Privacy Policy — How cuan14 Protects Your Data

The following terms, when used in this Privacy Policy, carry the meanings set out below:

• "cuan14", "we", "us", or "our" refers to the cuan14 Platform and its operating entity, accessible at https://cuan14.app.
• "Platform" means the cuan14 website, member dashboard, mobile-optimized site, and all associated sub-pages and services available at https://cuan14.app.
• "Player" or "you" means any individual who visits, registers on, or uses the cuan14 Platform.
• "Personal Data" means any information that identifies or could reasonably be used to identify a living individual, including name, date of birth, contact details, financial information, device identifiers, and behavioral data.
• "Processing" means any operation performed on Personal Data — including collection, storage, use, disclosure, transfer, and deletion.
• "KYC" means Know Your Customer — the identity and document verification process required by cuan14 before processing withdrawal requests or as otherwise required for compliance purposes.
• "Cookies" means small text files stored on your device by your browser at the instruction of a website, used to maintain session state, remember preferences, and support analytics.
• "Third-Party Service Providers" means external companies engaged by cuan14 under contractual data-processing agreements to support specific operational functions, including payment processing, identity verification, fraud detection, and platform analytics.

cuan14 is the data controller responsible for Personal Data collected through the Platform. As data controller, cuan14 determines the purposes and means of processing your Personal Data in accordance with this Privacy Policy and applicable data protection law.

For all privacy-related queries, data subject requests, or concerns regarding cuan14's data practices, you may contact our dedicated Privacy Team using the details in Section 15 of this Policy. We aim to respond to all privacy inquiries within 5 business days and to formally resolve data subject requests within 30 calendar days.

cuan14 collects Personal Data through several channels, including account registration forms, KYC submissions, payment transactions, platform usage, and customer support interactions. The categories of data we collect are set out in the table below.

cuan14 processes your Personal Data only for the specific, legitimate purposes set out below. We do not use your data for purposes that are incompatible with those listed here without first obtaining your explicit consent.

• Account management: To create, maintain, and administer your cuan14 Account, including verifying your identity, processing login requests, and enabling access to Platform features.
• Payment processing: To process deposits and withdrawals in Indonesian Rupiah (IDR) via local bank transfers (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja), and to maintain accurate transaction records.
• KYC and compliance: To verify your identity, confirm your age (21+ requirement), and satisfy our obligations under applicable anti-money laundering (AML) and counter-terrorism financing (CTF) frameworks.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, bonus abuse, collusion, and other prohibited conduct as described in our Terms & Conditions.
• Platform improvement: To analyze aggregate usage patterns, identify technical issues, optimize game and page performance, and develop new features that improve the player experience on cuan14.
• Customer support: To respond to your queries, resolve disputes, process complaints, and communicate account-related updates effectively.
• Responsible Gaming: To monitor account activity for signs of problem gambling behavior, facilitate self-exclusion requests, and enforce deposit and loss limits activated by you via the member dashboard.
• Marketing communications: To send you promotional offers, bonus notifications, and news about cuan14 features — but only where you have given explicit consent, and always with a clear opt-out mechanism. See Section 13 for full details.
• Legal obligations: To comply with lawful requests from regulatory bodies, courts, or law enforcement authorities, and to enforce our Terms & Conditions where necessary.

cuan14 processes your Personal Data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and cuan14 — including account creation, payment processing, and service delivery — is carried out on the basis that it is necessary for the performance of that contract.
• Legitimate interests: cuan14 processes certain data — such as Technical Data and Usage Data — on the basis of our legitimate interests in operating a secure, fair, and commercially viable platform, provided those interests are not overridden by your fundamental rights and freedoms.
• Legal obligation: Processing necessary to comply with applicable law, including KYC/AML obligations, is carried out on the basis that it is required by law.
• Consent: Processing for marketing communications and non-essential cookies is carried out only on the basis of your freely given, specific, and informed consent, which you may withdraw at any time without affecting the lawfulness of prior processing.

cuan14 does not sell, rent, or trade your Personal Data to any third party for their independent commercial use. We share your data only in the following limited circumstances, and only with parties who are contractually bound to maintain appropriate data protection standards:

• Payment processors: Local Indonesian bank APIs and e-wallet platforms (OVO, DANA, GoPay, ShopeePay, LinkAja) receive the minimum transaction data necessary to execute your deposit or withdrawal request.
• KYC and identity verification providers: Third-party identity verification services receive copies of your KYC documents and biometric verification data solely for the purpose of confirming your identity and age.
• Fraud and risk management providers: Specialist fraud-detection platforms receive Technical Data and Transaction Data to identify and prevent fraudulent activity on the Platform.
• Game content providers: Licensed game studios (including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft) may receive a pseudonymous player identifier and session data to operate their game engines and maintain fair-play records.
• Platform analytics providers: Aggregate and anonymized Usage Data may be shared with analytics providers to support Platform optimization. No personally identifiable information is included in these analytics data flows.
• Legal and regulatory authorities: cuan14 will disclose Personal Data to courts, law enforcement agencies, or regulatory bodies when required to do so by law, court order, or regulatory directive — including responding to lawful requests made in connection with investigations into financial crime or illegal activity.
• Corporate transactions: In the event of a merger, acquisition, or sale of all or part of cuan14's business, your Personal Data may be transferred to the acquiring entity as part of the transaction, subject to the same privacy protections described in this Policy.

cuan14 uses cookies and similar tracking technologies on the Platform. The following table describes the categories of cookies we deploy, their purposes, and their retention periods.

cuan14 does not deploy third-party behavioral advertising cookies, social media tracking pixels, or retargeting technologies. You will never see cuan14 advertisements on third-party websites as a result of cookies placed by our Platform.

You may manage or disable non-essential cookies at any time through your browser settings. Please note that disabling strictly necessary cookies will impair your ability to log in to and use the cuan14 Platform. Browser-level cookie controls are available in your browser's privacy or settings menu — refer to your browser's official documentation for instructions.

cuan14 retains your Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention schedule applies:

• Account and identity data: Retained for the duration of your active Account plus a minimum of 5 years following account closure, to satisfy our AML/KYC legal obligations.
• Transaction and financial data: Retained for a minimum of 7 years following each transaction, consistent with standard financial record-keeping requirements.
• KYC documents: Retained securely for the life of the Account plus 5 years. Documents are stored in encrypted form and access is restricted to authorized compliance personnel.
• Communication data (support chat, emails): Retained for 3 years following the close of each support interaction, to allow for dispute resolution and quality assurance.
• Technical and usage data: Retained for up to 24 months in aggregate anonymized form for platform analytics. Raw device and IP log data is retained for up to 6 months for security purposes.
• Marketing consent records: Retained for the duration of your Account plus 3 years, to demonstrate consent compliance in the event of a regulatory inquiry.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymized. Where deletion is technically complex (e.g., data embedded in backup archives), we ensure that such data is protected from further active processing until it is deleted as part of routine backup rotation cycles.

cuan14 implements a layered security architecture to protect your Personal Data against unauthorized access, disclosure, alteration, and destruction. Our security measures include, but are not limited to:

• Transport encryption: All data in transit between your browser or app and cuan14's servers is encrypted using TLS 1.2 or higher (256-bit SSL). Our domains are HSTS-enforced to prevent protocol downgrade attacks.
• Encryption at rest: Sensitive stored data — including KYC documents, financial records, and account credentials — is encrypted at rest using AES-256.
• Access controls: Access to production systems and Personal Data is restricted to authorized cuan14 personnel on a strict need-to-know basis, enforced through role-based access control (RBAC) and multi-factor authentication (MFA).
• Infrastructure security: cuan14's server infrastructure is hosted in ISO 27001-aligned data centers with physical access controls, 24/7 monitoring, and redundant power and network connectivity.
• Penetration testing: Our Platform undergoes regular independent penetration tests and vulnerability assessments. Critical findings are remediated on an accelerated timeline.
• Incident response: cuan14 maintains a documented data breach response plan. In the event of a confirmed breach affecting your Personal Data, you will be notified within 72 hours of our becoming aware, together with details of the nature of the breach and recommended protective actions.

cuan14 is operated for the Indonesia market. The majority of your Personal Data is processed and stored on infrastructure located in Asia-Pacific regions. However, certain Third-Party Service Providers — including international KYC verification platforms, game studio back-ends, and global fraud detection services — may process your data in jurisdictions outside Indonesia.

Where Personal Data is transferred to a jurisdiction that may not offer an equivalent level of data protection to Indonesia, cuan14 ensures that appropriate safeguards are in place. These safeguards include:

• Contractual data protection clauses incorporated into our agreements with all Third-Party Service Providers, requiring them to process data only for specified purposes and to maintain security standards equivalent to those described in this Policy.
• Vendor security assessments conducted prior to onboarding any new data processor that will handle Personal Data.
• Restrictions on onward transfer — our processors are prohibited from sub-contracting the processing of your Personal Data to additional parties without prior written approval from cuan14.

