topone33 Privacy Policy

This Privacy Policy ("Policy") describes how topone33 ("topone33", "we", "us", "our") collects, processes, stores, and protects personal data provided by users ("Player", "you", "your") who access or register on the topone33 Platform at topone33.win.

topone33 processes personal data in accordance with applicable data protection principles, including the requirements of international gaming authority operating standards applicable to our licensing jurisdiction. By registering an Account or continuing to use the Platform, you acknowledge that you have read and understood this Policy.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, all of which form part of your agreement with topone33.

topone33 acts as the data controller in respect of all personal data collected through the Platform. As data controller, topone33 is responsible for determining the purposes and means of processing your personal data.

For all data protection enquiries, subject access requests, or complaints, please contact our designated data protection point of contact via email at [email protected], with "Data Protection" clearly indicated in your subject line. We aim to respond to all formal data enquiries within 30 calendar days.

3.1 topone33 collects personal data through several channels, including account registration, use of the Platform, customer support interactions, and payment processing. The categories of personal data we collect include:

• Identity Data: Full legal name, date of birth, gender, and copies of government-issued identity documents (Malaysian MyKad, passport) submitted for KYC verification.
• Contact Data: Email address, Malaysian mobile phone number, and residential address.
• Financial Data: Payment method details (e.g., Touch 'n Go eWallet account reference, DuitNow QR identifier, bank account details for Maybank, CIMB, or Public Bank), transaction history, deposit and withdrawal records.
• Technical Data: IP address, device type, operating system, browser type and version, session timestamps, and connection logs.
• Usage Data: Game history, bet amounts, wagering patterns, bonus redemption history, and login timestamps.
• Communications Data: Records of customer support interactions via email or live chat, including any attachments you provide.
• Responsible Gaming Data: Self-exclusion requests, deposit limits set, and cooling-off period elections recorded in your Account settings.

3.2 You are not required to provide all categories of data to access the Platform, but certain data — particularly Identity Data and Financial Data — is mandatory for account registration, KYC compliance, and payment processing. Failure to provide mandatory data may prevent us from opening or maintaining your Account.

4.1 topone33 processes your personal data for the following purposes:

• Account Management: To create, maintain, and administer your topone33 Account, including processing login sessions and managing account settings.
• Identity Verification: To conduct KYC verification as required by our international gaming authority obligations and to prevent underage gambling, fraud, and money laundering.
• Payment Processing: To process deposits and withdrawals via your chosen Malaysian payment method and to maintain accurate financial records.
• Platform Delivery: To provide access to the full topone33 game library, sportsbook, Toto 4D, and all other Platform features.
• Security: To detect and investigate fraud, collusion, money laundering, account takeover, and other prohibited conduct as defined in our Terms & Conditions.
• Responsible Gaming: To enforce self-exclusion orders, deposit limits, and other player protection measures elected or imposed under our Responsible Gaming Policy.
• Legal Compliance: To comply with applicable gaming authority reporting requirements, anti-money laundering obligations, and lawful data requests from competent authorities.
• Communications: To respond to your support enquiries, send transactional notifications (deposit confirmations, withdrawal updates), and — where you have consented — marketing communications about topone33 promotions.
• Platform Improvement: To analyse usage patterns, identify technical issues, and improve the performance and user experience of the topone33 Platform.

4.2 topone33 does not use your personal data to make fully automated decisions that produce legal or similarly significant effects without human oversight, except where such processing is specifically required by our gaming authority obligations.

5.1 topone33 processes personal data on the following legal bases:

• Contractual Necessity: Processing necessary to perform our contract with you — account creation, game delivery, payment processing, and customer support.
• Legal Obligation: Processing required to comply with our gaming authority licensing conditions, AML obligations, and lawful authority requests.
• Legitimate Interests: Processing necessary for fraud prevention, security monitoring, and Platform improvement, where our interests do not override your fundamental rights and freedoms.
• Consent: Where we send you marketing communications about topone33 promotions or process non-essential cookies, we rely on your explicit consent, which you may withdraw at any time.

6.1 topone33 does not sell your personal data to any third party for commercial purposes. We may share your data only in the following limited circumstances:

• Payment Processors: Your financial data is shared with licensed payment service providers (including Touch 'n Go eWallet, Boost, DuitNow, and Malaysian banking partners) solely to process your transactions.
• KYC/AML Providers: Identity data may be shared with regulated identity verification and anti-money laundering screening service providers as required by our compliance obligations.
• Game Software Providers: Certain usage data (game session identifiers, RNG verification data) is shared with our certified game providers for audit and game integrity purposes.
• Regulatory Authorities: We may be required to disclose personal data to our gaming licensing authority, financial intelligence units, or other competent authorities pursuant to lawful requests or our licence conditions.
• Service Providers: We engage third-party technical service providers (hosting, analytics, security monitoring) who process data on our behalf under strict data processing agreements that prohibit independent use of your data.

