sinicuci Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is issued by sinicuci ("sinicuci", "we", "us", or "our"), the operator of the online gaming platform accessible at sinicuci.lat. The Policy governs how we collect, process, store, and protect personal data provided by or generated from users ("you", "your") who access or use our website, mobile applications, or any related services (collectively, the "Platform").

By registering an account, accessing the Platform, or otherwise engaging with sinicuci's services, you acknowledge that you have read and understood this Policy and consent to the practices described herein. If you do not agree with any part of this Policy, you should discontinue use of the Platform immediately.

We may update this Policy from time to time to reflect changes in our practices, technology, or legal obligations. Where material changes are made, we will notify registered users by email or through a prominent notice on the Platform prior to the change taking effect.

2. Information We Collect

sinicuci collects personal data through several channels. The categories of information we may collect include:

2.1 Registration & Account Data

When you create an account on sinicuci, we collect information you provide directly, including your full legal name, date of birth (for age verification — you must be 21 or older to register), email address, mobile phone number, preferred currency (Malaysian Ringgit, MYR), and account login credentials.

2.2 Identity Verification (KYC) Data

To comply with anti-money laundering (AML) regulations and our licensing obligations, sinicuci is required to verify the identity of account holders. This process — commonly referred to as Know Your Customer, or KYC — may require you to submit copies of your:

• National identity card (MyKad) or passport
• Recent utility bill or bank statement as proof of address
• Selfie photograph or live facial recognition scan
• Source-of-funds documentation, where applicable

KYC documents are handled with the highest level of confidentiality and are processed only for verification purposes.

2.3 Financial Transaction Data

When you make deposits or withdrawals, sinicuci records transaction details including the amount, currency, payment method (e.g. Touch 'n Go eWallet, Boost, Maybank, CIMB, Public Bank, or bank transfer), timestamps, and reference numbers. We do not store full payment card numbers on our servers; card data is handled by our PCI-DSS compliant payment processors.

2.4 Gameplay & Betting Activity

We record your betting history, game participation, session duration, wagered amounts, wins and losses, and promotional offer redemptions. This data is used for account management, dispute resolution, responsible gaming monitoring, and regulatory reporting.

2.5 Technical & Device Data

When you access the Platform, our servers automatically collect technical information such as your IP address, browser type and version, operating system, device identifier, screen resolution, referring URL, and pages visited. This data is collected via server logs and, where applicable, through cookies and similar tracking technologies.

2.6 Communications Data

If you contact our customer support team — by email, live chat, or any other channel — we retain records of those communications, including your messages, our responses, and any attachments. This helps us resolve disputes, improve our service, and maintain an audit trail.

3. How We Use Your Data

sinicuci processes your personal data only for legitimate purposes. The primary bases for processing include contractual necessity, legal obligation, legitimate interests, and (where required) your explicit consent. Specific purposes include:

• Account creation and management — to set up, authenticate, and maintain your sinicuci account.
• Identity and age verification — to confirm you are 21 or older and to satisfy KYC requirements.
• Payment processing — to facilitate deposits, withdrawals, and refunds in MYR and other supported currencies.
• Service delivery — to provide access to sports betting, casino games, slots, live dealer tables, crash games, mix parlay, and other platform features.
• Personalisation — to customise your experience, including game recommendations and relevant promotional offers where you have opted in to marketing communications.
• Responsible gaming — to monitor for signs of problematic gambling behaviour and, where necessary, to apply deposit limits, cooling-off periods, or self-exclusion measures.
• Fraud prevention and security — to detect, investigate, and prevent fraudulent transactions, account compromise, and other illegal activities.
• Legal and regulatory compliance — to meet our obligations under applicable AML, KYC, and data-protection laws, and to respond to lawful requests from authorities.
• Analytics and platform improvement — to understand usage patterns, diagnose technical issues, and improve the overall quality of the sinicuci experience.
• Customer support — to respond to your enquiries, resolve disputes, and provide assistance via our 24/7 support team.

We do not use automated decision-making or profiling in ways that produce legal orsignificantly affect you without human review. If you have concerns about any decision made in relation to your account, you may contact our support team to request a manual review.

