sinicuci Privacy Policy

1. Introduction

sinicuci ("we", "us", "our") operates the online gaming platform accessible at sinicuci.club. We are committed to protecting the privacy and personal data of every player and visitor who interacts with the sinicuci platform. This Privacy Policy ("Policy") describes in detail how we handle personal data in connection with your use of the sinicuci website, account registration process, gaming services, payment functions, and any other interactions with the sinicuci brand.

By accessing sinicuci.club or creating a sinicuci Account, you acknowledge that you have read and understood this Policy and consent to the collection, use, and processing of your personal data as described herein. If you do not agree to the terms of this Policy, please discontinue your use of the sinicuci platform.

This Policy should be read alongside sinicuci's Terms & Conditions and Responsible Gaming Policy. In the event of any conflict between this Policy and those documents, the specific terms applicable to the subject matter shall prevail.

2. Data Controller

The data controller responsible for personal data collected through the sinicuci platform is the operator of sinicuci.club. For all data-related enquiries, including requests to exercise your rights under applicable personal data protection law, please contact us at the details provided in Section 15 of this Policy.

sinicuci processes personal data in accordance with applicable data protection legislation, including the principles embodied in Malaysia's Personal Data Protection Act 2010 (PDPA) and equivalent international standards applicable under the jurisdiction of sinicuci's operating licence.

3. Personal Data We Collect

sinicuci collects the following categories of personal data in connection with the provision of its Services:

3.1 Identity & Contact Data

• Full legal name as it appears on your MyKad or passport
• Date of birth (for age verification — all players must be aged 21 or above)
• Malaysian mobile phone number
• Email address
• Residential address
• MyKad number or equivalent national identification number

3.2 Financial & Transaction Data

• Deposit and withdrawal transaction records, including amounts, timestamps, and payment method references
• e-Wallet account references (Touch n Go eWallet, Boost, GrabPay) used for transactions with sinicuci
• Bank account details used for Maybank or CIMB transfers
• Cryptocurrency wallet addresses used for USDT TRC20 transactions
• Bonus and promotional credit history

3.3 Account & Gaming Activity Data

• sinicuci Account username and login credentials (passwords stored in hashed, encrypted form only)
• Gaming history: games played, bets placed, winnings, session duration
• Sportsbook betting records: events bet on, odds accepted, results
• Responsible gaming settings: deposit limits, session alerts, self-exclusion status

3.4 Technical & Device Data

• IP address and approximate geolocation derived therefrom
• Device type, operating system, and browser version
• Session tokens and authentication logs
• Cookie identifiers and similar tracking technology data (see Section 8)

3.5 KYC Verification Data

• Copies of identity documents (MyKad front and back, or passport data page)
• Selfie or liveness verification images submitted during the KYC process
• Any additional documentation requested for enhanced due diligence purposes

4. How We Collect Personal Data

sinicuci collects personal data through the following means:

• Direct provision: Data you provide when registering a sinicuci Account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or completing any form on the platform.
• Automated collection: Technical data collected automatically during your use of the sinicuci website, including through cookies, server logs, and analytics tools (see Section 8).
• Third-party payment processors: Confirmation data received from Touch n Go eWallet, Boost, GrabPay, Maybank, CIMB, and other payment partners when you initiate a transaction on sinicuci.
• Identity verification providers: Results and data returned by third-party KYC service providers engaged by sinicuci to verify player identities and screen against sanctions and PEP lists.
• Game providers: Session and outcome data returned by sinicuci's integrated game content providers (PG Soft, Evolution Gaming, Pragmatic Play, etc.) to facilitate correct account crediting, dispute resolution, and regulatory reporting.

5. Legal Basis for Processing

sinicuci processes personal data on one or more of the following legal bases, depending on the nature of the processing activity:

• Contractual necessity: Processing required to create and manage your sinicuci Account, process deposits and withdrawals, deliver gaming services, and fulfil our obligations under the Terms & Conditions you have accepted.
• Legal obligation: Processing required to comply with applicable laws including anti-money laundering (AML) regulations, know-your-customer (KYC) requirements, and obligations under our gaming operating licence.
• Legitimate interests: Processing carried out for fraud detection and prevention, platform security, responsible gaming enforcement, and improvement of sinicuci's products and services, where such processing does not override your fundamental rights and freedoms.
• Consent: Processing carried out on the basis of your explicit consent, including the use of non-essential cookies (see Section 8) and certain marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. How We Use Your Personal Data

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

7. Data Sharing & Disclosure

sinicuci does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data processing agreements:

• Payment processors: Touch n Go eWallet, Boost, GrabPay, Maybank, CIMB, and other payment partners, solely to the extent necessary to process your requested transactions.
• KYC and AML service providers: Third-party identity verification and sanctions screening providers engaged to assist sinicuci in meeting its regulatory compliance obligations.
• Game content providers: PG Soft, Evolution Gaming, Pragmatic Play, and other integrated providers, to the extent required to deliver certified gameplay and resolve game-related disputes.
• Regulatory authorities: Gaming licensing authorities, financial intelligence units, and law enforcement agencies where disclosure is required by law, court order, or regulatory directive.
• IT and infrastructure providers: Cloud hosting, data storage, and cybersecurity service providers engaged by sinicuci, all of whom are bound by contractual data protection obligations no less protective than this Policy.

