Privacy Policy

Introduction

This Privacy Policy ("Policy") describes how cilli88 ("we", "us", "our" or "the Website"), accessible at https://cilli88.cam, collects, uses, stores, discloses and otherwise processes personal data relating to visitors and registered users of the platform ("you" or "User").

cilli88 is an English-language information and educational platform focused on the Malaysian online casino and sports betting market. We are committed to protecting the privacy of all Users, handling personal data responsibly and complying with applicable data-protection standards.

By accessing or using any part of the cilli88 Website, you acknowledge that you have read and understood this Policy and that you consent to the data practices described herein. This Policy should be read alongside our Terms & Conditions, which govern your general use of the Website.

Definitions

The following terms carry the meanings assigned below throughout this Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, IP address, device identifiers and browsing behaviour.
• "Processing" means any operation performed on personal data, including collection, recording, storage, use, disclosure, erasure or destruction.
• "Data Controller" refers to cilli88, the entity that determines the purposes and means of processing personal data collected through this Website.
• "Data Processor" means any third-party service provider that processes personal data on behalf of and under the instruction of cilli88.
• "Cookies" means small text files placed on a User's device by a website to store session information, preferences and analytics data.
• "Third-party Operator" refers to any external casino, sportsbook, payment provider or other platform that a User may visit independently after engaging with cilli88 content.
• "Consent" means a freely given, specific, informed and unambiguous indication of the User's agreement to the processing of their personal data for a stated purpose.

Data We Collect

cilli88 operates primarily as an informational platform. The personal data we collect is limited to what is necessary for the legitimate operation of the Website and the delivery of relevant, useful content to Malaysian users. We may collect the following categories of data:

3.1 Data You Provide Directly

Where account registration, contact forms or feedback mechanisms are made available, you may voluntarily submit:

• Name or display username;
• Email address;
• Preferred language or region (e.g., Kuala Lumpur, Penang, Johor Bahru);
• Any comments or queries submitted through a support channel.

3.2 Data Collected Automatically

When you browse cilli88, our servers and analytics tools may automatically collect:

• IP address and approximate geographic location (country or state level);
• Browser type, version and operating system;
• Device type (desktop, mobile, tablet) and screen resolution;
• Pages visited, time on page and navigation path through the Website;
• Referring URL (the page that directed you to cilli88);
• Session duration and frequency of visits.

3.3 Data We Do Not Collect

Legal Basis for Processing

cilli88 processes personal data only where a legitimate legal basis exists. The applicable bases are:

• Consent: Where you have given explicit consent for a specific processing purpose — for example, subscribing to content updates or submitting a contact form. You may withdraw consent at any time without affecting the lawfulness of processing undertaken prior to withdrawal.
• Legitimate Interests: Where processing is necessary for the legitimate operational interests of cilli88, such as maintaining Website security, preventing fraudulent access and improving content quality for Malaysian users, provided those interests are not overridden by your privacy rights.
• Legal Obligation: Where processing is required to comply with applicable legal or regulatory obligations.
• Contractual Necessity: Where processing is necessary to perform a contract with you, for example fulfilling a registered account agreement.

How We Use Your Data

Personal data collected by cilli88 is used solely for the purposes described in this Policy. Specifically, we use your data to:

• Operate, maintain and improve the cilli88 Website and its content for Malaysian users;
• Respond to support queries, feedback or account-related requests submitted by Users;
• Analyse aggregate browsing behaviour to understand which guides, payment-method explainers and sports betting articles are most useful to Malaysian readers;
• Detect, investigate and prevent fraudulent, unauthorised or otherwise prohibited activity on the Website;
• Comply with applicable legal obligations or respond to lawful requests from public authorities;
• Personalise the content experience where technically possible — for example, displaying content relevant to a User's general geographic region within Malaysia (Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam).

Data Sharing & Disclosure

cilli88 does not sell, rent, trade or otherwise commercially transfer personally identifiable User data to third parties. We may share data in limited circumstances as follows:

• Service providers: Trusted technical partners engaged to support Website hosting, analytics, content delivery and security may process limited data on our behalf as Data Processors, under contractual obligations to handle data securely and only for the specific purpose authorised;
• Legal compliance: We may disclose personal data where required by law, court order, regulatory authority or government body. We will notify affected Users where legally permitted to do so;
• Business transfers: In the event of a merger, acquisition or sale of assets, User data may be transferred as part of that transaction. Users will be notified of any change in data controller before such a transfer takes effect;
• Aggregated, anonymised data: Non-identifiable, aggregated data (e.g., total page views from Kuala Lumpur, or the most-read guides per month) may be shared publicly or with content partners without restriction, as it cannot be used to identify any individual User.

cilli88 has no commercial relationship with any specific casino operator, sportsbook or payment provider referenced on the Website. Payment brands mentioned — including Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank and Hong Leong — are referenced for educational purposes only and do not receive User data from cilli88.

Cookies & Tracking Technologies

cilli88 uses cookies and similar tracking technologies to deliver a functional, consistent user experience and to analyse how Users interact with the Website. Cookies do not grant us access to your device and do not contain personal identity information unless you have voluntarily provided it in a separate context.

