Topone33 Privacy Policy – Our Commitment to Protecting Your Data

Topone33 collects your personal data across several different situations throughout your use of our platform. Here is a comprehensive overview of the types of data we collect:

Personal data collected by topone33 is used solely for legitimate purposes directly related to the delivery of our platform services. The primary purposes for which data is used are as follows:

• Account management: Registering, verifying, and managing user accounts on topone33.
• Transaction processing: Processing deposits and withdrawals in Malaysian Ringgit (RM) via approved payment methods.
• Identity verification (KYC): Meeting compliance requirements and preventing fraud and money laundering.
• Service delivery: Providing access to games, Sports Betting (football, badminton, e-sports), Live Casino, poker, and lottery.
• Customer support: Responding to enquiries, resolving technical issues, and improving the user experience.
• Platform security: Detecting and preventing fraud, account misuse, and activities that violate our Terms & Conditions.
• Responsible gaming: Monitoring betting patterns to identify users who may need assistance and early intervention.
• Marketing communications: Sending relevant promotional information and bonuses – only to users who have consented to receive such communications.

Topone33 will not use your data for any purpose beyond those stated above without first obtaining your fresh consent.

Under Malaysia's Personal Data Protection Act 2010 (PDPA), topone33 processes users' personal data on the following lawful bases:

• Your consent: You provide explicit consent when registering a topone33 account and when participating in any promotion that requires additional data sharing.
• Contractual performance: Data processing is necessary to fulfil topone33's obligations under the Terms & Conditions you agreed to, including processing deposits, paying out winnings, and providing access to games.
• Legitimate interests: topone33 has a legitimate interest in processing data for the purposes of platform security, fraud prevention, and service improvement.
• Legal obligation: We are required to process and store certain data to fulfil our compliance and reporting obligations under applicable Malaysian law.

Topone33 does not sell, rent, or trade users' personal data to any third party for marketing purposes. Data sharing occurs only in the following limited circumstances:

• Payment processors: Information required to process transactions is shared with approved payment processors such as DuitNow, Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, and FPX (Maybank2u / CIMB Clicks). Data shared is kept to a minimum and covers only what is necessary to process the transaction.
• Technical service providers: Cloud infrastructure providers and technical service providers that assist us in operating the platform may access data in their capacity as data processors, subject to strict data protection agreements.
• Regulatory bodies & law enforcement: topone33 will disclose the required data to the relevant authorities when mandated by a court order or Malaysian law.
• Fraud prevention: In cases of identity verification or fraud investigation, limited information may be shared with accredited fraud prevention agencies.

Topone33 user data is stored on secure servers protected by multiple layers of security. Our technical security measures include:

• 256-bit SSL/TLS encryption for all data in transit.
• AES-256 encryption for data stored on servers (data at rest).
• Strict role-based access controls for topone33 staff.
• Regular security audits and independent penetration testing.
• 24/7 security monitoring with an intrusion detection and prevention system (IDS/IPS).
• Regular data backups across geographically separate data centres for disaster recovery.

Data retention period: topone33 retains user personal data for as long as the account remains active, and for a period of 7 years after account closure to meet Malaysian legal and tax requirements. Data that is no longer needed will be securely deleted or anonymised.

Topone33 uses cookies and similar tracking technologies to enhance the user experience and enable key platform functions. The cookies we use fall into several categories:

• Essential cookies: Required for core platform functions such as login authentication and session security. These cookies cannot be disabled.
• Performance cookies: Helping us understand how users interact with the platform so we can continuously improve the user experience.
• Functional cookies: Remembering your preferences, such as language and display settings, for future sessions.
• Marketing cookies: Used to display relevant topone33 promotions based on your interests. These are only activated with your consent.

You can manage your cookie settings through your web browser preferences. However, disabling essential cookies may affect the functionality of the topone33 platform.

Under Malaysia's PDPA 2010, you have the following rights regarding the personal data held by topone33:

• Right to access: You may request a copy of the personal data we hold about you.
• Right to rectification: You may request the correction of any data that is inaccurate or incomplete.
• Right to object to processing: You may object to the processing of your data for direct marketing purposes.
• Right to withdraw consent: You may withdraw your consent at any time — this does not affect the validity of any processing carried out prior to withdrawal.
• Right to erasure: You may request the deletion of your data in certain circumstances, subject to our legal retention obligations.
• Right to lodge a complaint: You have the right to lodge a complaint with the Department of Personal Data Protection Malaysia if you believe your privacy rights have been violated.

The topone33 platform is exclusively for individuals aged 18 and above only. topone33 does not knowingly collect or process personal data of individuals under the age of 18.

Should topone33 discover that data from a minor has been collected inadvertently, we will take immediate steps to delete the information and close the associated account. Parents or guardians who believe their child has registered on topone33 are urged to contact us at support@topone33.ws without delay.

Topone33 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in data practices, legal requirements, or platform improvements. Whenever a material change is made, we will:

• Updating the "Last Updated" date at the top of this document.
• Displaying a prominent notice on the topone33 homepage for 30 days following any amendment.
• Sending an in-platform notification upon your first login after the changes take effect.
• Sending an email to the user's registered address for any highly significant changes.

Continued use of the topone33 platform after the effective date of any changes constitutes acceptance of the updated Privacy Policy.

If you have any questions, concerns, or complaints regarding this Privacy Policy or how topone33 handles your personal data, please reach out to us through the following channels: