Privacy Policy

01 Introduction

This Privacy Policy ("Policy") is issued by Cill88 ("Cill88", "we", "us", "our") and applies to all personal data collected through the Cill88 online gaming platform at https://cill88.cam and any associated subdomains, mobile interfaces, and customer support channels (collectively, the "Platform").

We are committed to processing personal data in a manner that is lawful, fair, and transparent, and to implementing appropriate technical and organisational measures to protect your information from unauthorised access, disclosure, alteration, or destruction.

This Policy should be read in conjunction with our Terms & Conditions, which govern the overall use of the Platform and are incorporated herein by reference. By registering an account, depositing funds, or otherwise using the Platform, you acknowledge that you have read, understood, and agreed to the data practices described in this Policy.

02 Definitions

In this Policy, the following terms carry the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person — including but not limited to name, email address, phone number, device identifier, and financial account details.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, or deletion.
• "Data Subject" refers to you — the individual whose Personal Data is being processed.
• "Data Controller" means Cill88, which determines the purposes and means of processing your Personal Data.
• "KYC Data" means identity verification documents and information submitted for Know Your Customer compliance purposes, including copies of government-issued identification and proof of payment method ownership.
• "Cookies" means small text files placed on your device by the Platform to support functionality, analytics, and personalisation.
• "Third Party" means any entity other than Cill88 and the Data Subject, including payment processors, compliance vendors, and technology service providers.

03 Data We Collect

Cill88 collects the following categories of Personal Data in the course of operating the Platform:

We do not knowingly collect sensitive personal data categories such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where strictly required by our licensing obligations (for example, in relation to problem gambling self-identification or age verification).

04 How Data Is Collected

Personal Data is collected through the following channels:

• Direct submission: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or claiming a promotional bonus.
• Automated technical collection: Technical and Usage Data collected automatically when you access the Platform, through cookies, log files, and analytics tools.
• Payment processors: Transaction confirmation data received from Malaysian payment providers including Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, and participating banks (Maybank, CIMB Bank, Public Bank, Hong Leong Bank, RHB Bank).
• Third-party verification services: Identity and document verification services used to complete the KYC process, which may return confirmation or match-status data to Cill88.
• Fraud prevention and AML tools: Data received from risk scoring, device fingerprinting, and anti-money laundering screening services as part of our regulatory compliance obligations.

05 Purposes of Processing

Cill88 processes your Personal Data for the following specific and clearly defined purposes:

• Account creation and management: To register your account, verify your identity, and manage your player profile throughout the duration of your relationship with Cill88.
• KYC and age verification: To confirm that all players are aged 21 or above and that account details are accurate, as required by our international licensing obligations.
• Payment processing: To process deposits via DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, and bank transfers, and to facilitate withdrawals to verified accounts.
• Game delivery and platform operation: To provide access to our games library, record gaming activity for dispute resolution, and maintain platform integrity.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, collusion, bonus abuse, money laundering, and other prohibited conduct.
• Regulatory compliance: To fulfil our obligations under applicable anti-money laundering (AML) regulations, know your customer (KYC) requirements, and the conditions of our international gaming licence.
• Customer support: To respond to enquiries, resolve complaints, and provide account assistance through our live chat, WhatsApp, and email support channels.
• Responsible gambling: To administer self-exclusion requests, deposit limits, and other responsible gambling tools, and to identify patterns that may indicate problem gambling behaviour.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates where you have provided consent. You may withdraw consent at any time via your account settings or by contacting support.
• Platform analytics and improvement: To analyse usage patterns, improve platform performance, and develop new features that better serve Malaysian players.

06 Legal Basis for Processing

Cill88 processes Personal Data on the following lawful bases:

• Contractual necessity: Processing required to fulfil our obligations under the Terms & Conditions you accepted upon registration — including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable anti-money laundering laws, KYC requirements, age verification mandates, and the conditions of our international gaming licence.
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gambling monitoring, and platform improvement, where those interests are not overridden by your fundamental rights.
• Consent: For direct marketing communications and non-essential cookies, where you have provided explicit and freely given consent. Consent may be withdrawn at any time.

07 Data Sharing

Cill88 does not sell, rent, or trade Personal Data. We share data only in the following limited and controlled circumstances:

• Payment service providers: We share transaction data with licensed Malaysian payment processors — including Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, and participating banks — strictly for the purpose of processing your deposits and withdrawals.
• Identity verification and KYC vendors: We share identity document data with authorised third-party KYC verification services to confirm the authenticity of submitted documents and the identity of account holders.
• Fraud prevention and AML service providers: We share relevant data with licensed fraud detection, risk scoring, and anti-money laundering compliance vendors to satisfy our regulatory obligations.
• Technology and infrastructure providers: We engage third-party providers for cloud hosting, data storage, analytics, and platform delivery under strict data processing agreements that prohibit independent use of your data.
• Regulatory and law enforcement authorities: We may be legally required to disclose certain data to regulatory bodies, law enforcement agencies, or courts of competent jurisdiction in response to lawful requests or court orders.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of Cill88's business, your Personal Data may be transferred to the acquiring entity, subject to equivalent privacy protections.

