cicakwin Privacy Policy

Introduction

cicakwin ("cicakwin", "we", "us", "our") operates the online gaming and sports betting information platform accessible at https://cicakwin.cam (the "Platform"). This Privacy Policy describes how cicakwin collects, uses, stores, discloses and protects personal data provided by users ("you", "User", "Member") of the Platform.

cicakwin is committed to handling personal data responsibly and in accordance with applicable data protection principles. This Policy applies to all personal data processed in connection with your use of the Platform, including data collected during registration, account management, financial transactions, customer support interactions and general browsing activity.

By accessing or using the cicakwin Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this Policy, please discontinue use of the Platform and contact us to arrange for the closure and deletion of any Account you may hold.

This Privacy Policy should be read alongside our Terms & Conditions and Responsible Gambling policy, both of which are incorporated by reference.

Definitions

The following definitions apply throughout this Privacy Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, identification number, contact details, financial information and online identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, erasure or destruction.
• "Data Controller" means cicakwin, the entity that determines the purposes and means of Processing Personal Data collected via the Platform.
• "Data Processor" means any third party that Processes Personal Data on behalf of cicakwin pursuant to a written agreement and cicakwin's instructions.
• "Consent" means a freely given, specific, informed and unambiguous indication of agreement to the Processing of Personal Data for one or more stated purposes.
• "Cookies" means small text files placed on your device by the Platform to enable certain functionality and collect usage data.
• "KYC Data" means identity and address verification documents submitted by a User in fulfilment of Know Your Customer obligations, including copies of government-issued identification and proof of address.
• "Malaysian Personal Data Protection Act" or "PDPA" refers to the Personal Data Protection Act 2010 (Malaysia) and any subordinate legislation made under it.

Data We Collect

cicakwin collects the following categories of Personal Data, depending on how you interact with the Platform:

How We Collect Your Data

cicakwin collects Personal Data through the following methods:

• Direct provision: Data you actively submit via registration forms, KYC document uploads, deposit and withdrawal requests, customer support channels and feedback forms.
• Automated collection: Technical and Usage Data collected automatically through server logs, analytics tools and Cookie technologies when you browse or interact with the Platform.
• Third-party sources: Data received from payment processors (e.g., FPX gateway providers, e-wallet operators such as Touch 'n Go and GrabPay), identity verification service providers and fraud prevention partners in the course of processing transactions or verifying accounts.
• Publicly available sources: In limited circumstances, cicakwin may verify information against publicly accessible records for fraud prevention or compliance purposes.

Legal Basis for Processing

cicakwin processes Personal Data on one or more of the following legal bases, depending on the specific Processing activity:

• Contractual necessity: Processing required to fulfil our contractual obligations to you under the cicakwin Terms & Conditions, including account management, transaction processing and service delivery.
• Legal obligation: Processing necessary to comply with applicable laws, regulations, court orders or regulatory requirements, including anti-money laundering (AML), counter-terrorism financing (CTF) and KYC obligations.
• Legitimate interests: Processing necessary for cicakwin's legitimate interests, including fraud prevention, Platform security, business analytics and service improvement, provided such interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing based on your freely given consent, such as the use of non-essential Cookies or the delivery of optional promotional communications. You may withdraw consent at any time without affecting the lawfulness of prior Processing.

How We Use Your Data

cicakwin uses the Personal Data we collect for the following purposes:

• Creating and managing your cicakwin Account, including authentication and account recovery;
• Processing MYR deposits and withdrawals through your chosen Malaysian payment method;
• Conducting identity and age verification (21+ requirement) and ongoing KYC compliance checks;
• Detecting, investigating and preventing fraudulent activity, money laundering, bonus abuse and other prohibited conduct;
• Providing customer support, responding to enquiries and resolving disputes;
• Personalising your Platform experience based on your usage preferences and betting history;
• Administering and awarding bonuses, promotions and loyalty incentives in accordance with applicable terms;
• Conducting Platform analytics to understand usage patterns and improve the cicakwin experience;
• Sending transactional communications such as deposit confirmations, withdrawal notifications and security alerts;
• Sending promotional communications where you have provided consent or where permitted under applicable law, with an opt-out mechanism provided in every such communication;
• Complying with applicable legal, regulatory and reporting obligations.

Data Sharing and Disclosure

cicakwin does not sell, rent or trade your Personal Data to third-party marketers. We may share your data in the following limited circumstances:

• Payment processors and e-wallet operators: To process MYR transactions via FPX, DuitNow, Touch 'n Go eWallet, Boost, GrabPay and bank partners including Maybank, CIMB, Public Bank and Hong Leong. Each processor is bound by contractual data protection obligations.
• Identity verification providers: Third-party KYC and AML service providers engaged to verify the identity and age of registered Users.
• IT and hosting infrastructure: Cloud storage and server hosting providers who process data on our behalf under strict data processing agreements.
• Fraud prevention services: Risk management and fraud detection partners that help cicakwin protect the Platform and its users from financial crime.
• Legal and regulatory authorities: Where required by applicable law, court order or regulatory directive, cicakwin may disclose Personal Data to competent authorities, including Malaysian regulatory bodies and law enforcement agencies.
• Business transfers: In the event of a merger, acquisition or sale of assets, Personal Data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

