Privacy Policy – 77cuci

1. Introduction

This Privacy Policy ("Policy") describes how 77cuci ("we," "us," "Platform," or "77cuci"), accessible at 77cuci.win, collects, processes, stores, and discloses personal data about individuals ("you," "Member," "User") who visit, register with, or otherwise interact with the Platform.

77cuci is committed to protecting your privacy and handling your personal data in a manner consistent with applicable data protection legislation, including the Personal Data Protection Act 2010 (PDPA) of Malaysia and the data protection requirements of our international gaming authority licensing regime. By registering an account with 77cuci or using the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

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

2. Data Controller

For the purposes of applicable data protection law, 77cuci is the data controller in respect of personal data processed under this Policy. Queries regarding data processing activities may be directed to our support team at [email protected] with the subject line "Data Privacy Inquiry."

3. Data We Collect

77cuci collects personal data in the following categories:

3.1 Registration & Identity Data

Full legal name, date of birth, nationality, residential address, email address, mobile telephone number, and username. This data is collected at the time of account registration and is required to create and maintain a 77cuci account.

3.2 Identity Verification (KYC) Data

Copies of government-issued identification documents (e.g., MyKad, passport), utility bills or other proof-of-address documents, and selfie photographs where required for biometric verification. KYC data is collected when you initiate your first withdrawal or when 77cuci is required to verify your identity under its licensing obligations.

3.3 Financial Data

Payment method details (e-wallet identifiers, bank account names, transaction reference numbers), deposit and withdrawal amounts, transaction histories, and wallet balances. Full payment credentials (e.g., full bank account numbers) are not stored by 77cuci; they are processed by PCI DSS-compliant payment processors.

3.4 Gaming Activity Data

Game session logs, bet amounts, game outcomes, win/loss records, active bonus statuses, and promotional opt-in records. This data is retained as required by our gaming licence and for responsible gaming monitoring purposes.

3.5 Technical & Device Data

IP address, browser type and version, operating system, device identifiers, screen resolution, referring URL, pages visited, session duration, and clickstream data. This data is collected automatically when you access the Platform.

3.6 Communications Data

Records of live chat sessions, email correspondence, and support ticket history between you and 77cuci staff. These are retained for quality assurance, dispute resolution, and regulatory compliance.

4. How We Use Your Data

77cuci uses your personal data for the following purposes:

• Account administration: creating, maintaining, and managing your 77cuci account; processing deposits and withdrawals; verifying your identity and age.
• Gaming operations: providing and improving game services, calculating and crediting winnings, administering bonuses and promotions.
• Regulatory compliance: fulfilling obligations under our gaming licence, anti-money laundering (AML) laws, counter-terrorism financing (CTF) regulations, and the Personal Data Protection Act 2010.
• Responsible gaming: monitoring gaming patterns to identify potentially problematic behaviour; enforcing self-exclusion and account limits; complying with responsible gaming obligations under our licence.
• Fraud prevention and security: detecting, investigating, and preventing fraudulent transactions, account breaches, and other prohibited activities.
• Customer support: responding to your inquiries, resolving disputes, and improving the quality of support provided.
• Platform improvement: analysing aggregated usage data to improve Platform performance, user experience, and product offerings.
• Marketing: sending promotional communications where you have opted in, and administering loyalty programmes (see Section 11).

5. Legal Basis for Processing

77cuci processes your personal data on the following legal grounds:

• Contractual necessity: processing required to perform our contract with you, including account management, payment processing, and provision of gaming services.
• Legal obligation: processing required to comply with applicable law, including AML/CTF obligations, gaming licensing requirements, and tax reporting obligations.
• Legitimate interests: processing required for fraud prevention, security monitoring, responsible gaming oversight, and Platform analytics, where our interests are not overridden by your fundamental rights.
• Consent: processing for marketing communications, where you have provided explicit opt-in consent. You may withdraw consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.

6. Sharing Your Data with Third Parties

77cuci does not sell, rent, or trade personal data. We share data only in the following limited circumstances:

• Payment processors: to facilitate deposits and withdrawals via Touch n Go eWallet, Boost, GrabPay, Maybank, CIMB, and other supported payment methods. Payment processors receive only the data necessary to execute the transaction.
• Game providers: technical data (such as session tokens) required to load and operate third-party game content. Game providers do not receive your identity or financial data.
• KYC and AML compliance providers: identity verification services used to fulfil our regulatory KYC obligations. These providers are bound by confidentiality and data security obligations.
• Regulatory authorities and law enforcement: where 77cuci is required to disclose data under applicable law, a court order, or a regulatory directive. 77cuci will notify you of such disclosure where legally permitted to do so.
• Professional advisers: legal, audit, and compliance advisers, subject to professional confidentiality obligations.
• Business transfers: in connection with a merger, acquisition, or sale of all or substantially all of 77cuci's assets, subject to the acquirer assuming equivalent data protection obligations.

