Privacy Policy — leci123

1. Introduction

This Privacy Policy (the "Policy") is issued by leci123 (hereinafter "leci123", "we", "us", or "the Company"), the operator of the online sports betting and gaming platform accessible at https://leci123.cam (the "Platform"). This Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by leci123.

leci123 is committed to processing personal data in a manner that is lawful, fair, transparent, and consistent with the principles of data protection applicable to the jurisdictions in which we operate. We recognise that players across Malaysia — from Kuala Lumpur to Penang, Johor Bahru to Petaling Jaya — entrust us with sensitive personal and financial information, and we take that responsibility seriously.

This Policy applies to all personal data processed in connection with your use of the Platform, including data collected during account registration, deposits and withdrawals via Malaysian payment channels (including Touch 'n Go eWallet, Boost, DuitNow, FPX, Maybank2u, and CIMB Clicks), customer support interactions, KYC verification, promotional participation, and general platform use.

2. Definitions

For the purposes of this Privacy Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, identification number, contact details, financial information, and online identifiers.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, alteration, and deletion.
• "Data Controller" means the entity that determines the purposes and means of Processing Personal Data — in this context, leci123.
• "Data Processor" means any third party that Processes Personal Data on behalf of leci123 in accordance with our documented instructions.
• "Data Subject" means the individual to whom Personal Data relates — in this context, you as a registered or prospective user of the Platform.
• "KYC" means Know Your Customer — the identity verification process used to confirm a player's identity, age, and payment method ownership.
• "Cookies" means small text files stored on your device by the Platform to facilitate functionality, analytics, and session management.
• "Sensitive Personal Data" means a subset of Personal Data that warrants enhanced protection, including identity document numbers, biometric data, and financial account information.

3. Personal Data We Collect

leci123 collects the following categories of personal data, depending on the nature of your interaction with the Platform:

3.1 Registration & Account Data

• Full legal name as it appears on your identification document
• Date of birth (to verify the 21+ age requirement)
• Residential address (street, city, postcode, country)
• Email address (primary contact and notification channel)
• Mobile phone number
• Username and encrypted account password
• Preferred currency (MYR for Malaysian players)

3.2 Identity Verification (KYC) Data

• Scanned copy or clear photograph of MyKad (NRIC), Passport, or Driver's License
• Proof of residential address (utility bill, bank statement dated within 3 months)
• Selfie photograph holding a valid identity document
• Proof of payment method ownership (e-wallet or bank account statement)

3.3 Financial & Transaction Data

• Deposit and withdrawal transaction records including amounts (in MYR), timestamps, and payment method identifiers
• Partial payment method details (masked account numbers, e-wallet registered name)
• Betting and gaming activity history, including wager amounts, outcomes, and game types
• Account balance history and bonus credit/debit records

3.4 Technical & Usage Data

• IP address and approximate geolocation derived from IP
• Browser type, version, and operating system
• Device type (desktop, mobile, tablet) and device identifiers
• Pages visited, session duration, and clickstream data
• Login timestamps and session activity logs

3.5 Communication Data

• Content of live chat conversations and email correspondence with our support team
• Customer feedback, complaint records, and dispute correspondence
• Marketing preference selections (opt-in or opt-out records)

4. How We Collect Personal Data

leci123 collects personal data through the following channels:

• Direct submission: Data you provide during registration, KYC verification, deposit/withdrawal processes, or when contacting customer support
• Automated collection: Technical data collected automatically via Cookies, server logs, and tracking technologies as you interact with the Platform
• Third-party payment processors: Transaction data received from Malaysian payment intermediaries including Touch 'n Go eWallet, Boost, GrabPay, DuitNow, and FPX network participants, limited to what is necessary for payment processing and fraud prevention
• Identity verification providers: Data returned from third-party KYC verification services engaged to confirm the authenticity of identity documents
• Fraud and AML screening services: Risk signals and identity flags from anti-money laundering and fraud detection service providers

5. How We Use Your Personal Data (Data Processing)

leci123 processes your Personal Data for the following specific purposes:

6. Legal Basis for Processing

leci123 processes personal data on the following legal bases:

• Performance of a contract: Processing necessary to provide you with the leci123 platform services, including account management, payment processing, and bet settlement
• Legal obligation: Processing required to comply with applicable regulations, including anti-money laundering requirements, age verification obligations, and regulatory reporting duties
• Legitimate interests: Processing necessary for our legitimate business interests, including fraud prevention, platform security, responsible gambling monitoring, and business analytics — provided such interests are not overridden by your privacy rights
• Consent: Processing based on your freely given, specific, and informed consent — applicable to marketing communications and certain non-essential Cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing

7. Data Sharing & Third-Party Disclosure

leci123 does not sell, rent, or trade your Personal Data to third parties for their independent marketing purposes under any circumstances. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

7.1 Payment Service Providers

Processing your deposits and withdrawals via Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank2u, CIMB Clicks, Public Bank, Hong Leong Connect, and USDT TRC20 requires sharing minimum necessary data with the relevant payment gateway or financial institution. This is limited to the information required to execute the transaction and perform transaction-level fraud checks.

7.2 Identity Verification & KYC Partners

We engage accredited third-party identity verification services to authenticate documents submitted during the KYC process. These partners act as Data Processors under contract and are not permitted to use your data for any purpose beyond the specific verification service.

7.3 Fraud Prevention & AML Services

Certain account and transaction data is shared with fraud detection and anti-money laundering screening providers to fulfil our regulatory obligations and protect the integrity of the Platform.

7.4 Regulatory & Law Enforcement Authorities

leci123 may disclose Personal Data to competent regulatory authorities, law enforcement agencies, or courts where required by applicable law, regulation, or a valid legal order. Such disclosures will be made in a manner consistent with our legal obligations.

7.5 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of assets, your Personal Data may be transferred to the relevant successor entity, subject to that entity providing equivalent data protection commitments to those set out in this Policy. You will be notified of any such transfer.

8. Data Retention

leci123 retains Personal Data only for as long as is necessary for the purposes for which it was collected, taking into account applicable legal retention obligations. Our standard retention periods are as follows:

• Active account data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, to meet anti-money laundering and regulatory record-keeping requirements
• KYC and identity verification data: Retained for a minimum of five (5) years from the date of collection or last use, in accordance with applicable AML regulations
• Transaction and financial records: Retained for a minimum of five (5) years from the date of each transaction
• Customer support records: Retained for three (3) years from the date of the interaction
• Marketing consent records: Retained for the duration of the consent and for one (1) year following withdrawal of consent, as evidence of compliance
• Cookie and technical usage data: Retained for up to thirteen (13) months, consistent with standard analytics retention practices

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

9. Data Security Measures

leci123 implements a comprehensive suite of technical and organisational security measures to protect your Personal Data against unauthorised access, loss, destruction, alteration, or disclosure. Key measures include:

• End-to-end 256-bit TLS encryption for all data transmitted between your browser and our servers
• Encrypted storage of Sensitive Personal Data at rest using AES-256 or equivalent standards
• Strict role-based access controls and least-privilege access policies for all internal systems
• Multi-factor authentication (MFA) required for all personnel accessing production systems
• Regular penetration testing and vulnerability assessments by independent security professionals
• Comprehensive audit logging of all access to Personal Data and Account records
• Dedicated incident response procedures with defined escalation timelines for any data security events

While leci123 takes all reasonable steps to safeguard your data, no internet-based system can guarantee absolute security. You are also responsible for maintaining the security of your own Account credentials and for notifying us immediately at [email protected] if you suspect any unauthorised access to your Account.

10. Cookies & Tracking Technologies

leci123 uses Cookies and similar tracking technologies to operate the Platform, maintain your session, and improve your user experience. Cookies are small text files stored on your device when you visit the Platform.

