Privacy Policy

1. Introduction

This Privacy Policy (hereinafter "the Policy" or "this Policy") is issued by 12cuc (hereinafter "12cuc", "the Company", "we", "us", or "our"), the operator of the online sports betting and live casino platform accessible at https://12cuc.cam (the "Platform").

This Policy describes how 12cuc collects, uses, stores, shares, and protects the personal data of individuals ("Users", "Players", or "you") who register an account on the Platform, access any of our services, interact with our customer support team, or visit our website.

12cuc operates under an internationally recognised gaming licence and is committed to handling personal data in a responsible, transparent, and lawful manner. We have designed our data practices to align with internationally recognised data protection standards, including principles of lawfulness, fairness, transparency, data minimisation, accuracy, storage limitation, integrity, and confidentiality.

This Policy should be read in conjunction with 12cuc's Terms and Conditions and Responsible Gambling Policy, which together form the complete framework governing your use of the Platform.

2. Definitions

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" means any information that relates to an identified or identifiable natural person — including name, identification number, contact details, location data, financial information, or any combination of information that can reasonably be used to identify an individual.
• "Processing" means any operation or set of operations performed on Personal Data, whether automated or not — including collection, recording, storage, adaptation, retrieval, use, disclosure, transfer, restriction, erasure, or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this context, 12cuc.
• "Data Processor" means any third party that processes Personal Data on behalf of and under instruction from the Data Controller.
• "Consent" means a freely given, specific, informed, and unambiguous indication of a data subject's agreement to the processing of their personal data for a stated purpose.
• "KYC" means Know Your Customer — the identity and document verification process required under12cuc's gaming licence and applicable anti-money laundering obligations.
• "Cookies" means small text files placed on your device by the Platform to facilitate functionality, session management, and analytics.
• "Account" means a registered User account on the 12cuc Platform.

3. Data Controller

12cuc acts as the Data Controller in respect of all Personal Data collected through the Platform and associated customer interactions. As Data Controller, 12cuc determines the purposes for which Personal Data is processed and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

Where 12cuc engages third-party service providers to process Personal Data on its behalf — such as KYC verification providers, payment processing partners, and fraud detection services — those providers act as Data Processors and are bound by contractual data processing agreements that restrict their use of your data to the specific purposes authorised by 12cuc.

For any privacy-related enquiries or to exercise your data subject rights, please contact us using the details provided in Section 16 of this Policy.

4. Personal Data We Collect

12cuc collects the following categories of Personal Data from Users of the Platform:

4.1 Registration Data

When you create an Account, we collect: your full legal name, date of birth, email address, phone number, and Malaysian residential address. This information is required to create and administer your Account in accordance with our licensing obligations.

4.2 Identity Verification (KYC) Data

To comply with our gaming licence requirements and anti-money laundering obligations, we collect copies of government-issued identity documents (Malaysian MyKad, Driver's Licence, or Passport), proof of address documents (utility bills or bank statements), and selfie photographs taken for identity verification purposes.

4.3 Financial Data

We collect transaction records including deposit amounts, withdrawal requests, payment method details (e.g., the last four digits of a bank account or partial e-wallet account identifier), and transaction timestamps. Full payment credentials such as complete bank account numbers or card numbers are not stored on 12cuc's systems — they are processed directly by our regulated payment partners.

4.4 Betting and Gaming Activity Data

We record all bets placed, sports markets wagered on, casino games played, betting history, win/loss outcomes, bonus usage, and VIP programme activity. This data is used to operate the Platform, calculate payouts, detect suspicious patterns, and administer promotional offers.

4.5 Technical and Device Data

When you access the Platform, we automatically collect IP address, device type and model, operating system and version, browser type and version, screen resolution, session timestamps, pages visited, clickstream data, and referring URLs. This data is used to optimise Platform performance, detect fraud, and troubleshoot technical issues.

4.6 Communications Data

We retain records of communications between you and 12cuc's customer support team, including live chat transcripts, email correspondence, and any complaint submissions. These records are retained for quality assurance, dispute resolution, and regulatory compliance purposes.