Cookies and Tracking Technologies

cicakwin uses Cookies and similar tracking technologies to enhance your experience on the Platform. Cookies serve the following functions:

• Strictly necessary cookies: Required for the Platform to function correctly, including session management, authentication and security features. These cannot be disabled without impairing Platform functionality.
• Functional cookies: Retain your preferences such as language selection, preferred payment method and session settings to provide a more personalised experience.
• Analytics cookies: Collect aggregated, anonymised data about how visitors interact with the Platform to help cicakwin understand usage patterns and improve features.
• Marketing cookies: Used where you have provided consent, to deliver relevant content and measure the effectiveness of cicakwin's communications. You may withdraw consent at any time.

You may manage your Cookie preferences through your browser settings. Note that disabling certain Cookies may affect Platform functionality. For a full list of Cookies in use, please contact cicakwin support using the details in Section 15.

Data Security

cicakwin implements appropriate technical and organisational security measures to protect Personal Data against unauthorised access, accidental loss, alteration, disclosure or destruction. Our security measures include, but are not limited to:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and cicakwin servers;
• Encrypted storage of sensitive Personal Data and KYC documents at rest;
• Role-based access controls limiting internal access to Personal Data on a strict need-to-know basis;
• Regular security assessments, vulnerability testing and patch management;
• Staff training on data protection obligations and information security best practices;
• Incident response procedures to detect, contain and notify data security incidents in a timely manner.

While cicakwin takes data security seriously, no method of electronic transmission or storage is entirely immune from risk. You are responsible for maintaining the confidentiality of your cicakwin Account login credentials and must notify us immediately if you suspect unauthorised access to your Account.

Data Retention

cicakwin retains Personal Data for as long as is necessary to fulfil the purposes set out in this Privacy Policy, comply with legal and regulatory obligations, resolve disputes and enforce our agreements. General retention periods are as follows:

• Account and identity data: Retained for the duration of your Account membership and for a minimum of five years following Account closure, in compliance with AML and KYC regulatory requirements.
• Financial transaction records: Retained for a minimum of seven years from the date of each transaction, in accordance with applicable financial record-keeping obligations.
• Customer support communications: Retained for three years from the date of last contact, unless a longer period is required to resolve an ongoing dispute or legal matter.
• Technical and usage data: Typically retained for a period of 24 months in identifiable form, after which it may be aggregated and anonymised for analytical purposes.
• KYC documents: Retained for at least five years following the conclusion of the relevant business relationship, unless a longer retention period is mandated by law.

Upon the expiry of the applicable retention period, Personal Data will be securely deleted or irreversibly anonymised.

Your Rights

Subject to applicable law and certain exceptions (such as where compliance with legal obligations requires retention of data), you hold the following rights in respect of your Personal Data held by cicakwin:

To exercise any of the above rights, please contact cicakwin using the details provided in Section 15. We will respond to all verifiable requests within 30 days. cicakwin may require you to verify your identity before processing a data rights request.

Third-Party Services

The cicakwin Platform integrates with third-party services in order to deliver certain features, including payment processing, identity verification and analytics. These third parties operate under their own privacy policies and data handling practices. cicakwin is not responsible for the privacy practices of third-party providers; however, we only engage providers that offer adequate data protection guarantees and with whom cicakwin maintains a formal data processing agreement.

cicakwin does not incorporate third-party advertising networks or social media tracking pixels that would transmit your Personal Data to social platforms without your knowledge. The Platform does not contain links to external websites, and no third-party content is served from outside the cicakwin infrastructure without appropriate security review.

Children's Privacy

The cicakwin Platform is strictly for adults aged 21 years and above. cicakwin does not knowingly collect, store or process Personal Data from any person under the age of 21. If cicakwin becomes aware that a registered User is under the age of 21, the relevant Account will be closed immediately and any Personal Data associated with that Account will be deleted in accordance with applicable law.

If you believe that a person under 21 has registered an Account or submitted Personal Data to cicakwin, please notify us immediately using the contact details in Section 15 so that appropriate action can be taken without delay.

Amendments to This Privacy Policy

cicakwin reserves the right to update, modify or replace this Privacy Policy at any time. Where a material change is made to the way in which cicakwin processes Personal Data, registered Members will be notified via the email address associated with their Account, or by means of a prominent notice on the Platform, at least 14 days prior to the change taking effect.

The "Last Reviewed" date displayed at the top of this page indicates when the most recent revision was made. We encourage you to review this Privacy Policy periodically. Continued use of the cicakwin Platform following the effective date of any amendment constitutes your acknowledgement of the revised Privacy Policy.

Where an amendment requires your fresh consent (for example, where a new Processing purpose is introduced that was not covered by your original consent), cicakwin will seek that consent separately before commencing the new Processing activity.

Contact Us

If you have any questions, concerns or requests in relation to this Privacy Policy or the way in which cicakwin processes your Personal Data, please contact our Data Protection team using the details below. All communications should be directed to our support team by email, and we will endeavour to respond within 30 days of receipt.