Types of cookies used

• Essential cookies: Required for core Website functionality, including session management, page load optimisation and security validation. These cannot be disabled without affecting Website performance.
• Analytics cookies: Used to collect aggregated, pseudonymised data on page views, traffic sources, session duration and navigation patterns. This data helps us improve content relevance for Malaysian users.
• Preference cookies: Store non-sensitive user preferences such as language settings or last-visited content categories to improve return visit experience.

cilli88 does not use third-party advertising cookies, cross-site tracking pixels or behavioural retargeting technologies that monitor User activity outside the cilli88 Website domain.

Data Retention

cilli88 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. Our general retention approach is as follows:

• Account data: Retained for the duration of an active account and for a reasonable period following account closure or deactivation to allow resolution of any outstanding queries;
• Support correspondence: Email or support ticket records are retained for a reasonable period following resolution to maintain an audit trail and assist with follow-up queries;
• Analytics and session logs: Pseudonymised analytics data is retained in aggregate form for content improvement purposes. Raw session logs containing IP addresses are not retained beyond the operational period required for security purposes;
• Legal holds: Where data must be preserved in connection with a legal obligation, regulatory investigation or dispute, it will be retained for the duration of that requirement and deleted promptly upon resolution.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction of individual User records.

Data Security

cilli88 implements reasonable and appropriate technical and organisational security measures to protect personal data against unauthorised access, accidental loss, destruction, alteration or disclosure. Measures include:

• HTTPS encryption across all Website pages to protect data in transit between User devices and our servers;
• Access controls limiting internal access to personal data on a need-to-know basis;
• Regular security reviews of Website infrastructure and data-handling procedures;
• Contractual obligations requiring third-party processors to maintain appropriate security standards.

In the event of a personal data breach that is likely to result in a high risk to User rights and freedoms, cilli88 will take prompt steps to contain the breach and notify affected Users in accordance with applicable obligations.

Your Rights

Subject to applicable law and verification of your identity, you may exercise the following rights in relation to personal data held by cilli88:

• Right of Access: You may request a copy of the personal data cilli88 holds about you, together with information about how it is being used;
• Right to Rectification: You may request correction of inaccurate or incomplete personal data;
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent and no other legal basis applies;
• Right to Restriction: You may request that processing of your data be restricted in certain circumstances — for example, while accuracy is disputed;
• Right to Object: You may object to processing based on legitimate interests, including profiling for content personalisation purposes;
• Right to Data Portability: Where processing is based on consent or contractual necessity and carried out by automated means, you may request a copy of your data in a structured, commonly used machine-readable format;
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without penalty, though withdrawal does not affect the lawfulness of processing prior to withdrawal.

Children & Minors

The cilli88 Website is strictly intended for adults aged 21 years and above. We do not knowingly collect, solicit or process personal data from individuals under the age of 21. Online casino and gambling-related content is not appropriate for minors, and access by underage individuals is prohibited.

If you are a parent or guardian and believe that your child has submitted personal data to cilli88 without your consent, please contact us immediately using the details in Section 15. Upon receiving a credible notification, we will take prompt steps to verify and, where confirmed, delete the data concerned without undue delay.

cilli88 encourages parents and guardians to utilise parental control tools and internet filtering software to prevent underage access to gambling-related websites.

Third-party Links & Services

cilli88 may reference or describe third-party platforms, payment service providers and casino operators for educational and informational purposes. This Privacy Policy applies exclusively to the cilli88 Website at https://cilli88.cam and does not extend to any external website, application or service.

When you navigate away from cilli88 to a third-party platform — whether a casino operator, sportsbook, e-wallet provider such as Touch 'n Go eWallet or GrabPay, or a financial institution such as Maybank, CIMB or Public Bank — that platform's own privacy policy and data practices govern your interaction. cilli88 has no control over, and accepts no responsibility for, the privacy practices of any third-party platform.

International Data Transfers

Where cilli88 engages service providers or infrastructure partners located outside Malaysia — for example, cloud hosting providers or content delivery network operators — personal data may be transferred to and processed in countries other than Malaysia. Such transfers will occur only where:

• The destination country provides an adequate level of data protection as recognised under applicable standards; or
• Appropriate contractual safeguards — such as standard data protection clauses — are in place between cilli88 and the receiving party; or
• The transfer is necessary for the performance of a contract or for legitimate operational purposes with appropriate protective measures applied.

cilli88 selects service providers with care and requires all processors handling User data to implement security measures consistent with the standards described in this Policy.

Policy Amendments

cilli88 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, our data-handling practices or the nature of the Website's services. Revised versions will be published on this page with an updated "Last Updated" date.

Where amendments are material — for example, changes to the categories of data collected, new disclosure arrangements or changes to User rights — cilli88 will, where practicable, provide reasonable notice before the revised Policy takes effect.

Your continued use of the cilli88 Website following publication of an amended Policy constitutes acceptance of the revised terms. We encourage you to review this page periodically to stay informed of how your data is being handled.

Contact Us

For privacy-related queries, data subject rights requests, or to report a suspected data breach or underage access concern, please contact the cilli88 privacy team through the following channel:

When submitting a privacy request, please state clearly the nature of your request (e.g., access, rectification, erasure), include the email address associated with your account if applicable, and provide sufficient detail to allow us to locate and verify your data. Do not include full MyKad numbers, passport numbers, bank account details or payment card information in any correspondence to cilli88.