5. How Personal Data Is Collected

12cuc collects Personal Data through the following channels:

• Directly from you — when you register an Account, submit KYC documents, make deposits or withdrawal requests, contact our support team, or participate in promotions.
• Automatically through the Platform — via cookies, server logs, and technical tracking as described in Section 12 of this Policy.
• From third-party verification providers — KYC verification partners and fraud detection services may provide supplementary verification data as part of the identity check process.
• From payment service providers — when you make a deposit via Touch'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong, or a cryptocurrency wallet, relevant transaction metadata is shared with us by the payment provider to confirm transaction status.

6. Data Processing Purposes

12cuc processes your Personal Data for the following specific, documented purposes:

7. Legal Basis for Processing

12cuc processes your Personal Data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and 12cuc (i.e., to operate your Account, process transactions, administer bets, and deliver the services described in our Terms and Conditions).
• Legal Obligation: Processing is required to comply with 12cuc's obligations under its gaming licence, anti-money laundering regulations, and applicable financial crime prevention frameworks — including mandatory KYC verification and transaction monitoring.
• Legitimate Interests: Processing is necessary for12cuc's legitimate business interests, including fraud prevention, platform security, responsible gambling monitoring, and Platform improvement — provided such interests are not overridden by your rights and interests.
• Consent: Where we send marketing communications or use non-essential cookies, we do so only on the basis of your freely given, specific consent. You may withdraw your consent at any time by contacting our support team or updating your Account communication preferences.

8. Third-Party Data Sharing

12cuc does not sell, rent, or trade your Personal Data to third parties for commercial purposes. We may share your data with the following categories of third parties, strictly on a need-to-know basis and under appropriate data protection safeguards:

• KYC and Identity Verification Providers: Third-party services that assist in verifying the identity, age, and address of Account registrants as required by our licensing obligations.
• Payment Processing Partners: Malaysian e-wallet operators (including Touch 'n Go eWallet, Boost, GrabPay), bank transfer platforms (DuitNow, FPX), and major Malaysian commercial banks (Maybank, CIMB, Public Bank, Hong Leong) as necessary to process your deposit and withdrawal transactions.
• Fraud Prevention and AML Services: Specialist providers that assist in identifying and preventing fraudulent activity, money laundering, and other financial crimes, as required under our licence obligations.
• Gaming Software Providers: Providers of live casino games, slot games, and sports data feeds may receive limited account or session data necessary to deliver their services within the Platform.
• Regulatory and Licensing Authorities: 12cuc's gaming regulator and licensing authority may request access to certain account or transaction data as part of regulatory audits, investigations, or periodic compliance reviews.
• Law Enforcement and Legal Process: Where required by a court order, subpoena, regulatory directive, or applicable law, 12cuc may be required to disclose Personal Data to law enforcement agencies or other competent authorities.

9. International Data Transfers

12cuc operates under an international gaming licence and uses technology infrastructure that may involve the transfer or storage of Personal Data in jurisdictions outside Malaysia. Where such transfers occur, 12cuc ensures that appropriate safeguards are in place to protect your Personal Data to a standard equivalent to that applied within Malaysia.

Safeguards for international transfers may include:

• Standard contractual clauses incorporated into data processing agreements with international service providers.
• Transfers only to jurisdictions that provide an adequate level of data protection assessed by 12cuc's compliance team.
• Pseudonymisation or encryption of transferred data where technically feasible.

By using the 12cuc Platform, you acknowledge and agree that your Personal Data may be transferred to and processed in jurisdictions outside Malaysia, subject to the safeguards described above.

10. Data Retention

12cuc retains Personal Data for no longer than is necessary for the purpose for which it was collected, subject to the following retention guidelines:

• Active Account Data: Retained for the duration of your Account's active status and for a period of five (5) years following permanent account closure, in accordance with gaming licence record-keeping requirements.
• KYC Documents: Retained for a minimum of five (5) years from the date of verification, or longer where required by anti-money laundering regulations applicable in the governing jurisdiction.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in accordance with financial crime prevention obligations.
• Customer Support Communications: Retained for two (2) years from the date of the last communication, or longer where a dispute remains unresolved or subject to ongoing investigation.
• Technical Logs: IP address logs and session data are typically retained for ninety (90) days for security and fraud investigation purposes, after which they are anonymised or deleted.
• Marketing Consent Records: Retained for as long as you remain a Platform User, plus two (2) years following account closure, to demonstrate consent history in the event of a complaint.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in manner that prevents re-identification.

