Privacy Policy

1. Introduction and Data Controller Identity

This Privacy Policy ("Policy") is issued by sukacuci ("sukacuci", "we", "us", "our"), the operator of the online gaming platform accessible at sukacuci.org and all associated subdomains and services (the "Platform"). sukacuci acts as the data controller in respect of personal data collected from Members and visitors to the Platform.

sukacuci is committed to protecting the privacy and personal data of all individuals who interact with the Platform. This Policy describes in detail what personal data sukacuci collects, why it is collected, how it is used, with whom it may be shared, and what rights data subjects have in relation to their personal data. This Policy forms part of sukacuci's Terms & Conditions and should be read alongside them.

By registering a sukacuci account, accessing the Platform, or submitting personal data to sukacuci in any form, 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.

2. Definitions

In this 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 information, location data, financial details, and online identifiers.
• "Member" means any individual who has completed the sukacuci registration process and holds an active or previously active account on the Platform.
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure, transfer, or deletion.
• "Third Party" means any entity other than sukacuci and the data subject, including payment processors, identity verification providers, game studios, and regulatory authorities.

3. Personal Data We Collect

sukacuci collects the following categories of personal data from Members and Platform visitors:

• Registration Data: Full legal name, date of birth, Malaysian NRIC number or passport number, residential address, email address, and mobile phone number provided during account registration.
• Verification Data: Copies of government-issued identification documents, utility bills, or other documents submitted for identity and age verification purposes.
• Financial Data: Bank account details, eWallet identifiers (Touch 'n Go eWallet, Boost), and transaction records including deposit amounts, withdrawal amounts, dates, and payment method references.
• Gaming Activity Data: Betting history, game session data, bet amounts, odds, results, and wagering patterns across all products on the Platform (Sportsbook, Casino, Slots, Toto 4D, Lucky Dice).
• Device and Technical Data: IP address, browser type and version, operating system, device identifiers, screen resolution, and connection information collected automatically when you access the Platform.
• Communications Data: Records of correspondence between the Member and sukacuci support, including live chat logs, email exchanges, and support ticket content.
• Responsible Gaming Data: Self-exclusion requests, deposit limits, loss limits, session time settings, and any information provided in connection with responsible gaming tools.

4. How We Collect Your Personal Data

sukacuci collects personal data through the following means:

• Directly from you when you register an account, complete identity verification, make a deposit or withdrawal, contact support, set responsible gaming limits, or update your account settings.
• Automatically through cookies, log files, and similar tracking technologies when you access or interact with the Platform.
• From third parties, including identity verification service providers who assist sukacuci in confirming the identity and age of Members, and payment processors who provide transaction confirmation data.

5. Purposes and Legal Basis for Processing

sukacuci processes Member personal data for the following purposes:

• Account Registration and Management: To create, maintain, and administer Member accounts on the Platform. Legal basis: performance of a contract.
• Identity and Age Verification: To verify that Members are who they claim to be and that they meet the minimum age requirement of 21 years. Legal basis: legal obligation and protection of vulnerable individuals.
• Payment Processing: To process deposits, settle winnings, and execute withdrawal requests in Malaysian Ringgit (MYR). Legal basis: performance of a contract.
• Anti-Money Laundering and Fraud Prevention: To monitor transactions for indicators of money laundering, fraud, or other financial crime, and to report suspicious activity to relevant authorities where required by law. Legal basis: legal obligation.
• Customer Support: To respond to Member enquiries, investigate complaints, and resolve disputes. Legal basis: performance of a contract and legitimate interests.
• Platform Security: To detect, prevent, and investigate security incidents, unauthorised access, and technical abuse of the Platform. Legal basis: legitimate interests.
• Responsible Gaming: To administer responsible gaming tools including self-exclusion, deposit limits, and loss limits, and to identify Members who may be exhibiting signs of problem gambling. Legal basis: legal obligation and protection of vulnerable individuals.
• Marketing and Promotions: To send Members information about sukacuci promotions, bonuses, and platform updates where the Member has not opted out of such communications. Legal basis: legitimate interests or consent, as applicable.
• Legal Compliance: To comply with applicable laws, regulations, and directives issued by relevant regulatory authorities. Legal basis: legal obligation.

