Topx Privacy Policy – Data Protection & Member Privacy

1 Information We Collect

To deliver the best, most secure, and regulatory-compliant service, topx collects several categories of personal information from our members. This collection is carried out transparently and solely for legitimate purposes.

2 How We Use Your Data

Collected information is used solely for legitimate and transparent purposes. topx does not use your data for any purpose unrelated to platform operations or legal requirements. The following are the primary purposes for which your data is used:

• Account Management: Creating, verifying, and maintaining your account on the topx platform, including the mandatory KYC process to ensure the safety of all members.
• Transaction Processing: Ensuring that deposits and withdrawals are processed accurately, promptly, and securely. Your financial data is used solely for this purpose and is not retained longer than necessary.
• Security & Fraud Prevention: Monitoring account activity to detect and prevent unauthorized access, money laundering, collusion, or any form of platform abuse.
• Customer Support: Providing technical assistance and resolution for any complaints or inquiries you submit to our support team.
• Legal Compliance: Fulfilling reporting and compliance obligations under applicable Malaysian law, including anti-money laundering (AML) and data protection requirements.
• Platform Communications: Sending important notifications regarding your account, policy changes, relevant promotions, and security information.
• Service Improvement: Analyzing usage patterns in aggregate and anonymized form to understand member needs and continuously improve platform quality.
• Responsible Gaming: Detecting concerning gambling patterns and reaching out to members who may need responsible gambling support.

3 Legal Basis for Personal Data Processing

All personal data processing we carry out is based on one or more lawful grounds under applicable data protection law in Malaysia. topx operates in accordance with the Personal Data Protection Act 2010 (PDPA) of Malaysia.

• Contract Performance: Processing necessary to fulfill our obligations to you as a platform member, including account management and financial transactions.
• Legal Obligations: Processing necessary to comply with applicable Malaysian law, including KYC and AML requirements as mandated by the relevant authorities.
• Legitimate Interest: Processing necessary to protect the legitimate interests of topx and our members, including fraud prevention and platform security.
• Consent: For certain processing activities such as optional marketing communications, we obtain your explicit consent. You may withdraw this consent at any time.

4 Information Sharing & Disclosure

Topx takes a highly cautious approach to sharing your personal information. Our core principle is clear: we does not sell, rent, or trade your personal data to any party for marketing or commercial purposes. Information sharing only occurs in the following limited situations:

• Third-Party Service Providers: We share only the minimum necessary information with service providers that support our platform operations — such as payment processors, identity verification providers, and cloud infrastructure providers. All such providers are bound by strict confidentiality agreements and are only permitted to use your data for specified purposes.
• Legal Requirement: topx will disclose your personal information to government authorities or law enforcement bodies when required by a valid court order, directive from a relevant authority, or AML/CTF compliance obligations prescribed under Malaysian law.
• Security Protection: In situations where there is a serious threat to member safety or platform integrity, relevant information may be shared with the appropriate authorities for investigation and crime prevention purposes.
• Business Transfers: If topx is involved in any merger, acquisition, or asset transfer, member personal information may form part of the transferred assets. You will be notified via appropriate notice before any such transfer takes place.

5 Data Security & Information Protection

The security of your personal data is a core technical priority at topx. We continuously invest in state-of-the-art security infrastructure to ensure your information is always protected against cyber threats, unauthorized access, and data breaches.

• 256-bit SSL Encryption: All data transmitted between your device and topx servers is encrypted using military-grade TLS/SSL protocol (256-bit AES encryption). This ensures no third party can intercept or read your data in transit.
• Secure Data Storage: Your personal data is stored on servers protected by multiple layers of security, including advanced firewalls, intrusion detection systems, and strict access controls based on the principle of least privilege.
• 24/7 Monitoring: Our cybersecurity team continuously monitors the platform infrastructure at all times to promptly detect and respond to any threats or suspicious activity.
• Regular Audits: topx conducts regular penetration testing and security audits by independent security experts to ensure our systems remain robust and up to date.
• Internal Access Controls: Only topx staff with a legitimate business need and who have completed appropriate data protection training are permitted to access member personal data.
• Hashed Passwords: Your account password is not stored in plain text — it is stored in a hashed format that cannot be decoded, keeping your password secure even in the event of an unexpected incident.

