Cikgu88 Privacy Policy

This Privacy Policy (the "Policy") is issued by Cikgu88 (referred to herein as "Cikgu88", "we", "us", or "the Company") and applies to all users of the platform accessible at cikgu88.cam (the "Platform"). It sets out in clear and accessible terms how we collect, receive, hold, use, disclose, transfer, and otherwise process your personal data in connection with your use of the Platform.

Cikgu88 is committed to the responsible stewardship of personal data. We recognise that privacy is a fundamental right and that the trust our users place in us when sharing their information is something we must honour through consistent, transparent, and lawful data practices.

This Policy applies to all individuals who access or use the Platform, including registered account holders, visitors browsing without an account, and individuals who interact with Cikgu88 through support channels. It covers personal data collected through the website, through our customer support communications, and through the payment processing interfaces connected to the Platform.

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

For the purposes of this Policy, the following terms carry the meanings defined below:

Cikgu88 collects personal data that is necessary for the operation of the Platform, the delivery of our services, and our compliance with applicable legal and regulatory obligations. The categories of personal data we collect are set out in the table below:

4.1 Data You Provide Directly

We collect personal data that you actively provide to us through the following interactions:

• Completing the account registration form on the Platform
• Submitting KYC verification documents through the account verification portal
• Making a deposit or requesting a withdrawal through the cashier interface
• Contacting our customer support team via live chat or email
• Opting into promotional communications or completing preference surveys
• Participating in promotions, tournaments, or VIP programme activities

4.2 Data Collected Automatically

When you access the Platform, certain technical and usage data is collected automatically through the use of cookies, web beacons, server logs, and similar tracking technologies. This includes your IP address, device identifiers, browsing behaviour on the Platform, and game session data. Please refer to Section 10 (Cookies & Tracking) for further details.

4.3 Data from Third Parties

We may receive personal data about you from third parties in the following circumstances:

• Payment processors: Transaction confirmation data, payment instrument verification status, and fraud risk signals from providers such as Touch 'n Go, DuitNow, FPX partner banks (Maybank, CIMB, Public Bank, RHB, Hong Leong), and cryptocurrency networks
• Identity verification services: Confirmation of document authenticity and identity match from third-party KYC verification platforms
• Fraud and AML screening tools: Risk scores and watchlist status from compliance screening providers
• Self-exclusion registries: Exclusion status from responsible gambling self-exclusion databases to which Cikgu88 subscribes

Cikgu88 processes personal data only for specific, explicit, and legitimate purposes. The principal purposes for which we process your data are as follows:

• Account creation and management: To register your account, maintain it accurately, and enable you to access Platform services
• Identity verification (KYC): To verify your age (21+), identity, and address in compliance with our licensing obligations and anti-money laundering frameworks
• Payment processing: To process deposits received via Malaysian payment methods (Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, direct bank transfer) and to execute withdrawal requests to your verified payment instruments
• Fraud prevention and platform security: To detect, investigate, and prevent fraudulent activity, multi-accounting, collusion, money laundering, and other prohibited conduct
• Regulatory compliance: To fulfil our obligations under our international gaming licence, including record-keeping, audit requirements, and reporting obligations
• Responsible gambling monitoring: To identify patterns of play that may indicate problem gambling and to administer self-exclusion and deposit limit tools in accordance with our Responsible Gambling Policy
• Customer support: To respond to and resolve your queries, complaints, and feedback through live chat and email support channels
• Service improvement: To analyse usage patterns, optimise Platform performance, and develop new features based on aggregate, anonymised usage data
• Marketing communications: To send you promotional offers, bonus notifications, and updates about the Platform — only where you have provided explicit consent and subject to your right to withdraw that consent at any time
• Legal proceedings: To establish, exercise, or defend legal claims in the event of a dispute