8. Cookies & Tracking Technologies

sinicuci uses cookies and similar tracking technologies on its platform. The following cookie categories are used:

• Strictly necessary cookies: Required for core platform functionality, including session authentication, login state management, and security token validation. These cookies cannot be disabled without impairing your ability to use sinicuci.
• Functional cookies: Used to remember your preferences such as language settings, responsible gaming limit configurations, and layout preferences on the sinicuci platform.
• Analytics cookies: Used to collect aggregated, anonymised data about how players interact with the sinicuci platform — pages visited, session duration, device types — to help us improve the user experience. No personally identifiable information is transmitted via analytics cookies.
• Fraud prevention cookies: Used to detect and prevent automated and fraudulent access attempts on the sinicuci platform.

You may manage non-essential cookie preferences through your browser settings. Blocking all cookies may affect the functionality of the sinicuci platform, including the ability to remain logged in between sessions.

9. Data Retention

sinicuci retains personal data for as long as necessary to fulfil the purposes for which it was collected and to comply with applicable legal, regulatory, and contractual obligations. The following general retention periods apply:

• Active Account data: Retained for the duration of your Account's active status on sinicuci.
• KYC and identity documents: Retained for a minimum of five (5) years following Account closure or the last transaction, in accordance with AML regulatory requirements.
• Financial transaction records: Retained for a minimum of seven (7) years following each transaction, in compliance with financial record-keeping obligations.
• Gaming activity logs: Retained for a minimum of three (3) years from the date of the session, subject to applicable regulatory requirements.
• Marketing consent records: Retained until consent is withdrawn, and for a reasonable period thereafter as evidence of the consent given.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction of the original data.

10. Your Rights

Subject to applicable personal data protection law, including Malaysia's Personal Data Protection Act 2010, you have the following rights with respect to your personal data held by sinicuci:

• Right of access: You may request a copy of the personal data sinicuci holds about you and information about how it is processed.
• Right to correction: You may request correction of inaccurate or incomplete personal data. You may update most Account information directly through your sinicuci Account settings.
• Right to withdraw consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
• Right to restrict processing: In certain circumstances, you may request that sinicuci restrict processing of your personal data, such as while a dispute regarding data accuracy is resolved.
• Right to erasure: Subject to overriding legal obligations (such as AML data retention requirements), you may request deletion of your personal data following closure of your sinicuci Account.
• Right to complain: You have the right to lodge a complaint with Malaysia's Personal Data Protection Commissioner or the relevant regulatory authority in your jurisdiction if you believe sinicuci has not handled your personal data lawfully.

To exercise any of the above rights, please contact sinicuci at [email protected] with the subject line "Data Rights Request". sinicuci will respond to verified requests within 30 days of receipt.

11. Data Security

sinicuci implements technical and organisational security measures appropriate to the risk level associated with the personal data we process. Key security measures include:

• 256-bit SSL/TLS encryption on all data in transit between your device and sinicuci's servers
• Encryption of sensitive data fields (including passwords, which are stored only as cryptographic hashes and never in plain text) at rest
• Role-based access controls limiting sinicuci staff access to personal data on a strict need-to-know basis
• Two-factor authentication available to all registered sinicuci players to protect Account access
• Regular security audits and penetration testing of the sinicuci platform and infrastructure
• Automated monitoring for unusual login patterns, suspicious transaction activity, and potential data breach indicators

Notwithstanding the above, no internet-based system can be guaranteed to be completely secure. sinicuci will notify affected players and relevant authorities in the event of a data breach that poses a significant risk to individual rights and freedoms, in accordance with applicable legal requirements.

12. Children & Minors

sinicuci's Services are strictly intended for individuals who are 21 years of age or older. sinicuci does not knowingly collect, process, or store personal data of persons under 21 years of age. Age verification is a mandatory component of the sinicuci KYC process.

If sinicuci discovers or has reason to believe that a registered Account belongs to a person under 21 years of age, the Account will be immediately suspended, all associated Funds withheld pending investigation, and the data associated with the Account handled in accordance with applicable legal requirements for minor data protection.

If you are a parent or guardian and believe that a minor in your care has accessed or registered an Account on sinicuci, please contact us immediately at [email protected].

13. Cross-Border Data Transfers

In order to provide its Services, sinicuci may transfer personal data to third parties located in jurisdictions outside Malaysia, including but not limited to cloud infrastructure providers, game content providers, and KYC verification services. Where such transfers occur, sinicuci ensures that appropriate safeguards are in place, including:

• Contractual data processing agreements incorporating standard data protection clauses
• Transfer only to jurisdictions that provide an adequate level of personal data protection as assessed under applicable law
• Implementation of supplementary technical measures (such as encryption) where the destination jurisdiction's protections are assessed as insufficient in isolation

14. Changes to This Privacy Policy

sinicuci reserves the right to update this Privacy Policy at any time. Where changes are material — such as a change in the categories of data collected, the purposes for which data is used, or the rights available to players — sinicuci will provide advance notice via a notification on the platform or by email to your registered address. The "Last updated" date at the top of this page reflects the date of the most recent revision.

Your continued use of the sinicuci platform following any update to this Policy constitutes your acknowledgement of the revised Policy. If you do not agree with any change, you may close your sinicuci Account by contacting our support team.

15. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by sinicuci, please contact us using the details below:

• Email: [email protected] (plain text only — not a clickable link)
• Subject Line for Data Requests: "Data Rights Request" or "Privacy Policy Enquiry"
• Response Time: Within 30 days for formal data rights requests; within 1–2 business days for general privacy enquiries (GMT+8, Malaysian business hours)

sinicuci is committed to handling all personal data queries in a transparent, fair, and timely manner consistent with our obligations under applicable data protection law and the standards required by our gaming authority licensing framework.