4. Disclosure to Third Parties

sinicuci does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may, however, share your data with carefully selected third parties where necessary to operate the Platform or comply with legal obligations. These include:

4.1 Payment Service Providers

To process your deposits and withdrawals, we share necessary transaction data with our licensed payment partners, including providers of Touch 'n Go eWallet, Boost, and local Malaysian bank transfer services such as Maybank, CIMB, and Public Bank. These providers are bound by their own data-protection obligations and are contractually prohibited from using your data for any purpose other than payment processing.

4.2 Identity Verification Partners

We engage accredited third-party KYC and AML screening services to verify your identity and screen against sanctions and watchlists. These providers process your identity documents solely for verification purposes and may not retain or repurpose your data beyond the scope of that engagement.

4.3 Technology and Hosting Providers

sinicuci uses cloud infrastructure, content delivery networks, and software-as-a-service tools to operate the Platform. Our technology partners may have incidental access to personal data as part of their services. All such partners are bound by data-processing agreements that require them to handle your data securely and only on our documented instructions.

4.4 Game Content Providers

Certain games on the sinicuci Platform are provided by third-party game studios and aggregators. In some cases, these providers may receive pseudonymised session data (such as a player token or session ID) to deliver gameplay. They do not receive your full name, contact details, or financial information unless strictly necessary and contractually governed.

4.5 Legal and Regulatory Authorities

We will disclose personal data to government bodies, law enforcement agencies, courts, or regulators where we are legally required to do so, or where we believe in good faith that disclosure is necessary to prevent fraud, protect rights, or comply with a valid legal process. Where permitted, we will notify you of such disclosures.

4.6 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of sinicuci or its assets, your personal data may be transferred to the successor entity. We will provide notice of any such transaction and the privacy choices available to you before your data is transferred and becomes subject to a different privacy policy.

5. Cookies & Tracking Technologies

sinicuci uses cookies and similar tracking technologies — including web beacons, pixel tags, and local storage — to operate the Platform effectively, remember your preferences, and understand how users interact with our services. A "cookie" is a small text file placed on your device when you visit a website.

5.1 Types of Cookies We Use

• Strictly Necessary Cookies — Required for the Platform to function. These include session authentication cookies that keep you logged in to your sinicuci account. They cannot be disabled without breaking core functionality.
• Performance & Analytics Cookies — Help us understand how users navigate the Platform, which pages are visited most frequently, and where errors occur. Data collected is aggregated and anonymised where possible.
• Functionality Cookies — Remember your preferences such as language, preferred sports markets, and display settings so you do not need to re-enter them on each visit.
• Responsible Gaming Cookies — Track session duration and betting patterns locally to support our responsible gaming tools, including session time reminders and reality checks.

5.2 Managing Cookies

You can control or delete cookies through your browser settings. Disabling strictly necessary cookies will prevent you from logging in to sinicuci. All other cookie categories can be managed without affecting your ability to access the Platform, though some features may work less smoothly. Our cookie consent banner allows you to customise your preferences on first visit and at any time thereafter via the cookie settings link in the footer area.

6. Data Retention

sinicuci retains personal data only for as long as necessary to fulfil the purposes outlined in this Policy or as required by applicable law. Retention periods vary by data category:

• Account data — Retained for the duration of your account and for a minimum of five (5) years after account closure, in line with standard AML record-keeping requirements.
• KYC documents — Retained for a minimum of five (5) years from the date of collection or from the date of your last transaction, whichever is later.
• Transaction records — Retained for a minimum of seven (7) years to satisfy financial record-keeping obligations.
• Support communications — Retained for three (3) years from the date of last correspondence, unless a dispute or legal matter requires longer retention.
• Technical logs — Typically retained for ninety (90) days for security monitoring and diagnostic purposes, after which they are deleted or anonymised.

Where your data is no longer required, we will securely delete or anonymise it so that it can no longer be associated with you as an individual.

