Privacy Policy topup33 – Personal Data Protection for Malaysian Players

Topup33 is the data controller for all personal information collected through our platform at topup33.best. This means topup33 is fully responsible for determining the purposes and means of processing your personal data, and for ensuring that all processing is carried out in accordance with applicable privacy laws and ethical standards.

Under Malaysia's Personal Data Protection Act (PDPA 2010), topup33 is a "data user" responsible for ensuring your personal data is processed in a lawful, fair and transparent manner. We have appointed an internal Data Protection Officer (DPO) responsible for overseeing our compliance with applicable privacy requirements.

For any enquiries, requests or complaints related to data privacy, please reach out to our team directly by email at support@topup33.best with the subject line "Data Privacy Request" and we will respond within 24 business hours.

Topup33 collects only the personal data strictly necessary to operate the platform and provide you with the best possible service. Below are the categories of data we collect and the purpose behind each:

Topup33 uses collected personal data solely for legitimate and reasonable purposes related to the provision of our platform services. We do not use your data for unrelated purposes without your explicit prior consent.

• Account Operations & Identity Verification: Your registration and KYC information is used to verify your identity, process deposits and withdrawals, and prevent fraud and money laundering in line with Malaysian legal requirements.
• Financial Transaction Processing: Payment data is used to process deposits via Touch 'n Go, GrabPay, Boost, ShopeePay, DuitNow, and FPX (Maybank2u, CIMB Clicks), and to manage your winnings withdrawals securely and accurately.
• Personalised Gaming Experience: Your gameplay activity data helps topup33 deliver relevant game recommendations, personalise promotional offers, and ensure the platform interface is tailored to your preferences.
• Customer Support: Communication records and account history allow the topup33 support team to assist you more efficiently whenever you reach out to us.
• Platform Security & Fraud Prevention: Technical data such as IP addresses and session data is used to detect and prevent unauthorised access, fraudulent activity, player collusion, bot usage and any activity that violates topup33's Terms & Conditions.
• Responsible Gaming: Your game activity history is automatically monitored to identify patterns that may indicate problem gambling, enabling the topup33 team to offer timely assistance to players who need it.
• Marketing Communications (With Consent): If you have consented to receive marketing communications, we use your email address and phone number to keep you informed of the latest promotions, exclusive offers, and topup33 platform news.
• Legal Compliance & Reporting: Certain data may be required to fulfil legal reporting obligations, lawful authority requests, or regulatory compliance requirements applicable to topup33's operations.

Topup33 understands that your trust depends on how we handle your data when third parties are involved. Our policy is clear: we do not sell your data, and we only share it in the following limited and necessary situations:

• Payment Service Providers: To process your deposits and withdrawals, topup33 shares the necessary transaction data with Malaysian e-wallet and online banking service providers such as Touch 'n Go, GrabPay, Boost, ShopeePay, DuitNow and FPX providers. This sharing is kept to a minimum and limited strictly to the information required to complete the transaction.
• Game Software Providers: Live casino and slots game providers partnered with topup33 may receive the session data necessary to deliver a smooth and secure gaming experience. This data does not include your full financial information.
• Technical Service Providers: Companies that assist us with server hosting, cybersecurity, and platform analytics may have limited access to the data required to carry out those functions. All such providers are bound by strict data protection agreements with topup33.
• Legal Authorities: topup33 may be required to disclose certain data to Malaysian government authorities or law enforcement bodies upon receipt of a valid court order or official request that meets the requirements of applicable law.

Topup33 invests seriously in data security infrastructure to ensure your personal and financial information is always protected at the highest level. The following are the security layers we employ:

• 256-Bit SSL Encryption: All data transmitted between your device and topup33's servers is encrypted using TLS 1.3 protocol with 256-bit encryption. This ensures no third party can intercept or read your data in transit.
• Encrypted Data Storage: Sensitive data stored in topup33's databases — including identity card numbers and financial information — is stored in encrypted form using industry-standard encryption algorithms. Data is never stored in plain text.
• Layered Access Controls: topup33's access management system ensures that only authorised staff with a specific operational need can access player data. All access is logged and monitored by our security team.
• 24/7 Security Monitoring: topup33's cybersecurity team monitors our platform around the clock to detect and respond to any threats or suspicious activity in real time.
• Regular Security Audits: topup33 conducts regular internal security audits and penetration testing by independent security specialists to identify and address any vulnerabilities before they can be exploited.
• Incident Response Plan: topup33 has a comprehensive incident response plan in the event of a data breach. In such a situation, we will notify affected players and the relevant authorities within the timeframes prescribed by Malaysian law.

