UCS9 Privacy Policy — Our Commitment to Protecting the Personal Data of Malaysian Members

1 Personal Data We Collect

1.1 Data You Provide Directly

When you register, use, or interact with the ucs9 platform, you may provide us with the following personal data directly:

• Identity Data: Full name, identification card number (MyKad/passport), date of birth, gender.
• Contact Data: Email address, mobile number, residential address in Malaysia.
• Account Data: Username, password (stored in encrypted form), account preferences.
• Financial Data: Digital payment account details (Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, FPX), deposit and withdrawal records. We do not store full credit card numbers — only secure tokens issued by payment processors.
• KYC Verification Documents: MyKad copy, proof of address, and other documents required for the KYC process.

1.2 Automatically Collected Data

When you use the ucs9 platform, our systems automatically collect the following technical data for operational and security purposes:

• Device Data: Device type, operating system, phone model, screen resolution, application version.
• Network Data: IP address, internet service provider (ISP), approximate location (state/city within Malaysia).
• Session Data: Login and logout activity, session duration, in-platform actions, and game history.
• Cookie Data: Information collected through cookies and similar tracking technologies (see Section 6).

1.3 Data from Third Parties

In certain circumstances, ucs9 may receive your personal data from legitimate third-party sources, such as identity verification service providers used in the KYC process, or payment processors in connection with your financial transactions on the platform.

2 How UCS9 Uses Your Personal Data

UCS9 uses your personal data for the following purposes, all of which are lawful and necessary for the operation of the platform:

For marketing and promotional communications, ucs9 will only contact you if you have given explicit consent during registration or subsequently through your account settings. You may withdraw this consent at any time by updating your communication preferences in your account or by contacting support@ucs9.click.

3 Legal Basis for Data Processing

In accordance with Malaysia's Personal Data Protection Act (PDPA) 2010, UCS9 processes your personal data on one or more of the following valid legal bases:

• Contractual Performance: Processing required to fulfill the agreement between you and ucs9 — such as processing deposits, paying out winnings, and providing access to games.
• Legal Obligation: Processing required to comply with applicable Malaysian laws, including anti-money laundering (AML) and KYC requirements.
• Legitimate Interests: Processing for platform security, fraud prevention, and service improvement purposes — where these interests do not override your fundamental rights and freedoms.
• Consent: For optional purposes such as marketing communications, we rely on your explicit consent, which may be withdrawn at any time.

4 Data Sharing with Third Parties

4.1 General Principles

UCS9 does not sell, rent, or disclose your personal data to any third party for their own marketing purposes. Your data is only shared in limited, lawful circumstances as outlined below.

4.2 Authorised Service Providers

UCS9 shares only the necessary personal data with the following third parties who assist us in operating the platform:

• Payment Processors: Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow, and FPX service providers — for processing your deposit and withdrawal transactions.
• KYC Provider: Third-party identity verification services used to validate the information you provide during the KYC process.
• Game Provider: Game software providers such as Pragmatic Play, PG Soft, and others may receive limited session data necessary to operate their games on the ucs9 platform.
• Cloud Services & Infrastructure: Server and technology infrastructure providers that store and process data on behalf of ucs9.

All of these third-party service providers are bound by strict confidentiality and data protection agreements with ucs9. They are permitted to use your data only for the specific purposes we designate, and for no other purpose.

4.3 Legally Required Disclosures

UCS9 may disclose your personal data to Malaysian authorities (such as the Royal Malaysia Police, Bank Negara Malaysia, or relevant tribunals) when required by law, court order, or valid legal process. In such cases, we will endeavour to notify you in advance where permitted by law.

5 Data Security Measures

UCS9 implements multiple layers of technical and organisational security measures to protect your personal data from unauthorised access, alteration, disclosure, or accidental deletion:

• 256-bit SSL Encryption: All communications between your device and ucs9 servers are encrypted using the latest TLS protocol — no data is transmitted in plain text.
• Stored Data Encryption: Sensitive data such as passwords and payment information is stored in encrypted or hashed form using robust algorithms.
• Strict Access Controls: Access to members' personal data is restricted solely to ucs9 staff who require it to carry out their service duties, based on the principle of minimum access rights.
• Threat Detection System: The ucs9 platform operates a 24-hour security monitoring system that automatically detects and blocks unauthorised access attempts.
• Two-Factor Authentication (2FA): Members can enable 2FA for an additional layer of account security, reducing the risk of unauthorised access even if a password has been compromised.
• Regular Security Audits: ucs9's security systems undergo regular audits and penetration testing conducted by independent cybersecurity experts.

