Top1 Privacy Policy — Malaysia Player Personal Data Protection

1 Personal Data We Collect

Top1 only collects personal data that is strictly necessary to provide a safe, efficient and responsible service to all our users. Data collection is conducted transparently and with the user's full knowledge.

Directly Provided Information:

• Full name as shown on your identification card or official document.
• Date of birth for age verification purposes.
• A valid and active email address.
• Mobile number for two-factor authentication (2FA).
• Current residential address.
• Identity documents such as a copy of MyKad, passport, or driving licence for the KYC process.
• Payment method details used for deposits and withdrawals.

Automatically Collected Information:

• Device IP address and general geographic location.
• Device type, operating system, and web browser version.
• Session data includes login timestamps, session duration, and in-platform activity.
• Transaction logs including deposit history, withdrawals, and game activity.
• Cookie and similar tracking technology data.

2 How We Use Your Data

Every piece of data we collect is used for specific, lawful and transparent purposes. top1 does not use user data for any purpose unrelated to the delivery of our platform services.

Primary Purpose of Data Use:

• Account Management: Create, verify, and manage your user account, including processing password recovery requests and profile updates.
• Transaction Processing: Securely and promptly process deposits, withdrawals, and any financial transactions you make on the top1 platform.
• Security & Fraud Prevention: Detect and prevent fraudulent activity, money laundering, multi-account usage, and any violations of platform terms.
• Legal Compliance: Fulfill KYC, AML obligations, and reporting requirements of relevant authorities in accordance with applicable law.
• Customer Support: Provide technical assistance, resolve complaints, and communicate with you regarding your account or transactions.
• Personalize Your Experience: Personalize content, offers, and game recommendations based on your preferences and usage habits on the platform.
• Marketing Communications: Send promotional information, bonuses, and the latest offers — only if you have given your consent to receive them.

3 Data Sharing & Disclosure

Top1 takes an extremely cautious approach to user data sharing. As a matter of principle, we do not share your personal data with external parties except in the circumstances clearly stated below.

Parties That May Receive Your Data:

• Payment Service Providers: Payment processors and financial institutions that handle your deposit and withdrawal transactions. They are bound by strict confidentiality agreements.
• Identity Verification Service Providers: Trusted third parties that assist us in conducting KYC checks and identity verification in accordance with industry standards.
• Game Providers: Gaming companies that provide casino and betting content on the top1 platform. Data shared is kept to a minimum and limited strictly to technical requirements.
• Statutory Authorities: Law enforcement agencies or regulatory bodies when we are legally required to do so.

We Never:

• Sell your personal data to advertisers or data brokers.
• Sharing your data with other companies for their own marketing purposes.
• Disclose your transaction details or game activity to unauthorized parties.

4 Data Security Measures

Top1 invests seriously in security infrastructure to ensure your personal data is always protected against unauthorized access, loss, destruction or unintended disclosure.

Technical Security Measures:

• Data Encryption: All data in transit is protected by 256-bit TLS/SSL encryption. Data stored on our servers is also encrypted using AES-256 standards.
• Two-Factor Authentication (2FA): Users are encouraged to enable 2FA for an added layer of security when logging in to their top1 account.
• 24/7 Monitoring: Our security team continuously monitors systems to detect any suspicious activity or intrusion attempts.
• Regular Audits: Our security systems are independently audited by third parties on a regular basis to ensure compliance and resilience against the latest threats.
• Internal Access Controls: Staff access to user data is restricted on a need-to-know basis and is strictly monitored.

While we take all reasonable steps to protect your data, no security system in the world is 100% impenetrable. You also play an important role by using a strong password, not sharing your login credentials, and keeping your device secure.

5 Cookies & Tracking Technologies

Top1 uses cookies and similar tracking technologies to enhance platform functionality, understand how users interact with our website, and deliver a more personalized experience.

Types of Cookies We Use:

• Essential Cookies: Required for core platform functions such as login session verification and security. These cookies cannot be disabled.
• Performance Cookies: Collect information on how web pages are used to help us improve the overall user experience.
• Functional Cookies: Allows the platform to remember your preferences such as language, currency, and display settings.
• Analytics Cookies: Used to analyse platform traffic patterns and usage on an aggregated, anonymised basis.

You can manage or disable cookies through your web browser settings at any time. Please note that disabling certain cookies may affect the functionality or your experience on the top1 platform.

6 Your Rights as a User

Top1 respects and upholds user rights regarding their personal data. You have the following rights, which may be exercised at any time by contacting our support team.

To exercise any of the above rights, contact the top1 support team via live chat or our support email. We will process your request within 30 business days.

7 Data Retention Period

Top1 retains your personal data only for as long as it is needed for the purposes stated in this policy or as required by applicable laws and regulations.

• Active Account Data: Retained for the duration your account remains active and in use on the top1 platform.
• KYC & Identity Verification Data: Retained for a minimum of 5 years after account closure in accordance with international AML compliance requirements.
• Financial Transaction Records: Retained for 7 years in accordance with standard financial and tax legal requirements.
• Support Communication Logs: Retained for 2 years for reference and dispute resolution purposes.
• Session & Technical Log Data: Retained for 90 days for security and technical issue resolution purposes.

Once the defined retention period expires, your personal data will be securely deleted or anonymized using industry-standard deletion procedures.

8 Contact Us Regarding Privacy

If you have any questions, concerns, or complaints regarding this Privacy Policy or how we handle your personal data, we encourage you to contact us directly.

The top1 Data Protection Team can be contacted via:

• Live Chat: Available 24 hours a day, 7 days a week via the chat icon at the bottom corner of the platform.
• Email: [email protected] — for specific enquiries relating to privacy and data protection.
• FAQ Page: Visit FAQ us for answers to frequently asked questions about privacy and your account.

We also respect your right to lodge a complaint with the relevant data protection authority if you feel your complaint has not been resolved satisfactorily by us.

This Privacy Policy may be updated from time to time to reflect changes in our practices or legal requirements. Any material changes will be communicated via in-platform notifications or email to registered users. The "Last Updated" date at the top of this document indicates when the current version took effect.