topup77 Privacy Policy

For the purposes of this Privacy Policy, the data controller responsible for your personal data is the entity operating the topup77 online gaming platform at topup77.club ("topup77," "we," "us," or "the Company"). topup77 determines the purposes and means of processing personal data collected through the platform.

topup77 operates under international gaming authority licensing and is subject to data protection obligations arising from both its licensing conditions and applicable data protection legislation. If you have any questions regarding this Privacy Policy or topup77's data practices, please refer to Section 13 (Contact Us) for the appropriate channels.

topup77 collects personal data in the following categories:

topup77 does not collect sensitive personal data (as defined under Malaysia's Personal Data Protection Act 2010) except where expressly required for KYC compliance purposes, in which case such data is handled under heightened security controls.

topup77 processes personal data for the following purposes:

• Account management: Creating, maintaining, and administering your topup77 account, including authentication and security;
• Service delivery: Providing access to all gaming products, processing deposits and withdrawals, and delivering customer support;
• Identity verification and KYC: Verifying your identity and age (minimum 21 years) as required by topup77's licensing obligations;
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent transactions, money laundering, and other prohibited activities;
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behaviour and administering self-exclusion, deposit limit, and cool-off requests;
• Legal and regulatory compliance: Meeting obligations arising from topup77's international gaming licence, anti-money laundering requirements, and other applicable laws;
• Platform improvement: Analysing usage patterns to improve platform performance, user experience, and game catalogue;
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates where you have provided consent or where topup77 has a legitimate interest — subject always to your opt-out rights;
• Dispute resolution: Maintaining records necessary to resolve player disputes and respond to regulatory enquiries.

topup77 does not use automated profiling or artificial intelligence-based decision-making that produces legal or similarly significant effects on players without human review and the ability to contest the outcome.

topup77 processes personal data under the following legal bases:

• Contractual necessity: Processing required to fulfil topup77's obligations under the account agreement, including account creation, gaming access, payment processing, and customer support;
• Legal obligation: Processing required to comply with KYC/AML requirements, licensing conditions, tax obligations, and court orders;
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where topup77's legitimate interests are not overridden by your data protection rights;
• Consent: Processing for direct marketing communications, certain cookie categories, and other activities where topup77 relies on your explicit, freely given consent — which you may withdraw at any time.

topup77 does not sell or rent your personal data. topup77 may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to confidentiality obligations:

• Payment processors and e-wallet providers: Touch 'n Go, Boost, GrabPay, Maybank, CIMB, Public Bank, and other payment partners for the purpose of processing your deposits and withdrawals;
• KYC and identity verification partners: Third-party identity verification service providers engaged by topup77 to conduct regulatory-required identity checks;
• Gaming software providers: Licensed game studios and platform technology providers who require access to certain account and session data to deliver games and maintain fair play;
• Fraud detection and security providers: Specialist third parties engaged to assist in detecting and preventing fraudulent activity on the platform;
• Regulatory and law enforcement authorities: Competent authorities, courts, and regulatory bodies where topup77 is legally obligated to disclose data, or where disclosure is necessary to protect topup77's legal rights;
• Professional advisors: Legal counsel, auditors, and compliance consultants acting under professional confidentiality obligations.

topup77 uses cookies and similar tracking technologies on the platform for the following purposes:

• Strictly necessary cookies: Essential for platform operation, user authentication, session management, and security. These cannot be disabled without affecting platform functionality.
• Functional cookies: Remember your preferences such as language settings, game lobby view, and responsible gaming configurations.
• Analytics cookies: Collect anonymised usage data to help topup77 understand how the platform is used and identify areas for improvement. These are deployed only with your consent.
• Marketing cookies: Track your interaction with topup77 promotions to prevent duplicate offer delivery and to measure promotional effectiveness. Deployed only with consent.

You may manage your cookie preferences through your browser settings at any time. Disabling certain cookies may limit platform functionality. Strictly necessary cookies cannot be disabled as they are essential for security and account access.

topup77 retains personal data for as long as necessary to fulfil the purposes outlined in this Privacy Policy, subject to the following minimum retention periods:

• Account and identity data: Retained for a minimum of 5 years following account closure, as required by anti-money laundering and licensing regulations;
• Financial transaction records: Retained for a minimum of 7 years following each transaction, as required for financial regulatory compliance;
• Gaming activity logs: Retained for a minimum of 5 years following the relevant gaming session;
• Customer support communications: Retained for 3 years following the resolution of the relevant support interaction;
• Marketing consent records: Retained until consent is withdrawn and for a further 2 years thereafter as evidence of prior consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with topup77's data destruction procedures.

topup77 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These measures include:

• AES-256 SSL/TLS encryption for all data transmitted between your browser and topup77 servers;
• Encryption of sensitive personal data at rest in topup77's database infrastructure;
• One-way cryptographic password hashing with unique salts;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular penetration testing and vulnerability assessments conducted by independent security firms;
• Two-factor authentication available for all player accounts;
• Automated anomaly detection systems monitoring for suspicious access patterns.

As a data subject, you hold the following rights with respect to personal data processed by topup77, subject to applicable legal limitations:

• Right of access: You may request a copy of the personal data topup77 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 topup77 no longer has a lawful basis to retain it, subject to regulatory minimum retention requirements;
• Right to restrict processing: You may request that topup77 limit processing of your personal data in certain circumstances;
• Right to data portability: You may request a copy of your personal data in a structured, machine-readable format;
• Right to object: You may object to processing based on legitimate interests or for direct marketing purposes;
• Right to withdraw consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact topup77's data protection team via the channels listed in Section 13. topup77 will respond to all valid requests within 30 days of receipt. Requests that are manifestly unfounded or excessive may be refused or subject to an administrative fee.

topup77 employs age verification procedures during registration and KYC processes to prevent underage access. Where topup77 becomes aware that personal data has been collected from an individual under the age of 21, that account will be immediately suspended, all data will be securely deleted, and any deposits will be returned to the originating payment method following investigation.

If you believe that topup77 has inadvertently collected personal data from a minor, please contact topup77 immediately via the contact details in Section 13.

topup77 may transfer personal data to countries outside Malaysia in connection with the operation of its platform, including to service providers and technology partners located in jurisdictions with different data protection laws. Where such transfers occur, topup77 ensures that appropriate safeguards are in place, which may include:

• Standard contractual clauses approved by relevant data protection authorities;
• Binding corporate rules applicable to topup77's corporate group;
• Transfer to jurisdictions recognised as providing an adequate level of data protection.

topup77 will not transfer your personal data to jurisdictions that do not provide adequate data protection safeguards without your explicit consent, except where required by applicable law.

topup77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in legal requirements, platform features, or data processing practices. Where changes are material, topup77 will notify registered players via email to the address on their account or via an on-platform notice prior to the updated policy taking effect.

The current version of this Privacy Policy is always accessible at topup77.club/privacy-policy. The "Last Updated" date at the top of this document indicates when the most recent changes were made. Your continued use of the topup77 platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms.

For any questions, concerns, or requests relating to this Privacy Policy or topup77's handling of your personal data, please contact our data protection team through the following channels:

• Live Chat: Available 24/7 directly on the topup77 platform
• Email: [email protected]
• Operating Hours: 24 hours a day, 7 days a week including Malaysian public holidays (Malaysia Standard Time, UTC+8)

topup77 endeavours to acknowledge all data rights requests within 3 business days and to provide a full response within 30 calendar days. For complex requests requiring additional review, topup77 will notify you of the extended timeline within the initial 30-day window.