Privacy Policy topx app — Personal Data Protection for Malaysia Members

Introduction

Topx app (hereinafter referred to as "we", "the Platform" or "topx app") operates as a trusted online gaming platform in Malaysia. We understand that personal information is a valuable asset and we are committed to handling it with full responsibility, transparency and professionalism.

This Privacy Policy applies to all personal data you provide to us when registering an account, using platform services, contacting our support team, or interacting with any component of our platform, including the topx app website and mobile app.

By using the topx app platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this policy, please discontinue use of the platform and contact us for further assistance.

Personal Data We Collect

We collect your personal data through several channels — directly when you provide it to us, automatically when you use the platform, and in some cases through trusted third parties such as payment providers and identity verification partners.

Data You Provide Directly

Data Categories	Sample Information	Purpose of Collection
Personal Identity	Full name, date of birth, MyKad number	Identity verification & KYC
Contact Information	Phone number, email address, residential address	Account communications & notifications
Financial Information	Bank account number, bank name, account holder name	Deposit & withdrawal processing
Verification Documents	MyKad copy, verification selfie, bank statement	KYC compliance & fraud prevention
Account Information	Username, password (encrypted), account preferences	Account management & security

Automatically Collected Data

When you use the topx app platform, our systems automatically record certain technical information required to keep the service running safely and smoothly. This includes:

• Device Data: Device type, operating system, phone model, and unique device identifier
• Network Data: IP address, internet connection type, and internet service provider information
• Session Data: Login times, session duration, pages visited and in-platform actions
• Geolocation Data: Approximate location based on IP address for security and geographic compliance purposes
• Game Activity Data: Game records, wagering history, bonus transactions and win statistics

How We Use Your Data

Every piece of data we collect is used for a clear and lawful purpose. We do not process your personal data for purposes unrelated to the services you use. The following are the primary purposes for data use:

• Account Management: Creating, verifying, managing and protecting your topx app account from unauthorised access.
• Transaction Processing: Processing deposits, withdrawals and other financial activities securely and accurately.
• Legal Compliance:Meeting KYC requirements, anti-money laundering (AML) obligations and reporting duties to the relevant authorities in Malaysia.
• Platform Security: Detecting and preventing fraudulent activity, unauthorised access, account abuse and cybersecurity threats.
• Service Improvement: Analysing usage patterns to improve platform performance, user interface and overall gaming experience.
• Support Communications: Answering your enquiries, resolving technical issues and providing assistance through available support channels.
• Promotional Communications: Sending promotional information, bonus offers and platform updates — subject to the notification preferences you set in your account.
• Responsible Gaming: Monitoring gameplay patterns to identify signs of problem gambling and provide appropriate support to members who need it.

Data Sharing & Disclosure

Topx app does not sell, rent or trade member personal data to any third party for marketing or commercial purposes. However, in the course of legitimate platform operations, we may share certain data with the following parties under limited and controlled circumstances:

Trusted Third-Party Service Providers

We engage selected third-party service providers to support platform operations. All providers are bound by strict data protection agreements and are only permitted to process your data under our instructions for the stated purposes. These provider categories include:

• Licensed payment gateway and financial service providers
• Identity verification and KYC service providers
• Certified cloud infrastructure and hosting service providers
• Gaming software and technology platform providers
• Analytics and cybersecurity services

Authorities & Legal Requirements

Topx app will disclose member personal data to the relevant authorities when required by Malaysian law, court order, or direction from a legitimate regulatory body. This includes investigations related to fraud, money laundering or financial crime. In such circumstances, we will comply with applicable legal requirements while seeking to protect member rights to the extent permitted.

Business Transfer

Should topx app be involved in any merger, acquisition or transfer of business assets, member personal data may be transferred as part of that transaction. In such circumstances, members will be notified in advance and the same or stricter privacy policy will continue to apply to your data.

Data Security & Encryption

Topx app continuously invests in industry-grade security infrastructure to protect the personal and financial data of every member. Our security approach is multi-layered — meaning your data is protected by several mutually reinforcing security mechanisms.

• 256-bit SSL/TLS Encryption: All communications between your device and topx app servers are encrypted using the latest SSL/TLS protocols, ensuring no third party can intercept or read your data in transit.
• Static Data Encryption: Sensitive data stored in our databases, including financial information and identity documents, is encrypted using AES-256 encryption that meets international financial industry standards.
• Two-Factor Authentication (2FA): topx app supports and encourages the use of two-factor authentication for all member accounts to add an extra layer of security during login.
• 24/7 Security Monitoring: Our automated monitoring system works around the clock to detect and respond to any suspicious activity in real time.
• Internal Access Controls: Access to members' personal data on our end is strictly limited to staff with a legitimate operational need, and every access is logged for audit purposes.
• Regular Penetration Testing: topx app conducts regular security testing through independent security specialists to identify and remediate any system vulnerabilities before they can be exploited.

Cookies & Tracking Technologies

Topx app uses cookies and similar tracking technologies to enhance the user experience, maintain session security and understand how members interact with our platform. The following are the types of cookies we use:

• Essential Cookies: Required for core platform functions such as login authentication, session management, and security. These cookies cannot be disabled without affecting platform functionality.
• Preference Cookies: Saving your personal preferences such as language, display settings and game preferences so you do not need to reset them each time.
• Analytics Cookies: Helping us understand which pages are visited most frequently, how long members spend on the platform and how they navigate between different sections — all used to improve the user experience.
• Security Cookies: Used to detect suspicious login attempts, verify device identity, and prevent unauthorised access to member accounts.

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

Data Retention & Deletion

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

• Active Account Data: Retained for the duration your account remains active and for a reasonable period after account closure to allow for the resolution of any outstanding claims or disputes.
• Financial Transaction Records: Retained for a minimum of seven (7) years in accordance with Malaysian financial and anti-money laundering legal requirements.
• KYC Documents: Retained for the duration of the active account period plus seven years after account closure, in accordance with compliance requirements.
• Security Logs: Retained for a minimum of twelve (12) months for security investigation and internal audit purposes.
• Support Communication Data: Retained for three (3) years for dispute resolution and service improvement purposes.

Once the retention period expires and there is no legal requirement to retain the data further, topx app will securely delete or anonymise your personal data using methods that ensure it cannot be recovered.

Your Rights as a topx app Member

Under Malaysia's Personal Data Protection Act 2010 (PDPA), you have the following rights regarding the personal data we hold. We are committed to respecting and facilitating the exercise of these rights:

To exercise any of the above rights, please contact the topx app support team via live chat or email. We will process your request within 30 working days from the date we receive your complete request. In complex cases or those involving large volumes of data, we may require additional time and will notify you accordingly.

Children's Privacy

Topx app is a licensed gaming platform operating exclusively for individuals aged 18 and above. We do not knowingly collect or process personal data from individuals under the age of 18.

Should we discover that personal data of an individual under the age of 18 has been collected without proper age verification, we will take immediate steps to delete that data and close the account in question. Parents or guardians who have reason to believe their child has registered on our platform are urged to contact our support team immediately.

Amendments to This Privacy Policy

Topx app reserves the right to update or modify this Privacy Policy from time to time to reflect changes in our data practices, new legal requirements or developments in the services we offer.

You will be notified of any material amendments via your registered email or in-platform notification at least 14 days before those amendments take effect. The last updated date shown at the top of this document reflects the latest version currently in force.

Your continued use of the topx app platform after the effective date of any amendment will be considered your acceptance of the updated terms. You are encouraged to review this page periodically.

Contact Us About Privacy

If you have any questions, concerns or complaints regarding this Privacy Policy or how we handle your personal data, the topx app privacy team is here to help. We are committed to responding to all privacy-related enquiries within a reasonable timeframe.

You can reach us via live chat on the platform or by email at [email protected]. When contacting us regarding privacy matters, please include "Data Privacy Inquiry" in your message subject line so it can be directed to the responsible team.

If you are not satisfied with our response, you have the right to file a complaint with the Department of Personal Data Protection, Malaysia's Ministry of Digital, which is the PDPA regulatory authority in Malaysia.