08 Data Retention

Cill88 retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law or our licensing conditions. The following general retention periods apply:

• Account data: Retained for the duration of your active account, plus a minimum of five (5) years following account closure, to satisfy AML record-keeping obligations.
• KYC documentation: Retained for a minimum of five (5) years from the date of submission or from account closure, whichever is later, as required by anti-money laundering regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Customer support communications: Retained for two (2) years following the resolution of each support interaction.
• Marketing consent records: Retained until consent is withdrawn, plus one (1) year thereafter as evidence of consent history.
• Technical and usage data: Retained for thirteen (13) months from the date of collection in analytics systems, after which it is aggregated and anonymised.

Following the expiry of applicable retention periods, Personal Data is securely deleted or anonymised in a manner that prevents re-identification. Anonymised, aggregated data may be retained indefinitely for statistical and analytical purposes.

09 Security Measures

Cill88 implements a layered approach to data security, encompassing technical, organisational, and procedural controls. Key measures include the following:

• Transport encryption: All data transmitted between your device and our servers is encrypted using TLS 1.2 or higher with 256-bit symmetric encryption.
• Data-at-rest encryption: Personal data and KYC documents stored in our systems are encrypted at rest using industry-standard encryption protocols.
• Access controls: Access to Personal Data is restricted on a strict need-to-know basis. Role-based access controls are enforced, and all access is logged and auditable.
• Two-factor authentication: Internal staff systems handling Personal Data require multi-factor authentication for access.
• Penetration testing and vulnerability management: Regular third-party security audits and penetration tests are conducted to identify and remediate vulnerabilities.
• Incident response: Cill88 maintains a documented data breach response procedure. In the event of a breach likely to affect your rights, we will notify affected players without undue delay.

10 Cookies & Tracking Technologies

Cill88 uses cookies and similar tracking technologies on the Platform to support functionality, maintain session state, perform analytics, and, where consent has been obtained, to personalise content and advertisements.

The following categories of cookies are used:

• Strictly necessary cookies: Required for the Platform to function. These enable features such as user authentication, session management, and payment security. These cookies cannot be disabled without affecting core Platform functionality.
• Functional cookies: Remember your preferences such as language selection and display settings to improve your experience across sessions.
• Analytics cookies: Collect anonymised usage data to help us understand how players interact with the Platform and identify areas for improvement. Activated only with consent.
• Marketing cookies: Used to deliver relevant promotional content. Activated only where explicit consent has been provided and may be withdrawn at any time.

You can manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will impair your ability to use the Platform, including the ability to log in and process payments. Disabling analytics and marketing cookies will not affect core Platform functionality.

11 Your Rights

As a Data Subject, you hold the following rights in relation to your Personal Data held by Cill88. Requests should be submitted to our support team at [email protected] or via live chat. We will respond within 30 calendar days of receipt of a valid request.

12 Minors & Age Policy

The Cill88 Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect Personal Data from persons under the age of 21. If we become aware that a minor has registered an account or submitted personal data through the Platform, we will immediately:

• Suspend and close the account;
• Forfeit any associated balance;
• Permanently delete the personal data collected;
• Report the matter to relevant authorities where required by law.

If you believe that a minor may have accessed the Platform or submitted personal data without authorisation, please contact us immediately at [email protected] or via our 24/7 live chat.

13 International Data Transfers

As an internationally licensed gaming platform, Cill88 may transfer Personal Data to servers and service providers located outside of Malaysia. Where such transfers occur, we ensure that appropriate safeguards are in place, including:

• Data processing agreements with all third-party recipients that impose equivalent data protection obligations;
• Transfer to jurisdictions that provide an adequate level of data protection under applicable international standards;
• Use of standard contractual clauses or equivalent transfer mechanisms where required.

By using the Cill88 Platform, you acknowledge that your Personal Data may be transferred to and processed in countries outside Malaysia. We take all reasonable steps to ensure that such transfers are conducted securely and in accordance with this Policy.

14 Policy Changes

Cill88 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, operational requirements, or applicable law. Material changes to this Policy will be communicated to registered players via:

• An email notification to the address associated with your account; and/or
• A prominent notice on the Platform prior to the amendment taking effect.

The effective date displayed at the top of this Policy indicates the version currently in force. We recommend reviewing this Policy periodically. Continued use of the Platform following notification of any amendment constitutes your acceptance of the revised Policy.

15 Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data, please contact the Cill88 Data Protection team through the following channels:

• Live Chat: Available 24/7 directly through the Platform. Average response time under 5 minutes.
• Email: [email protected] — please include "Privacy Request" in the subject line, along with your registered username and a clear description of your request.

We aim to acknowledge all privacy-related requests within 72 hours and to resolve them within 30 calendar days. Complex requests may require an extension of up to a further 30 days, in which case we will notify you of the delay and the reason for it.

For matters relating to responsible gambling data, self-exclusion, or account restrictions, please also refer to our Responsible Gambling page for dedicated guidance and support resources.