While ucs9 takes all reasonable steps to protect your data, no security system can be guaranteed to be completely foolproof. In the event of a data breach affecting your personal data, ucs9 will notify you and the relevant authorities within the timeframe required under applicable Malaysian law.

6 Cookies & Tracking Technologies

6.1 What Are Cookies?

Cookies are small text files stored on your device by websites or apps you visit. The ucs9 platform uses cookies and similar tracking technologies to ensure the platform functions properly and to provide you with a better experience.

6.2 Types of Cookies Used

• Essential Cookies: These cookies are required for the ucs9 platform to function. They manage your login session, ensure account security, and enable financial transactions to be processed securely. These cookies cannot be disabled without affecting core platform functionality.
• Performance Cookies: These cookies collect information about how you use the ucs9 platform — such as pages visited and games played — to help us improve our services. Data is collected in aggregate form and does not identify you personally.
• Functional Cookies: These cookies remember your preferences — such as language, display settings, and login details — to deliver a more personalised experience.

6.3 Managing Cookie Preferences

You can manage or disable cookies through your internet browser settings. Please note that disabling certain cookies may affect the functionality of the ucs9 platform. For guidance on managing cookies in popular browsers, refer to your browser's help documentation.

7 Your Rights Under Malaysia's PDPA 2010

As a data subject under Malaysia's Personal Data Protection Act (PDPA) 2010, you have the following rights regarding the personal data we hold about you:

To exercise any of the rights above, send a written request to support@ucs9.click with the subject line "Personal Data Rights Request", along with your full name, IC number, and ucs9 account username for verification purposes. We will process your request within 14 business days upon successful identity verification.

8 Data Retention & Deletion

UCS9 retains your personal data for as long as it is needed for the purposes stated in this policy, or as required by applicable Malaysian law. Specific retention periods are as follows:

• Active Account Data: Retained for as long as your ucs9 account remains active.
• Financial Transaction Records: Retained for a minimum of 7 years from the transaction date, in line with Malaysian financial and taxation legal requirements.
• KYC Documents: Retained for a minimum of 5 years after account closure, in accordance with Malaysia's anti-money laundering (AML) requirements.
• Security Logs: Retained for 2 years for security investigation purposes if required.
• Marketing Data (with consent): Retained until you withdraw your consent.

Once the applicable retention period has expired, your personal data will be securely deleted or anonymised so that it can no longer be linked to you personally.

9 Cross-Border Data Transfers

In the course of operating the ucs9 platform, your personal data may need to be processed or stored on servers located outside Malaysia — for example, cloud infrastructure servers used by our service providers. In such cases, ucs9 ensures that any such data transfers are carried out with adequate safeguards, including:

• Data transfer agreements requiring recipients of data outside Malaysia to comply with data protection standards equivalent to Malaysia's PDPA 2010.
• Use of recognised transfer mechanisms such as standard contractual clauses or certification by an independent body.
• Risk assessment conducted prior to any new data transfer being implemented.

UCS9 does not transfer your personal data to jurisdictions that lack adequate data protection standards without appropriate additional safeguards in place.

10 Children & Underage Users

The ucs9 platform is exclusively for adults aged 18 and above. UCS9 does not knowingly collect or process the personal data of individuals under the age of 18. If you believe we may have collected a child's or minor's personal data without appropriate consent, please contact us immediately at support@ucs9.click and we will take prompt action to delete that data.

11 Amendments to the Privacy Policy

UCS9 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our privacy practices, new legal requirements, or changes to the services we offer. The last updated date at the top of this document will be revised whenever a material amendment is made.

For significant amendments that affect how we use your data, ucs9 will endeavour to notify you via an in-platform notice or email to the address registered to your account at least 14 days before the changes take effect. Your continued use of the ucs9 platform after the effective date of such amendments will be considered your acceptance of the updated Privacy Policy.

12 Contact Us — Data Privacy Enquiries

For any enquiries, concerns, or requests relating to your privacy and personal data on the ucs9 platform, you may reach us through the following channels:

• Email (Recommended for Formal Requests): support@ucs9.click — please use the subject line "Privacy Policy Inquiry" or "Personal Data Rights Request". We aim to respond within 14 business days.
• 24/7 Live Chat: For general privacy inquiries, our support team operates 24/7 in Bahasa Melayu and is ready to assist via live chat on the ucs9 platform.

If you are not satisfied with ucs9's response to your privacy inquiry after contacting us, you have the right to lodge a complaint with the Personal Data Protection Commissioner of Malaysia, appointed under PDPA 2010.