Each processing activity carried out by Cikgu88 is conducted on one or more of the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — specifically the Terms & Conditions you accept upon registration — including account management, payment processing, and service delivery
• Legal obligation: Processing required to comply with our obligations under applicable laws and our international gaming licence, including KYC verification, AML record-keeping, and age enforcement
• Legitimate interests: Processing for purposes of fraud prevention, Platform security, service improvement, and responsible gambling monitoring, where our legitimate interests in conducting these activities are not overridden by your privacy rights
• Consent: Processing for direct marketing communications and the use of non-essential cookies, where you have provided explicit and informed consent. You may withdraw your consent at any time without detriment to your account
• Vital interests: In exceptional circumstances, processing necessary to protect the vital interests of a data subject or another person

Cikgu88 does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. We share your personal data only in the following circumstances:

7.1 Service Providers

We engage trusted third-party service providers to assist in operating the Platform. These providers may access your personal data solely to perform services on our behalf and are contractually prohibited from using it for any other purpose. Categories of service providers include:

• Payment processing partners (e-wallet operators, FPX banking partners, cryptocurrency infrastructure providers)
• Identity verification and KYC platform providers
• Cloud hosting and data infrastructure providers
• Customer support technology platforms (live chat software)
• Anti-fraud and AML compliance screening services
• Email delivery and communication services

7.2 Regulatory and Legal Disclosure

We may disclose personal data to regulatory authorities, law enforcement agencies, or courts where we are legally required to do so under applicable laws, court orders, or our licensing authority's instructions. Such disclosures will be made strictly to the extent required by law.

7.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of all or part of Cikgu88's assets, personal data held by us may be transferred to the successor entity. We will notify affected users of any such transfer in advance where practicable, and we will ensure that the receiving entity is bound by data protection obligations at least as stringent as those set out in this Policy.

Cikgu88 retains personal data only for as long as is necessary for the purposes for which it was collected and to comply with our legal and regulatory obligations. The following general retention guidelines apply:

• Account and KYC data: Retained for the duration of your account's active status and for a minimum of five (5) years following permanent account closure, in accordance with anti-money laundering record-keeping requirements
• Transaction and financial records: Retained for a minimum of five (5) years from the date of each transaction to comply with financial crime prevention obligations
• Support communications: Retained for three (3) years from the date of the last communication, or longer where relevant to an unresolved dispute or legal claim
• Marketing consent records: Retained for the duration of your subscription to marketing communications and for two (2) years after consent withdrawal, as evidence of consent management
• Technical and usage logs: Retained for up to twelve (12) months in standard form; aggregated and anonymised data may be retained indefinitely for analytics purposes

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification. Where deletion is not technically immediately practicable, data will be isolated from further processing until it can be securely destroyed.

Cikgu88 implements a layered suite of technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration, and unlawful disclosure. These measures include:

• Encryption in transit: All data transmitted between your browser and the Platform is encrypted using TLS 1.2 or higher (HTTPS). The presence of a padlock icon in your browser address bar confirms that your connection is secured.
• Encryption at rest: Sensitive personal data — including KYC documents and financial details — is encrypted at rest using AES-256 or equivalent encryption standards
• Access controls: Access to personal data within Cikgu88's systems is restricted on a strict need-to-know basis, with role-based access controls and multi-factor authentication required for privileged system access
• Intrusion detection and monitoring: Continuous monitoring systems are in place to detect and respond to anomalous access patterns, potential breaches, and denial-of-service attempts
• Third-party security assessments: Our hosting and infrastructure providers undergo independent security audits and maintain relevant security certifications
• Staff training: All personnel with access to personal data receive regular data protection training and are bound by confidentiality obligations

In the event of a personal data breach that poses a material risk to the rights of affected users, Cikgu88 will notify affected individuals without undue delay and will take all reasonable steps to mitigate the impact of the breach.

The Cikgu88 Platform uses cookies and similar tracking technologies to facilitate essential platform functionality, enhance user experience, and — where you have consented — to support analytics and personalisation activities.

