100cici Privacy Policy

§1 Introduction

100cici ("we," "us," "our," or "the Company") operates an online sportsbook, live casino, slots, mix parlay, and arcade platform accessible at 100cici.net (the "Platform"). In the course of providing these Services to registered users ("Users" or "you"), we collect and process certain personal data. This Privacy Policy explains what data we collect, how we use it, who we share it with, and what rights you have in relation to it.

This Policy should be read alongside the 100cici Terms & Conditions, which govern the overall relationship between 100cici and its Users. By registering an Account or using the Platform, you confirm that you have read and understood this Privacy Policy.

§2 Data Controller

100cici is the data controller in respect of personal data collected through the Platform. As data controller, we determine the purposes and means of processing your personal data and bear primary responsibility for its lawful handling. Where we engage third-party service providers to process data on our behalf, those providers act as data processors under contractual obligations that require them to process data only on our documented instructions and to maintain appropriate security standards.

Queries regarding this Policy or your personal data may be directed to our support team via live chat or by email at: [email protected]

§3 Data We Collect

We collect personal data across three broad categories. The table below summarises the data types, their source, and the context in which they arise:

We do not collect sensitive personal data such as racial or ethnic origin, religious beliefs, political opinions, biometric data, or health data unless required by applicable law or expressly consented to by the User.

§4 How We Collect Data

Personal data is collected through the following mechanisms:

• Direct submission: Data you enter into registration forms, KYC verification screens, support chat fields, or email correspondence.
• Automated collection: Technical and usage data collected automatically when you interact with the Platform, including through cookies and server logs.
• Third-party providers: Payment processors (including Touch n Go eWallet, Boost, Maybank, CIMB, and Public Bank) may transmit confirmation data to 100cici in connection with deposit and withdrawal processing. Identity verification service providers may transmit verification outcomes during KYC checks.
• Fraud detection services: We may receive risk signals and device fingerprint data from third-party fraud prevention tools integrated into the Platform.

§5 Purposes of Processing

100cici processes personal data for the following purposes:

• Account management: Creating, maintaining, and administering User Accounts, including processing deposits, withdrawals, and bet settlements.
• Identity verification and KYC: Verifying User age (21+), identity, and payment method ownership as required by our gaming licence obligations and anti-money laundering legislation.
• Service delivery: Operating the Sportsbook, Casino, Slots, Mix Parlay, and Arcade products and providing related customer support.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, money laundering, collusion, and other prohibited conduct.
• Responsible gaming: Monitoring wagering patterns to identify potential problem gambling indicators, administering self-exclusion requests, and enforcing deposit limits.
• Legal compliance: Meeting obligations under applicable gaming licence conditions, anti-money laundering regulations, and any other mandatory legal requirements.
• Marketing communications: Sending promotional offers and platform updates to Users who have opted in to such communications. Users may opt out at any time.
• Platform improvement: Analysing aggregated, anonymised usage data to improve platform performance, game selection, and User experience.

§6 Legal Basis for Processing

We process personal data only where a valid legal basis exists. The applicable legal bases for our processing activities are as follows:

• Contractual necessity: Processing required to perform the agreement between 100cici and the User, including account management, bet processing, and withdrawal payments.
• Legal obligation: Processing required to comply with applicable laws, including KYC obligations, anti-money laundering record-keeping, and gaming licence conditions.
• Legitimate interests: Processing for fraud prevention, platform security, and aggregated analytics, where our interests are not overridden by the User's privacy rights.
• Consent: Processing for marketing communications, where the User has given explicit opt-in consent. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

§7 Data Sharing

100cici does not sell, rent, or trade personal data with third parties for their own marketing purposes. We share personal data only in the following limited circumstances:

• Payment service providers: Necessary transaction data is shared with payment processors (Touch n Go eWallet, Boost, Maybank, CIMB, Public Bank, Visa, Mastercard, cryptocurrency processors) to execute deposits and withdrawals.
• Identity verification providers: Identity documents and biometric check results are shared with third-party KYC service providers acting under data processing agreements.
• Fraud prevention services: Device and behavioural data may be shared with specialist fraud prevention providers to protect Platform integrity.
• Gaming software providers: Game session data is shared with licensed game studios (e.g. PG Soft, Pragmatic Play) to the extent necessary to operate their games within the 100cici Casino and Slots sections.
• Regulatory and law enforcement authorities: We will disclose personal data to competent authorities where required by applicable law, gaming licence conditions, or court order.
• Corporate transactions: In the event of a merger, acquisition, or sale of all or part of 100cici's business, personal data held may be transferred to the acquiring entity subject to equivalent privacy protections.

§8 International Data Transfers

100cici's Platform infrastructure and certain third-party service providers may be located outside Malaysia. Where personal data is transferred outside the jurisdiction of collection, we ensure that appropriate safeguards are in place, including:

• Contractual clauses requiring the recipient to maintain standards of data protection equivalent to those applied by 100cici.
• Use of service providers who operate under recognised international data protection frameworks or certifications.

By using the Platform, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside Malaysia in the circumstances described above.

§9 Data Retention

100cici retains personal data only for as long as necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by law. The following indicative retention periods apply:

• Account and KYC records: Retained for a minimum of five years from Account closure, as required under anti-money laundering obligations.
• Transaction and wagering records: Retained for a minimum of five years from the date of each transaction or game session.
• Support communications: Retained for three years from the date of the communication, unless the communication forms part of an ongoing dispute or regulatory inquiry.
• Marketing consent records: Retained until consent is withdrawn, plus one year thereafter for audit purposes.
• Technical logs: Retained for up to 12 months for security and fraud monitoring purposes.

On expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be linked to an identifiable individual.

§10 Cookies & Tracking Technologies

100cici uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential cookies: Required for Platform functionality, including session authentication, bet slip persistence, and security features. These cannot be disabled without impairing Platform use.
• Analytics cookies: Used to collect aggregated data on Platform usage patterns, page visit frequency, and feature engagement to support Platform improvement. Data is anonymised before analysis.
• Preference cookies: Store User-selected settings such as language preference and display options to improve the User experience across sessions.

Users may manage cookie preferences through their browser settings. Disabling non-essential cookies will not prevent access to the Platform but may affect certain preference-based features.

§11 Your Data Rights

Subject to applicable law and regulatory obligations, Users have the following rights in relation to their personal data held by 100cici:

• Right of access: You may request a copy of the personal data we hold about you.
• Right to rectification: You may request correction of inaccurate or incomplete personal data.
• 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, subject to legal retention requirements.
• Right to restriction: You may request that we restrict processing of your personal data in certain circumstances, for example while a rectification request is being assessed.
• Right to data portability: Where processing is based on consent or contractual necessity and carried out by automated means, you may request a structured copy of your data in a machine-readable format.
• Right to object: You may object to processing based on legitimate interests, including direct marketing. Objections to direct marketing will be actioned immediately.
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

To exercise any of these rights, contact the 100cici support team via live chat or email at: [email protected]. We will respond to all verified requests within 30 days. Complex requests may require a further 60-day extension, of which you will be notified.

§12 Children & Minors

The 100cici Platform is strictly for individuals aged 21 and above. We do not knowingly collect personal data from persons under 21 years of age. If we become aware that personal data has been submitted by a minor, the associated Account will be immediately suspended, any funds frozen pending investigation, and the personal data deleted to the extent permitted by applicable law. Parents or guardians who believe a minor has registered on the 100cici Platform should contact support immediately via live chat.

§13 Security Measures

100cici implements technical and organisational security measures proportionate to the risk presented by the personal data we process. These include:

• SSL/TLS encryption with a minimum 256-bit standard for all data transmitted between the User and Platform.
• Encrypted storage of sensitive personal data at rest, including identity documents and financial data.
• Role-based access controls limiting internal access to personal data to staff with a documented need to access it.
• Regular penetration testing and security audits conducted by independent third parties.
• Incident response procedures providing for prompt User notification in the event of a data breach affecting their personal data, where required by applicable law.

No data transmission over the internet can be guaranteed to be completely secure. Users are responsible for maintaining the security of their Account login credentials and should not share their password with any third party.

§14 Policy Changes

100cici reserves the right to update this Privacy Policy at any time. Where material changes are made, we will provide reasonable advance notice to affected Users via the registered Account email address or a Platform notification prior to the changes taking effect. The "Last Updated" date at the top of this Policy will be revised on each update. Continued use of the Platform following the effective date of an updated Privacy Policy constitutes acceptance of the revised terms. Users who do not accept an updated Policy should cease use of the Platform and request Account closure.

§15 Contact & Complaints

Questions, data subject requests, or complaints relating to this Privacy Policy should be directed to the 100cici support team via the Platform's live chat, available 24 hours a day, 7 days a week. Alternatively, you may write to us at: [email protected]

If you are not satisfied with our response to a complaint, you may have the right to lodge a complaint with the applicable data protection supervisory authority in your jurisdiction. 100cici will cooperate with any investigation conducted by a competent supervisory authority in connection with this Policy.