7. Cookies & Tracking Technologies

77cuci uses cookies and similar tracking technologies to enable essential Platform functions, analyse usage patterns, and enhance user experience. The following categories of cookies are used:

• Strictly necessary cookies: required for core Platform functionality including authentication, session management, and security. These cannot be disabled.
• Performance cookies: collect anonymised data about how visitors use the Platform, which pages are visited most frequently, and where errors occur. This data is used solely to improve Platform performance.
• Functional cookies: remember your preferences (e.g., language, display settings) to provide a personalised experience on return visits.

You may manage your cookie preferences through your browser settings. Disabling non-essential cookies will not prevent access to the Platform but may affect certain personalisation features. 77cuci does not use cookies to serve third-party advertising.

8. Data Security

77cuci implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• 256-bit AES encryption for data stored at rest in production databases.
• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform.
• Role-based access controls limiting internal access to personal data to authorised personnel with a legitimate operational need.
• Regular penetration testing and security audits conducted by independent third parties.
• Incident response procedures for detecting, containing, and notifying affected parties of personal data breaches where required by law.

No method of electronic transmission or storage is 100% secure. While 77cuci uses commercially reasonable measures to protect your data, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your 77cuci Login credentials and must notify us immediately if you suspect any unauthorised access to your account.

9. Data Retention

77cuci retains personal data for as long as your account remains active and for a period thereafter as required by applicable law and our gaming licence. Typical retention periods are as follows:

• Account and identity data: retained for a minimum of five (5) years from account closure, or such longer period as required by applicable AML legislation or gaming regulations.
• Financial transaction data: retained for a minimum of seven (7) years from the date of each transaction in compliance with financial record-keeping requirements.
• Gaming activity data: retained for the duration of the account and for five (5) years after account closure.
• Technical and device data: retained for up to twelve (12) months from the date of collection, or longer where required for an ongoing investigation or legal proceeding.
• Communications data: retained for three (3) years from the date of the communication unless retention is required in connection with a dispute or regulatory matter.

Upon expiry of applicable retention periods, data is securely deleted or irreversibly anonymised.

10. Your Data Rights

Subject to applicable data protection law, you have the following rights in respect of personal data held by 77cuci:

• Right of access: to request a copy of the personal data we hold about you.
• Right to rectification: to request correction of inaccurate or incomplete personal data.
• Right to erasure: to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to restrict processing: to request that we limit our processing of your data in certain circumstances, such as while a rectification request is being resolved.
• Right to data portability: to receive a structured, machine-readable copy of personal data you have provided to us.
• Right to object: to object to processing based on legitimate interests, including direct marketing.
• Right to withdraw consent: where processing is based on your consent, to withdraw that consent at any time without affecting prior processing.

To exercise any of the above rights, please contact 77cuci via live chat or email at [email protected] with the subject line "Data Rights Request." We will respond within 30 days of receipt. We may require identity verification before actioning certain requests.

11. Marketing Communications

77cuci may send you promotional emails, SMS messages, and in-platform notifications regarding bonuses, new games, tournaments, and other promotions if you have opted in to receive such communications during registration or via account settings.

You may withdraw your consent to receive marketing communications at any time by updating your notification preferences in Account Settings, or by contacting 77cuci support. Opt-out requests will be processed within one business day. Please note that withdrawing marketing consent does not affect transactional communications (e.g., deposit confirmations, withdrawal notifications, security alerts), which are sent as a necessary part of the service.

Self-excluded members are automatically removed from all marketing communications lists for the duration of their exclusion period. 77cuci does not send promotional communications to self-excluded accounts.

12. Minors

The Platform is strictly restricted to individuals aged 21 years and above. 21+ 77cuci does not knowingly collect personal data from individuals under 21 years of age. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete such data and close the associated account. Any winnings accumulated during gameplay by an underage user will not be disbursed.

If you believe that an individual under 21 has registered on the Platform, please notify us immediately at [email protected].

13. International Data Transfers

77cuci operates under international gaming authority licensing, and some of our data processors — including game providers, KYC verification services, and platform infrastructure providers — may process data in jurisdictions outside Malaysia. Where data is transferred internationally, 77cuci ensures that appropriate safeguards are in place, including contractual data protection clauses, to provide a level of protection equivalent to that required under Malaysian law.

By registering with 77cuci, you acknowledge that your personal data may be transferred to, stored in, and processed in countries outside Malaysia, subject to the safeguards described above.

14. Changes to This Policy

77cuci reserves the right to update this Privacy Policy at any time. When material changes are made, we will notify you via a notice on the Platform and, where reasonably practicable, by email to your registered address, at least 14 days before the changes take effect. Your continued use of the Platform after the effective date of any change constitutes acceptance of the revised Policy. If you do not agree with any changes, you must cease using the Platform and request account closure.

15. Contact Us

For questions, concerns, or requests regarding this Privacy Policy or 77cuci's data processing activities, please contact us via:

• Live chat support (available 24/7 on the Platform)
• Email: [email protected] (subject line: "Data Privacy Inquiry")