TopOne Privacy Policy — Your Personal Data Protection

1 Information We Collect

Topone collects various types of information depending on how you interact with our platform. Generally, information is collected in three main ways: information you provide directly, information collected automatically, and information from legitimate third-party sources.

Information You Provide Directly:

• Full name as per identity card or passport
• Date of birth for age limit verification
• Active email address for account communications
• Mobile phone number registered in Malaysia
• Current residential address
• Financial information including bank account or digital wallet details for deposit and withdrawal purposes
• Copy of identification document for the Know Your Customer (KYC) process

Information Collected Automatically:

• IP address and general location information
• Device type, operating system and web browser version used
• Server log data including pages visited, visit times and actions taken
• Cookie information and device identifiers to enhance the user experience
• Transaction history and gaming activity on the platform

2 How We Use Your Data

Every piece of information we collect is used for a clear and legitimate purpose. topone does not use your data beyond what is necessary to provide you with a high-quality service.

• Account Management: Create, verify, and manage your user account, including the KYC process required by law.
• Transaction Processing: Process deposits, withdrawals, and all other financial transactions quickly and securely.
• Security & Fraud Prevention: Detect, investigate, and prevent fraudulent activity, money laundering, and any security threats to the platform and other users.
• Service Communications: Send important notifications related to your account, transactions, policy changes, and security information.
• Platform Improvements: Analyze usage patterns to improve the performance, functionality, and overall experience of our platform.
• Relevant Marketing: Send promotional offers, bonuses, and campaign information relevant to your interests — only if you have given consent to receive marketing communications.
• Legal Compliance: Fulfill legal obligations, regulations, and requirements of relevant authorities.

3 Information Sharing

Topone takes data sharing responsibilities very seriously. We only share user information in situations that are limited, lawful, and fully transparent to you.

• Trusted Service Providers: We share necessary information with payment providers, licensed gaming platforms and technology service providers that help us operate the platform. All parties are bound by strict confidentiality agreements.
• Legal Compliance: We may disclose information when required by courts, government authorities, or regulatory bodies pursuant to valid legal orders or requirements.
• Crime Prevention: In cases where serious criminal activity is suspected, information may be shared with the relevant law enforcement agencies.
• Business Transfers: In the event of a merger, acquisition, or business asset transfer, user data may be transferred to a successor entity subject to equivalent privacy protections.

4 Cookies & Tracking Technologies

Topone uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small data files stored on your device when you visit our website.

Types of cookies we use:

• Essential Cookies: Required for core platform functions such as login sessions and security. These cookies cannot be disabled without affecting platform functionality.
• Functional Cookies: Allows the platform to remember your preferences such as language, display settings, and other options to deliver a more personalized experience.
• Analytics Cookies: Helps us understand how users interact with the platform for improvement purposes. Data collected is in aggregate and anonymized form.
• Performance Cookies: Used to monitor platform performance, detect technical issues and ensure the platform runs smoothly for all users.

You can manage cookie settings through your web browser settings. However, disabling certain cookies may affect the functionality and experience of the TopOne platform.

5 Data Security

The security of your personal data is TopOne's top commitment. We continuously invest in the latest security infrastructure to ensure your information is always protected from any threats.

• 256-bit SSL Encryption: All data communications between your browser and our servers are encrypted using the latest TLS technology, preventing any party from intercepting your information during transmission.
• Strict Access Controls: Only authorised personnel have access to user data, and all access is logged and regularly monitored.
• Regular Security Testing: We conduct regular penetration testing and security audits by independent third parties to identify and address any system vulnerabilities.
• 24/7 Monitoring: Our automated monitoring system operates around the clock to detect any suspicious activity or unauthorized access attempts.
• Data Backup: Your data is securely and regularly backed up to ensure no information is lost due to technical failure or accidents.

While we take all reasonable precautions, no security system is entirely foolproof. We encourage you to also take responsibility for protecting your account by using a strong password and not sharing your login credentials.

6 Data Storage & Retention Period

Topone only retains your personal data for as long as it is necessary for the purposes stated in this Privacy Policy or as required by applicable law.

• Active Account Data: Retained for the duration your account is active and used to provide ongoing services.
• Financial Transaction Records: Retained for a minimum of seven (7) years from the transaction date in accordance with Malaysia's accounting and anti-money laundering legal requirements.
• KYC and Identity Verification Data: Retained for five (5) years after account closure or as required by the relevant authorities.
• Activity & Security Logs: Retained for two (2) years for security audit and investigation purposes if required.
• Marketing Data: Retained until you withdraw consent or request deletion, whichever comes first.

Once the retention period expires, your data will be securely deleted or anonymised using methods that prevent recovery.

7 Your Rights as a User

Under Malaysia's Personal Data Protection Act 2010 (PDPA) and TopOne's internal policies, you have the following rights regarding your personal data:

• Right to Access: You have the right to request a copy of the personal data we hold about you.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete information.
• Right to Erasure: In certain circumstances, you have the right to request the deletion of your personal data.
• Right to Object: You have the right to object to the processing of your data for direct marketing purposes at any time.
• Right to Withdraw Consent: Where data processing is based on your consent, you may withdraw that consent at any time.
• Right to Complain: You have the right to lodge a complaint with the relevant data protection authority if you believe your rights have been violated.

To exercise any of the above rights, please contact our support team. We will process your request within 30 business days. For complex requests, we may require additional time and will notify you accordingly.

8 Children's Privacy

Topone is a platform exclusively for adult users aged 18 and above. We do not intentionally collect, process, or store any personal information from individuals under the age of 18.

If you believe a child has provided their personal information to us without parental or guardian consent, please contact us immediately at [email protected]. We will take immediate action to delete that information and close the relevant account.

9 Third-Party Links

The topone platform may contain links or integrations with third-party services such as payment providers, licensed gaming platforms, and technology service providers. This Privacy Policy applies to the topone platform only.

Topone is not responsible for the privacy practices or content of third-party websites or services that you may access through our platform. We encourage you to read the privacy policy of each third-party service you use separately.

Nevertheless, we ensure that all third-party partners working with topone comply with equivalent data protection standards through binding contractual agreements.

10 Changes to This Privacy Policy

Topone reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the technology we use. All changes will take effect as soon as they are published on this page.

For significant changes, we will notify you via:

• Email notifications to the address registered with your account
• Clear pop-up notifications or banners on the topone platform
• Update the "Last Updated" date at the top of this document

Your continued use of the topone platform after any Privacy Policy changes take effect will be considered your acceptance of those changes. If you do not agree with any changes, you should stop using the platform and may request account closure.

11 Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy or how we handle your personal data, our data protection team is ready to assist.

• Data Protection Email: [email protected]
• Live Chat: Available 24/7 via the chat icon at the bottom right corner of the platform
• Response Time: We aim to respond to all privacy-related enquiries within 5 business days

For more complex inquiries regarding your rights under PDPA or data deletion requests, please clearly state the purpose of your request along with the required identity verification information so we can process your request quickly and accurately.