6. Disclosure of Personal Data to Third Parties

sukacuci does not sell, rent, or trade Member personal data to third parties for their independent marketing purposes. sukacuci may disclose Member personal data to the following categories of third parties where necessary for the purposes described in Section 5:

• Payment Service Providers: Including FPX operators, Maybank, CIMB, Public Bank, RHB Bank, Touch 'n Go eWallet, and Boost, for the purpose of processing deposits and withdrawals.
• Identity Verification Providers: Third-party services that assist sukacuci in verifying Member identity and age against authoritative data sources.
• Game Studio Partners: Certified game studios providing live casino and slot content may receive limited session data necessary for game integrity auditing and technical support.
• Regulatory and Law Enforcement Authorities: sukacuci may be required to disclose Member data to financial intelligence units, gaming regulatory bodies, or law enforcement agencies in response to legally binding orders or where disclosure is required by applicable law.
• IT and Infrastructure Providers: Hosting, cloud storage, and cybersecurity service providers operating under contractual data processing obligations that require them to protect Member data to a standard equivalent to sukacuci's own obligations.

7. International Data Transfers

Where sukacuci transfers Member personal data to recipients located outside Malaysia, such transfers are conducted only where adequate data protection safeguards are in place, including contractual clauses that impose obligations on the recipient equivalent to those applicable to sukacuci under this Policy. sukacuci will not transfer personal data internationally where doing so would result in a material reduction in the protection afforded to that data under this Policy.

8. Data Retention

sukacuci retains Member personal data for as long as is necessary to fulfil the purposes described in this Policy, or as required by applicable law. The following general retention periods apply:

• Account registration and identity verification data: retained for the lifetime of the Member's account and for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping obligations.
• Transaction records: retained for a minimum of seven (7) years from the date of the transaction, in compliance with applicable financial record-keeping requirements.
• Communications data: retained for two (2) years from the date of the last communication, unless retention for a longer period is required in connection with an open complaint or legal matter.
• Device and technical data: retained for up to twelve (12) months from the date of collection, subject to extension where required for security investigation purposes.

9. Security Measures

sukacuci implements a range of technical and organisational security measures designed to protect Member personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between Member devices and sukacuci's servers.
• Encryption of sensitive data fields at rest within sukacuci's databases, including financial account details and identification document data.
• Role-based access controls limiting sukacuci staff access to Member personal data to those with a documented business need.
• Regular security assessments and penetration testing of Platform infrastructure.
• Incident response procedures for the detection, investigation, and remediation of data security incidents, including notification procedures where a breach is likely to result in a risk to affected individuals.

10. Cookies and Tracking Technologies

The sukacuci Platform uses cookies and similar tracking technologies to support Platform functionality, enhance user experience, and collect analytical data about Platform usage. The following types of cookies are used:

• Essential Cookies: Required for the Platform to function, including session management, authentication state, and security tokens. These cookies cannot be disabled without impairing Platform functionality.
• Analytical Cookies: Used to collect aggregated, anonymised data about how Members navigate and use the Platform, enabling sukacuci to identify areas for improvement.
• Preference Cookies: Used to remember Member preferences such as language settings and responsible gaming tool configurations.

Members may manage cookie preferences through their browser settings. Disabling essential cookies may result in reduced Platform functionality or an inability to access certain features.

11. Your Rights as a Data Subject

Members and visitors to the sukacuci Platform have the following rights in relation to their personal data, subject to applicable legal limitations:

• Right of Access: You may request a copy of the personal data sukacuci holds about you.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data held by sukacuci.
• Right to Erasure: You may request deletion of your personal data where continued retention is no longer necessary or lawful, subject to sukacuci's obligations to retain data under applicable law.
• Right to Restriction of Processing: You may request that sukacuci restrict processing of your personal data in certain circumstances, such as where accuracy is contested.
• Right to Object: You may object to processing of your personal data based on sukacuci's legitimate interests, including processing for direct marketing purposes.
• Right to Data Portability: Where processing is based on consent or contract performance, you may request that sukacuci provide your personal data in a structured, commonly used, machine-readable format.

Data subject requests may be submitted to sukacuci at [email protected]. sukacuci will respond to all requests within 30 days of receipt. In some cases, sukacuci may request proof of identity before processing a data subject request.

12. Children and Minors

The sukacuci Platform is strictly intended for individuals aged 21 years and above. sukacuci does not knowingly collect personal data from individuals below the age of 21. If sukacuci becomes aware that personal data has been collected from a person below the minimum age, it will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered a sukacuci account or submitted personal data to the Platform, please contact [email protected] immediately.

13. Changes to This Privacy Policy

sukacuci may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Where changes are material, sukacuci will provide notice to existing Members via email or through a notice displayed at sukacuci Login. The date of the most recent revision is shown at the top of this Policy. Continued use of the Platform following the effective date of any revision constitutes acceptance of the updated Policy.

14. Contact and Data Subject Requests

For any questions about this Privacy Policy, to exercise your data subject rights, or to report a suspected data security incident, please contact the sukacuci data protection team at:

Email: [email protected]

sukacuci's support team operates 24 hours a day, 7 days a week, in English. All data protection enquiries are logged and addressed by a designated member of the sukacuci compliance team.