable.
• Functional cookies: remember your preferences (such as language and display settings) to improve your experience across sessions.
• Analytics cookies: collect aggregated, anonymised data about how Members use the Platform, which sinicuci uses to improve navigation, performance, and feature design.

9.2  sinicuci does not use third-party advertising or behavioural targeting cookies. You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair Platform functionality.

10 Your Data Rights

Subject to applicable law and any overriding regulatory obligations, you have the following rights in relation to your personal data held by sinicuci:

• Right of access: to request a copy of the personal data sinicuci holds about you;
• Right to rectification: to request correction of inaccurate or incomplete personal data;
• Right to erasure: to request deletion of your personal data, subject to sinicuci's legal retention obligations (for example, AML/KYC records cannot be deleted upon request);
• Right to restriction: to request that processing of your data be restricted in certain circumstances;
• Right to data portability: to receive your personal data in a structured, commonly used, machine-readable format where technically feasible;
• Right to object: to object to processing based on legitimate interests;
• Right to withdraw consent: where processing is based on consent, to withdraw that consent at any time.

To exercise any of these rights, please contact sinicuci's customer support team via the 24/7 Live Chat in your account dashboard or by email at [email protected]. sinicuci will respond to verified requests within thirty (30) days, subject to any extension permitted by applicable law for complex requests.

11 Security Measures

11.1  sinicuci implements a range of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction, including:

• 256-bit SSL/TLS encryption for all data in transit between your device and sinicuci servers;
• AES-256 encryption for sensitive data at rest, including financial and identity data;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Two-factor authentication requirements for administrative system access;
• Regular third-party security audits and penetration testing;
• Incident response procedures with defined escalation and notification timelines.

11.2  In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, sinicuci will notify you without undue delay, in accordance with applicable data breach notification obligations.

12 Children and Minors

12.1  The sinicuci Platform is strictly for use by individuals aged 21 and above. sinicuci does not knowingly collect personal data from individuals under the age of 21. If sinicuci becomes aware that personal data has been collected from a person under the minimum age, that data will be deleted and the associated account closed immediately.

12.2  If you believe that sinicuci holds personal data relating to a person under 21, please contact us immediately via customer support or at [email protected].

13 Changes to This Privacy Policy

13.1  sinicuci reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Material changes will be communicated to Members via a prominent notice on the Platform and/or notification to your registered contact details, with a minimum of seven (7) days' advance notice.

13.2  Continued use of the sinicuci Platform following the effective date of any amendment constitutes acknowledgement of the updated Policy. We encourage you to review this page periodically. The date of the most recent revision is displayed at the top of this page.

14 Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or sinicuci's data processing practices, please contact us through the following channels:

sinicuci operates under international gaming authority licensing. Regulatory enquiries relating to data protection compliance may also be directed to the applicable licensing authority through its published regulatory contact channels.