6 Data Retention Period

Topx retains your personal data for as long as necessary to fulfil the purposes stated in this privacy policy, or for as long as required by applicable Malaysian law.

• Active Account Data: For as long as your account is active or while you continue using topx services, your profile and account data will be retained to ensure smooth platform operations.
• Financial Records & Transactions: Financial transaction records are retained for a minimum of seven (7) years from the transaction date, in compliance with AML requirements and Malaysia's tax laws.
• KYC Data: Identity verification documents are retained for the period specified by the relevant authorities, typically five (5) to seven (7) years after account closure.
• Communication Records: Support chat logs and email correspondence are retained for three (3) years for dispute reference and service improvement purposes.
• Technical Data & Logs: Access logs and technical data are retained for ninety (90) days unless associated with an ongoing security investigation.

When data is no longer needed and there is no legal obligation to retain it, topx will securely delete or anonymise it using industry-recognised methods.

7 Your Rights as a User & Member

Under Malaysia's Personal Data Protection Act 2010 and international data protection best practices, you have the following rights regarding the personal data held by topx:

8 Cookies & Tracking Technologies

Topx uses cookies and similar tracking technologies to enhance your experience on our platform. Understanding how we use these technologies helps you make more informed decisions about your privacy.

• Essential Cookies: Required for core platform operations — including maintaining your login session, saving language preferences, and ensuring transaction security. These cookies cannot be disabled without affecting platform functionality.
• Performance & Analytics Cookies: Helping us understand how members interact with the platform — which pages are most visited, average session duration, and where members encounter difficulties. This data is used in aggregate form without identifying individuals.
• Functional Cookies: Saving your preferences and settings — such as display theme, preferred betting limits, and game selections — so you do not need to reconfigure them each time you login.
• Security Cookies: Used to detect suspicious login attempts, verify recognised devices, and protect your account from unauthorised access.

You can manage or delete cookies through your web browser settings at any time. Please note that disabling certain cookies may affect the full functionality of the topx platform.

9 Cross-Border Data Transfers

In operating a digital platform, your personal data may be processed or stored on servers located outside Malaysia. topx ensures that any cross-border data transfer is carried out in compliance with applicable legal requirements:

• Data transfers are only made to countries or regions with a level of data protection equivalent to or greater than that of Malaysia.
• Appropriate data transfer agreements — including standard contractual clauses — are in place with all data recipients outside Malaysia.
• The cloud service providers we use comply with internationally recognized security standards such as ISO 27001 and SOC 2.
• You will be notified of any material changes to our cross-border data transfer practices.

10 Children's Privacy

The topx platform is exclusively for users aged 18 years and above. We do not knowingly or intentionally collect, process, or store any personal data from individuals under the age of 18.

• All members are required to confirm that they are at least 18 years of age during the registration process.
• Our KYC verification process is designed to detect and prevent registration by underage individuals.
• If we become aware that personal data of an underage child has been collected without consent or in error, we will take immediate steps to delete that data and close the account in question.
• Parents or guardians who suspect their child has registered on our platform are advised to contact our support team immediately.

11 Privacy Policy Amendment

Topx reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our business practices, legal requirements, or service improvements. When significant changes are made:

• A clear notice will be displayed on the platform's home page and this Privacy Policy page at least 14 days before any changes take effect.
• Registered members will receive a notification via their registered email address if any changes materially affect the way your data is processed.
• The "Updated" date at the top of this page will be refreshed to reflect the latest version of the policy.
• Previous versions of the Privacy Policy will be archived for reference by members who require them.

Your continued use of the topx platform after any amendments to this Privacy Policy take effect will be deemed as your acceptance of the latest applicable terms.

12 Contact Us About Privacy

If you have any questions, concerns, or complaints regarding how topx handles your personal data, we are ready to listen and assist. You may reach us through the following channels:

• Privacy Email: [email protected] — mark your email subject as "Privacy Enquiry" for faster processing.
• Live Chat: Available 24/7 directly within the topx platform for general privacy and account enquiries.
• FAQ Page: Visit page FAQ us for answers to the most frequently asked questions regarding privacy and account security.

Our response time for privacy-related inquiries is within three (3) business days for general inquiries, and within thirty (30) days for formal data subject rights requests. If you are not satisfied with our response, you have the right to refer your complaint to the Department of Personal Data Protection Malaysia.