11. Your Data Rights

As a User of the 12cuc Platform, you have the following rights in relation to your Personal Data. To exercise any of these rights, please contact our support team using the details in Section 16. We will acknowledge your request within 5 business days and provide a substantive response within 30 calendar days.

12. Cookies & Tracking Technologies

12cuc uses cookies and similar tracking technologies to operate the Platform, maintain your logged-in session, and collect analytics data. The following categories of cookies may be set when you access the Platform:

• Strictly Necessary Cookies: Essential for the operation of the Platform — including session authentication, security tokens, and load balancing. These cannot be disabled without impairing Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, odds format, and layout choices to improve your experience on the Platform.
• Analytics Cookies: Collect anonymous, aggregated data about how Users navigate the Platform — including pages visited, time spent on page, and click paths. Used to improve Platform design and performance.
• Marketing and Preference Cookies: Used to deliver relevant promotional communications based on your betting preferences and Platform activity, where you have provided consent.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect your ability to use some Platform features. Where consent is required for non-essential cookies, we will request it prior to setting those cookies.

13. Data Security

12cuc implements and maintains appropriate technical and organisational measures to protect your Personal Data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security programme includes:

• 256-bit SSL/TLS encryption for all data in transit between your device and 12cuc's servers.
• At-rest encryption for stored sensitive data, including KYC documents and financial transaction records.
• Role-based access controls limiting employee access to Personal Data strictly on a need-to-know basis.
• Regular penetration testing and third-party security audits of Platform infrastructure.
• Multi-factor authentication requirements for internal system access by12cuc staff.
• Incident response procedures for identifying, containing, and notifying affected parties in the event of a data security breach.

In the event of a data breach that is likely to result in a risk to your rights and freedoms, 12cuc will notify affected Users as soon as reasonably practicable and will report the incident to the relevant regulatory authority as required by applicable law.

14. Minors & Age Restriction

The 12cuc Platform is strictly available to individuals aged 21 years and above. 12cuc does not knowingly collect or process Personal Data from persons under the age of 21.

As part of our account registration and KYC verification process, all Users are required to confirm their date of birth and submit government-issued identity documentation that confirms they meet the 21-year minimum age requirement. Accounts found to belong to persons under 21 will be immediately closed, KYC documents securely deleted, and any deposited funds returned to the originating payment source.

If 12cuc becomes aware that it has inadvertently collected Personal Data from a person under the age of 21, that data will be immediately deleted and the account suspended pending investigation. If you are a parent or guardian who believes a minor has created an account on the Platform, please contact our support team immediately.

15. Changes to This Privacy Policy

12cuc may update or revise this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or Platform functionality. The current version of this Policy — including its effective date — will always be accessible athttps://12cuc.cam/privacy-policy.

Where changes are material — for example, introducing new categories of data collection or new purposes for processing — 12cuc will notify you in advance via the Platform's in-account notification system and/or by email to your registered address, allowing you a reasonable period to review the changes before they take effect.

Your continued use of the Platform following the effective date of any amended Privacy Policy constitutes your acknowledgement of the changes and your agreement to be bound by the revised Policy. If you do not agree to the revised Policy, you should close your Account prior to the effective date of the change.

16. Contact Us

For any privacy-related enquiries, to exercise your data subject rights, or to submit a complaint about our data practices, please contact 12cuc's support team using the following details:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line (for privacy requests): "Privacy Request – [Your Account Username]"
• Live Chat: Available 24/7 via the Platform
• Response Time: Acknowledgement within 5 business days; substantive response within 30 calendar days

We are committed to resolving all privacy-related concerns through our internal process. If you are not satisfied with our response, you may escalate your complaint to the relevant data protection authority or gaming regulator in the jurisdiction governing your Account.