10.1 Types of Cookies We Use

• Strictly necessary cookies: Required for the Platform to function correctly, including session management, authentication state, and security features. These cookies cannot be disabled without materially affecting your ability to use the Platform.
• Performance and analytics cookies: Used to collect aggregated information about how users interact with the Platform — pages visited, time spent, errors encountered — to help us improve platform performance. These require your consent.
• Functional cookies: Used to remember your preferences such as language settings, game favourites, and display options to provide a more personalised experience.
• Security and fraud prevention cookies: Used to identify unusual or suspicious access patterns that may indicate fraudulent activity or account compromise attempts.

10.2 Managing Cookies

You can control non-essential cookies through your browser settings. Most modern browsers allow you to block, delete, or receive alerts about cookies. Note that disabling certain cookies may affect the functionality of some Platform features. Instructions for managing cookies in common browsers are available in your browser's help documentation.

Cikgu88 does not use third-party advertising cookies or cross-site tracking cookies for the purpose of serving targeted advertisements on external websites.

As an internationally licensed online gaming platform serving users in Malaysia, some personal data processed by Cikgu88 may be transferred to, stored in, or processed in jurisdictions outside Malaysia. Such transfers may occur when our cloud infrastructure, KYC verification partners, or other service providers are located in other countries.

Where personal data is transferred internationally, Cikgu88 takes appropriate steps to ensure that the transfer is conducted lawfully and that the receiving jurisdiction or organisation provides an adequate level of protection for that data. These steps may include:

• Transferring data only to recipients located in jurisdictions with recognised data protection frameworks
• Implementing standard contractual clauses or equivalent data transfer agreements with service providers located in third countries
• Conducting due diligence on the data protection practices of international service providers before engaging their services

By using the Platform, you acknowledge and consent to the transfer of your personal data across international borders as described in this section, subject to the safeguards outlined above.

Subject to applicable law, you have the following rights in relation to your personal data held by Cikgu88. To exercise any of these rights, please contact us using the details provided in Section 15.

The Cikgu88 Platform is not directed at, nor intended for use by, persons under the age of 21. We do not knowingly collect personal data from individuals under 21 years of age. Age verification is a mandatory component of our KYC process and is enforced strictly.

Where we discover or have reason to believe that an account has been registered by a person under the age of 21, we will immediately suspend the account, delete or isolate the personal data collected, and void any transactions or winnings associated with that account. Any deposited funds will be returned to the verified payment source where technically possible.

Cikgu88 reserves the right to amend this Privacy Policy at any time to reflect changes in our data processing activities, applicable legal requirements, or operational practices. The "Last Updated" date at the top of this Policy will be revised whenever material changes are made.

Where changes are material — for example, where we introduce a new category of data processing, a new purpose, or a new type of third-party sharing — we will notify registered users by email prior to the changes taking effect and will provide a reasonable opportunity for users to review the updated Policy before it applies to them.

For non-material changes — such as clarifications of existing language, correction of typographical errors, or updates to contact information — the revised Policy will take effect upon publication without specific notification. Your continued use of the Platform following any amendment constitutes your acknowledgement of the updated Policy.

We encourage you to review this Privacy Policy periodically. A current copy will always be accessible on the Platform at cikgu88.cam/privacy-policy.

For any questions, concerns, or requests relating to this Privacy Policy or to the personal data Cikgu88 holds about you — including requests to exercise your data subject rights — please contact our Privacy and Data team through the following channels:

• Email: support@cikgu88.cam  (plain text — not a clickable link)
• Live Chat: Available on the Platform 24 hours a day, 7 days a week
• Subject Line for Privacy Requests: Please use "Privacy Request — [Your Username]" to ensure prompt routing to the appropriate team
• Response Timeframe: Privacy queries are acknowledged within 48 hours; substantive responses within 30 calendar days

When submitting a data subject rights request, please include your registered username, the email address associated with your account, and a description of your request. We may need to verify your identity before processing certain types of requests to protect your data from unauthorised disclosure.