6.2 Where topone33 shares personal data with third parties, we require those parties to maintain appropriate technical and organisational security measures and to process the data only for the specified purpose and in accordance with our instructions.

7.1 The topone33 Platform uses cookies and similar tracking technologies to provide a functional gaming experience, maintain login sessions, and — where you have consented — to analyse Platform usage and personalise content.

7.2 The categories of cookies used on topone33.win include:

• Essential Cookies: Required for the Platform to function — session authentication, security tokens, and load balancing. These cannot be disabled without preventing Platform access.
• Functional Cookies: Remember your preferences such as language, display settings, and responsible gaming limit configurations.
• Analytics Cookies: Used — with your consent — to collect aggregate usage statistics that help us improve Platform performance and user experience. We use privacy-respecting analytics tools.

7.3 You may manage non-essential cookie preferences through your browser settings. Note that disabling functional cookies may affect your Platform experience, such as requiring you to re-enter preferences on each session.

8.1 topone33 retains personal data for as long as is necessary to fulfil the purposes outlined in this Policy, subject to the following minimum retention periods:

• Account and Identity Data: Retained for the duration of your Account and for a minimum of 5 years following Account closure, as required by our gaming authority licence conditions and AML obligations.
• Transaction Records: Retained for a minimum of 5 years from the date of each transaction, in accordance with financial record-keeping requirements.
• Support Communications: Retained for 3 years from the date of the interaction, unless the communication relates to an ongoing dispute or regulatory inquiry.
• Technical Logs: Typically retained for 12 months for security monitoring purposes, after which they are deleted or anonymised.

8.2 Where topone33 no longer has a legal or operational basis to retain your personal data, we will securely delete or anonymise it in accordance with our internal data disposal procedures.

9.1 topone33 implements technical and organisational security measures appropriate to the sensitivity of the personal data we hold, including:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers;
• Encryption of sensitive data at rest, including payment credentials and identity documents;
• Access controls limiting personal data access to authorised topone33 personnel on a need-to-know basis;
• Regular security assessments and penetration testing of the Platform infrastructure;
• Two-factor authentication available to all Players for Account access.

9.2 Despite the measures we implement, no data transmission over the internet is entirely without risk. You acknowledge that you transmit data to topone33 at your own risk. If you become aware of any security vulnerability or suspect your topone33 Account has been compromised, you must notify us immediately at [email protected].

10.1 Subject to applicable data protection law, you have the following rights in respect of your personal data held by topone33:

• Right of Access: You may request a copy of the personal data topone33 holds about you.
• 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 we no longer have a lawful basis to retain it, subject to our legal retention obligations.
• Right to Restriction: You may request that we restrict processing of your personal data in certain circumstances.
• Right to Portability: You may request a structured, machine-readable copy of personal data you have provided to topone33.
• Right to Object: You may object to processing based on our legitimate interests. Where processing is for direct marketing, you may object at any time and we will cease such processing immediately.
• Right to Withdraw Consent: Where we rely on your consent as the legal basis for processing, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

10.2 To exercise any of the above rights, please contact us at [email protected], clearly identifying yourself and specifying the right you wish to exercise. We may need to verify your identity before actioning your request. We will respond within 30 calendar days.

The topone33 Platform is strictly for adults aged 21 and above. topone33 does not knowingly collect personal data from persons under the age of 21. If we become aware that we have inadvertently collected data from an underage person, we will immediately close the relevant Account, forfeit any balance as required by our licence conditions, and securely delete the personal data collected.

If you believe a minor has created an account on topone33, please notify us at [email protected] so that we may investigate and take appropriate action without delay.

12.1 As topone33 operates under an international gaming authority licence, some of your personal data may be transferred to and processed in countries outside Malaysia. Where such transfers occur, topone33 implements appropriate safeguards, including data processing agreements that incorporate recognised data protection standards, to ensure your data receives a comparable level of protection to that applicable in Malaysia.

12.2 Where personal data is transferred to third-party service providers located in other jurisdictions, those providers are contractually required to maintain security standards equivalent to those set out in this Policy.

13.1 topone33 may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or Platform features. Material amendments will be communicated to registered Players via email or a prominent notice on the Platform prior to the revised Policy taking effect.

13.2 Your continued use of the Platform following the effective date of any revised Privacy Policy constitutes your acknowledgement of the updated practices. We encourage you to review this Policy periodically. The "Last updated" date at the top of this page indicates when the Policy was most recently revised.

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or wish to raise a complaint about how topone33 processes your personal data, please contact us:

If you are unsatisfied with our response to a data protection complaint, you may refer the matter to the relevant data protection supervisory authority in your jurisdiction or to our gaming authority licensing body.