100cic Privacy Policy for Malaysian Users

1. Definitions

In this Privacy Policy the following terms have the meanings set out below:

• "100cic" means the website and associated services operated under that brand name.
• "Personal Data" means any information that identifies or can reasonably identify a living individual, including name, date of birth, contact details, financial information and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, transmission, alteration and deletion.
• "User" means any individual who accesses 100cic, whether or not a registered account holder.
• "MYR Transaction" means any deposit, withdrawal or transfer denominated in Malaysian Ringgit using an eligible payment method.

2. Personal Data We Collect

100cic may collect personal data through account registration, payment processing, voluntary communications, technical signals and verification procedures. The categories below describe the types of information that may be involved.

Payment method names such as Maybank2u, CIMB Clicks, Public Bank Online, Hong Leong Connect, Touch 'n Go eWallet, Boost, GrabPay, DuitNow and FPX are referenced factually. 100cic does not store full card or banking passwords. Users must never share one-time verification codes or passwords in support messages.

3. Lawful Basis for Data Processing

100cic processes personal data only where a lawful basis applies. The primary bases used are:

• Contractual necessity — processing required to fulfil account, payment or service obligations arising from your use of 100cic.
• Legal obligation — processing required to comply with applicable law, including anti-money-laundering and age-verification requirements.
• Legitimate interests — processing for fraud prevention, security monitoring, responsible gambling controls and service improvements, where those interests are not overridden by individual rights.
• Consent — processing for specific optional communications where consent has been freely and clearly given and can be withdrawn at any time.

4. How Personal Data Is Used

Personal data collected by 100cic may be used for the following purposes:

• Creating and managing registered accounts for eligible Malaysian users;
• Verifying identity, age (21+) and payment method ownership as part of the KYC process;
• Processing MYR deposits and withdrawals through supported payment providers;
• Monitoring account activity to detect fraud, money laundering or security risks;
• Administering promotions, VIP tiers and loyalty programmes subject to applicable terms;
• Providing customer support and resolving account or transaction disputes;
• Enforcing self-exclusion, deposit limit or responsible gambling controls;
• Maintaining transaction and communication records as required by applicable law; and
• Improving content, payment guidance and educational information on the 100cic platform.

5. Sharing and Disclosure of Personal Data

100cic does not sell personal data to third parties. Personal data may be shared with the categories of recipient described below, where this is necessary and proportionate:

• Payment processors and banking partners — to facilitate MYR deposits and withdrawals through Maybank2u, CIMB Clicks, Public Bank Online, Hong Leong Connect, Touch 'n Go eWallet, Boost, GrabPay, DuitNow or FPX;
• Identity and age verification services — to confirm eligibility under applicable 21+ requirements;
• Fraud prevention and security services — to identify unusual activity and protect user accounts;
• Regulatory and legal authorities — where disclosure is required by a valid legal process, court order or applicable law; and
• Professional advisers — such as auditors or legal counsel, where engaged and subject to confidentiality obligations.

Any third party that receives personal data from 100cic is required to process it only for the stated purpose and in accordance with appropriate security standards.

6. Data Retention

Personal data is retained for as long as an account is active and for a reasonable period afterwards to handle outstanding transactions, disputes, legal claims or regulatory enquiries. Financial and identity records may be retained for extended periods where required by applicable anti-money-laundering or licensing rules.

After the applicable retention period, data will be deleted or anonymised in a manner that reasonably prevents further identification. Anonymised or aggregated data may be retained for legitimate analytical purposes without time limit because it no longer constitutes personal data.

7. Cookies and Tracking Technologies

100cic may use cookies and similar technologies to maintain session state, remember user preferences and analyse how the platform is used. The categories below describe the types of technology that may be deployed:

• Strictly necessary cookies — required for the website to function correctly, including login session management and security controls. These cannot be disabled.
• Functional cookies — used to remember language, currency (MYR) and display preferences between visits.
• Analytical cookies — used to understand page performance and user journey patterns at an aggregate level. No personal betting or financial activity is included in analytical reports.

Most browsers allow cookie settings to be adjusted or all cookies to be blocked. Blocking strictly necessary cookies may prevent some 100cic features from operating correctly.

8. Security Measures

100cic implements technical and organisational measures to protect personal data against unauthorised access, loss, alteration or disclosure. These measures include:

• Encrypted data transmission using current industry-standard protocols;
• Access controls limiting internal access to personal data on a need-to-know basis;
• Regular review of security configurations and data handling procedures; and
• Incident response procedures to identify, contain and report data security events.

No online system can guarantee absolute security. Users must protect their own passwords and must not share one-time codes. If you suspect that your 100cic account has been accessed without authorisation, contact support immediately using the plain-text address shown at the end of this policy.

9. Your Rights as a User

Subject to applicable law and verification of your identity, you may exercise the following rights in relation to personal data held by 100cic:

• Access — request a description of the personal data we hold about you and the purposes for which it is processed;
• Correction — request that inaccurate or incomplete personal data is corrected;
• Deletion — request deletion of personal data where it is no longer necessary for the original purpose and no overriding legal obligation requires retention;
• Restriction — request that processing be restricted in certain defined circumstances while a query is being resolved; and
• Withdrawal of consent — where processing is based solely on consent, withdraw that consent at any time, without affecting the lawfulness of processing carried out before withdrawal.

Requests will be assessed and responded to within a reasonable period. Some requests may be declined where processing is required to fulfil a legal obligation or to protect the legitimate interests of 100cic or other users.

10. Protection of Minors

100cic is intended solely for adults aged 21 and above. We do not knowingly collect or process personal data belonging to individuals under 21. If you believe that a person under 21 has submitted personal data to 100cic, please contact us using the details below and we will take prompt action to review and remove that information.

Age verification is part of the account registration and KYC process. Where age cannot be confirmed, access to account-based services will be withheld until verification is complete.

11. Changes to This Privacy Policy

100cic may update this Privacy Policy to reflect changes in services, technology, applicable law or internal data practices. Material changes will be communicated through an appropriate notice on the website or through the registered account. Continued use of 100cic after notification of a change constitutes acceptance of the updated policy.

We recommend reviewing this page periodically. The most current version always governs the processing of personal data on 100cic.

12. Contact Us

If you have questions about this Privacy Policy, wish to exercise a data right or want to report a privacy concern, please contact the 100cic support team. When making a request about your personal data, include your registered username or the email address on the account so that we can locate the relevant records.

Do not include your password, full payment credentials or one-time security codes in any support message. The 100cic contact email address is displayed below as plain text: [email protected].