Topup33 uses cookies and similar tracking technologies to enhance your experience on our platform, understand how the platform is used, and maintain the security of your session. The following are the types of cookies we use:

• Essential Cookies (Required): These cookies are required for the core functions of the topup33 platform — including secure login, session management, and transaction security. The platform cannot function properly without them and they cannot be disabled.
• Preference Cookies: These cookies allow topup33 to remember your settings and preferences — such as your preferred language, display layout, and game settings — so you do not have to reconfigure them each time you use the platform.
• Analytics Cookies: We use analytics cookies to understand how players use the topup33 platform — which pages are visited most frequently, how long sessions last, and where players encounter difficulties. This data is used in aggregate to improve the platform.
• Security Cookies: These cookies are used to detect and prevent fraud, verify your identity during active sessions, and ensure that every action taken on the topup33 platform is performed by a legitimate user.

You can manage your cookie settings through your web browser at any time. However, disabling essential cookies may affect the functionality of the topup33 platform and prevent you from logging in or completing transactions. For assistance with cookie management, please contact our support team.

Topup33 does not retain your personal data longer than is necessary for the purpose it was collected, unless we are required to do so by applicable law. The following are our general data retention guidelines:

• Active Account Data: Personal data and account records of active players are retained for the duration of the active account and for an additional period following account closure as required by applicable Malaysian law, typically between 5 to 7 years.
• Financial Transaction Records: All deposit, withdrawal and wagering transaction records are retained for a minimum of 7 years from the transaction date in accordance with Malaysia's anti-money laundering (AML) compliance and financial reporting requirements.
• Technical & Log Data: Access logs, session data, and other technical information are retained for a maximum of 12 months before being automatically deleted or anonymised, unless required for an ongoing security investigation.
• Support Communication Records: Records of customer support conversations and correspondence are retained for 3 years to facilitate the resolution of any disputes that may arise.
• Self-Exclusion Data: Self-exclusion request records are retained for the duration of the exclusion period plus 5 years to ensure we do not allow the player in question to re-register within the specified timeframe.

As a topup33 player who is a Malaysian citizen or resident, you have certain rights regarding your personal data under Malaysia's Personal Data Protection Act (PDPA). topup33 fully respects and upholds these rights:

To exercise any of the rights above, please contact our team at support@topup33.best with the email subject "Data Privacy Rights Request", along with your topup33 account number and specific request details. All requests will be acknowledged within 24 hours and resolved within 30 calendar days.

Topup33 is an adult betting platform that strictly does not offer services to individuals under the age of 18. We take the protection of children's privacy very seriously and maintain rigorous procedures to prevent underage registration.

• The topup33 registration process requires age verification, and all information provided is validated during the KYC process to ensure that only individuals aged 18 and above hold active accounts.
• Should topup33 discover that personal data belonging to an individual under the age of 18 has been inadvertently collected, we will delete that data immediately and close the associated account.
• Parents or guardians who believe their minor child has registered or attempted to register at topup33 are urged to contact us at support@topup33.best immediately so that appropriate action can be taken.

Topup33 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our privacy practices, new legal requirements, or improvements to the way we operate. Registered players will be notified of significant changes via email or in-platform notification at least 14 days before they take effect.

Each time this Privacy Policy is updated, the version number and date at the top of this document will be revised to reflect the latest changes. It is your responsibility to review this page periodically.

If you have any questions, concerns, or complaints regarding how topup33 handles your personal data, or wish to exercise any of your privacy rights, we encourage you to contact us directly. The topup33 data protection team is here to help.

• Data Privacy Email: support@topup33.best — use the subject line "Data Privacy Request" for faster handling. A response is guaranteed within 24 business hours for all privacy-related enquiries.
• In-Platform Live Chat: Available 24/7 in Bahasa Melayu. Suitable for general privacy enquiries and straightforward requests such as updating personal information.
• WhatsApp Support: topup33's official WhatsApp number is available in your account after logging in. Use it for urgent privacy and account security enquiries.

We are committed to providing a complete and satisfactory response to all privacy enquiries. If you are not satisfied with how topup33 has handled your privacy complaint, you have the right to lodge a formal complaint with the Personal Data Protection Commissioner of Malaysia in accordance with the procedures set out under PDPA 2010.