By registering an Account and using the cuan14 Platform, you acknowledge that your Personal Data may be transferred internationally as described in this section, and that cuan14 has taken reasonable steps to ensure your data is protected during such transfers.

As a registered cuan14 Player, you hold the following rights with respect to your Personal Data. To exercise any of these rights, contact our Privacy Team at [email protected] with the subject line "Data Subject Request", including your registered username and a clear description of your request.

• Right of access: You have the right to request a copy of the Personal Data cuan14 holds about you, together with information on how it is being processed.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete Personal Data we hold about you. Some data corrections (e.g., name changes) require supporting documentation.
• Right to erasure ("right to be forgotten"): You have the right to request deletion of your Personal Data in certain circumstances — for example, where the data is no longer necessary for the purposes it was collected. This right is subject to our legal retention obligations (see Section 8), which may prevent immediate deletion of certain categories of data.
• Right to restriction of processing: You have the right to request that cuan14 restricts the processing of your data — for example, while the accuracy of data is being contested or while an objection to processing is pending assessment.
• Right to data portability: You have the right to receive a copy of the Personal Data you provided to cuan14 in a structured, commonly used, machine-readable format (e.g., JSON or CSV), and to have that data transmitted to another controller where technically feasible.
• Right to object: You have the right to object to processing carried out on the basis of legitimate interests, including any profiling performed on that basis. cuan14 will cease such processing unless it can demonstrate compelling legitimate grounds that override your rights.
• Right to withdraw consent: Where processing is based on your consent (e.g., marketing emails, analytics cookies), you may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

cuan14 will respond to all verified data subject requests within 30 calendar days. Where a request is complex or voluminous, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reasons for it within the initial 30-day window.

The cuan14 Platform is strictly for adults. You must be at least 21 years of age to register an Account and use any cuan14 service. cuan14 does not knowingly collect or process Personal Data from individuals under the age of 21.

If cuan14 becomes aware that an Account has been registered by or on behalf of a person under 21 years of age, the Account will be immediately and permanently closed, all related Personal Data will be deleted as quickly as our legal retention obligations permit, and any deposits will be returned to the original payment method where technically feasible. Any winnings or bonuses accumulated by an underage Account will be forfeited in their entirety.

If you have reason to believe that a person under 21 has registered an Account on cuan14, please contact our support team immediately at [email protected].

cuan14 may send you promotional emails and in-Platform notifications about new games, bonus offers, and seasonal promotions — including those tied to Indonesian holidays such as Idul Fitri, Ramadhan, Chinese New Year (Imlek), and Independence Day (17 August) — but only where you have given explicit consent to receive such communications during registration or at a later point via your Account settings.

You may opt out of marketing communications at any time through any of the following methods:

• Clicking the "Unsubscribe" link in any marketing email sent by cuan14.
• Updating your communication preferences in the Notifications section of your cuan14 member dashboard.
• Contacting our support team via live chat or email with a request to unsubscribe from marketing communications.

Opting out of marketing communications will not affect the delivery of transactional communications — such as deposit confirmations, withdrawal notifications, KYC status updates, and account security alerts — which are sent as a necessary part of your Account service regardless of your marketing preferences.

cuan14 does not share your contact details with third-party marketers. All marketing communications originate from cuan14 directly, through email addresses and domains controlled by cuan14.

cuan14 reserves the right to update or amend this Privacy Policy at any time. The most current version is always available at https://cuan14.app/privacy-policy. The effective date at the top of this page indicates when the current version entered into force.

For material amendments — such as changes to the categories of data collected, the legal bases for processing, or your rights as a data subject — cuan14 will provide at least 14 days' advance notice to registered Members via the email address on file. For minor amendments (e.g., clarifications or typographical corrections that do not substantively alter the Policy), cuan14 may update this page without prior notice.

Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree with a material change, you are entitled to close your Account before the change takes effect by contacting our support team.

For any questions, concerns, or requests relating to this Privacy Policy or to the processing of your Personal Data by cuan14, please contact our Privacy Team through the following channels:

• Email: [email protected] — please use the subject line "Privacy Policy Query" or "Data Subject Request" as appropriate. Responses are typically provided within 5 business days.
• 24/7 Live Chat: Available directly from your member dashboard after login. Suitable for urgent privacy concerns or to initiate a data subject request.
• WhatsApp: +62 812 XXXX XXXX — available during WIB business hours (09:00–23:00 WIB, UTC+7).

When contacting us regarding a privacy matter, please include your registered Account username and a clear description of your query so that our team can route your request to the appropriate personnel without delay.