10.1 Categories of Cookies Used

• Strictly Necessary Cookies: Essential to the operation of the Platform — these enable core functions such as secure login, session management, and fraud prevention. These Cookies cannot be disabled without impairing Platform functionality
• Performance & Analytics Cookies: Collect anonymous aggregate data about how visitors use the Platform — page views, session lengths, and navigation paths — to help us improve performance and user experience
• Functionality Cookies: Remember your preferences such as language selection and display settings to personalise your experience on return visits
• Targeting / Marketing Cookies: Used only with your explicit consent to serve relevant promotional content to returning visitors. You may opt out of these at any time

10.2 Cookie Management

You may control your Cookie preferences through the Cookie consent banner displayed on your first visit to the Platform, or by adjusting your browser settings to block or delete Cookies. Please note that disabling Strictly Necessary Cookies will prevent you from logging in to or using the Platform. Detailed information about Cookie management in common browsers is available through each browser's help documentation.

11. Your Data Protection Rights

As a Data Subject, you hold the following rights with respect to the Personal Data that leci123 processes about you. Requests to exercise any of these rights should be submitted to [email protected]. leci123 will respond within a reasonable timeframe, and in any event within thirty (30) calendar days of receipt of a valid request.

• Right of Access: You have the right to request a copy of the Personal Data we hold about you and to receive information about how it is processed
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete Personal Data we hold about you
• Right to Erasure ("Right to Be Forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations
• Right to Restriction of Processing: You may request that we restrict the processing of your Personal Data in certain circumstances — for example, while a dispute about its accuracy is being resolved
• Right to Data Portability: You have the right to receive a machine-readable copy of the Personal Data you have provided to us, and to request that it be transmitted to another data controller where technically feasible
• Right to Object: You have the right to object to processing of your Personal Data based on our legitimate interests, including profiling for marketing purposes. You may also withdraw marketing consent at any time
• Right not to be subject to automated decision-making: You have the right not to be subject to decisions made solely on the basis of automated processing — including profiling — that produce legal or similarly significant effects, without human review

12. Minors — Persons Under 21

The leci123 Platform is strictly intended for use by persons aged 21 years and above only. leci123 does not knowingly collect, process, or store Personal Data relating to persons below the age of 21. If we become aware that Personal Data has been submitted by a person under the minimum age, we will immediately suspend the relevant Account and delete all associated data without retention.

If you have reason to believe that a person under the age of 21 has registered on the Platform or provided their personal information, please contact us immediately at [email protected]. Parents and guardians are encouraged to use internet filtering tools and parental control software to prevent minors from accessing gambling platforms.

13. Cross-Border Data Transfers

leci123 operates as an international platform, and your Personal Data may be processed by our systems or service providers located outside Malaysia. Where such cross-border transfers occur, leci123 takes appropriate safeguards to ensure that your Personal Data receives a level of protection consistent with this Policy and applicable data protection standards, including through the use of:

• Standard contractual clauses approved by relevant data protection authorities
• Data processing agreements containing binding obligations on recipient parties
• Transfer only to service providers that implement equivalent or superior technical and organisational security measures

leci123 does not transfer Personal Data to jurisdictions that do not provide an adequate level of data protection without the safeguards described above.

14. Amendments to This Privacy Policy

leci123 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in applicable law, regulatory guidance, our data processing activities, or Platform functionality. The most current version of this Policy will always be accessible at https://leci123.cam/privacy-policy, and the effective date at the top of this document will be updated accordingly.

Where amendments are material — that is, where they significantly affect your rights or our data processing activities — leci123 will provide advance notice via a prominent banner on the Platform or by email to your registered address, providing not less than seven (7) days' notice where practicable. Your continued use of the Platform following the effective date of any amendment constitutes your acknowledgement of the revised Policy.

15. Contact Us — Data & Privacy Queries

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data by leci123, please contact us through the following channels:

• Email: [email protected] — mark the subject line as "Privacy / Data Request" for faster routing
• Live Chat: Available 24 hours a day, 7 days a week — directly on the leci123 Platform — average response under 2 minutes
• Response Timeline: We acknowledge all privacy-related contacts within 2 business days and provide a substantive response within 30 calendar days

For formal data subject rights requests (access, erasure, portability), please include your registered Account username and a brief description of your request to facilitate prompt handling.