7. Security Measures

Protecting your personal data is a core operational priority at sinicuci. We implement a layered security framework designed to guard against unauthorised access, alteration, disclosure, or destruction of your information. Key measures include:

• Transport Layer Security (TLS 1.2 or higher) for all data transmitted between your device and our servers
• AES-256 encryption for sensitive data stored at rest
• Multi-factor authentication (MFA) available for all account holders
• Role-based access controls limiting internal staff access to personal data on a strict need-to-know basis
• Regular penetration testing and vulnerability assessments conducted by independent security professionals
• 24/7 automated monitoring for suspicious login activity, unusual transaction patterns, and potential account compromise
• Segregated environments for production and development systems, ensuring test data is never derived from live player records

Despite these measures, no system connected to the internet can be guaranteed to be completely secure. We strongly encourage you to use a strong, unique password for your sinicuci account, enable MFA, and notify our support team immediately if you suspect any unauthorised access to your account.

8. Your Rights

As a user of the sinicuci Platform, you have a number of rights with respect to your personal data. We are committed to honouring these rights in a timely and transparent manner. Your rights include:

8.1 Right of Access

You may request a copy of the personal data sinicuci holds about you, together with information about how and why it is being processed. We will provide this within thirty (30) calendar days of receiving a valid request.

8.2 Right to Rectification

If any personal data we hold about you is inaccurate or incomplete, you have the right to ask us to correct it. You can update certain details directly via your account settings; for other corrections, please contact our support team.

8.3 Right to Erasure

You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent (where consent is the legal basis for processing). Please note that we may be required to retain certain data under AML, KYC, and financial record-keeping laws even after your account is closed.

8.4 Right to Restrict Processing

In certain circumstances, you may ask us to pause processing of your personal data — for example, while you contest the accuracy of the data or the legitimacy of our processing.

8.5 Right to Data Portability

Where processing is based on your consent or a contract with you, and where technically feasible, you may request a copy of your personal data in a structured, commonly used, machine-readable format.

8.6 Right to Object

You may object to processing based on legitimate interests where you believe your own interests or fundamental rights override ours. You also have an absolute right to object to your data being used for direct marketing purposes.

8.7 Withdrawing Consent

Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of these rights, please contact us at [email protected] (plain text — not a clickable link). We may need to verify your identity before processing your request. We will respond within thirty (30) calendar days and will notify you if an extension is required.

9. Minors & Age Restriction

The sinicuci Platform is strictly intended for adults. You must be at least 21 years of age to register an account and participate in any real-money gaming activity. This age threshold reflects the responsible gaming standards we uphold and is consistent with the gambling age restriction applicable to casino-style gaming in Malaysia.

We do not knowingly collect personal data from individuals under the age of 21. During the registration process, we require you to confirm your date of birth, and we conduct KYC verification to validate this declaration. If we discover that a registered user is under the minimum age, we will immediately suspend the account, withhold any winnings derived from underage play in accordance with our Terms & Conditions, and delete the personal data collected, subject to any legal obligations to retain evidence of the breach.

If you are a parent or guardian and believe your child has registered on sinicuci, please contact us at [email protected] immediately. For more information on protecting young people from online gambling, please visit our Responsible Gaming page.

10. Policy Changes

sinicuci reserves the right to amend this Privacy Policy at any time. When we do so, we will update the "Effective Date" and "Last Reviewed" fields at the top of this page. Where changes are material — meaning they significantly affect your rights or how we use your data — we will provide at least fourteen (14) days' advance notice to registered users via the email address associated with your account.

Your continued use of the Platform after any updated Policy takes effect constitutes your acceptance of the revised terms. If you do not agree with the changes, you should cease using the Platform and may request account closure by contacting our support team.

We encourage you to review this Policy periodically to stay informed about how sinicuci is protecting your information. Archived versions of previous policies are available on request.

11. Contact & Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or about how sinicuci handles your personal data, please contact our Data Protection team:

We take all privacy complaints seriously and will investigate your concern thoroughly. If you are not satisfied with our response, you may have the right to lodge a complaint with the relevant data-protection authority in your jurisdiction.

For matters relating to responsible gaming rather than data privacy, please see our dedicated Responsible Gaming page, which covers self-exclusion tools, deposit limits, reality checks, and links to support organisations available to Malaysian players.