Privacy Policy — top69

The following definitions apply throughout this Privacy Policy:

This Privacy Policy applies to all personal data collected, stored, or processed by top69 in connection with:

• Account registration and ongoing account management on the top69 Platform;
• Deposits, withdrawals, and all other financial transactions conducted through the Platform;
• Customer support interactions via live chat, email, or any other communication channel;
• Participation in promotions, tournaments, or loyalty programs offered by top69;
• General browsing of the top69.bet website, including anonymized analytics data.

This Policy applies to Players based primarily in Indonesia, though top69's data processing practices are designed to meet internationally recognized data protection standards. If you access the Platform from outside Indonesia, you do so at your own discretion and acknowledge that your data will be processed in accordance with this Policy rather than any locally applicable data protection legislation in your jurisdiction.

top69 collects the following categories of personal data depending on how you interact with the Platform:

top69 collects personal data through the following methods:

• Directly from you: When you complete the account registration form, submit KYC documents, make a deposit or withdrawal request, or contact customer support.
• Automatically: Through cookies, web beacons, and analytics tools that collect technical and behavioral data when you visit or interact with the Platform. See Clause 10 for full details on cookies.
• From third parties: Identity verification data from licensed KYC/AML service providers; fraud screening data from payment processors; device fingerprinting signals from anti-fraud technology partners.
• From payment institutions: Transaction confirmation data from BCA, BRI, BNI, Mandiri, and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) as part of deposit and withdrawal processing.

top69 processes your personal data solely for the following defined purposes:

1. Account management: Creating, maintaining, and securing your top69 account, including authentication, password reset, and two-factor verification;
2. Transaction processing: Facilitating deposits and withdrawals in IDR via supported Indonesian banks and e-wallets, and maintaining an accurate transaction history;
3. KYC and regulatory compliance: Verifying your identity and age (21+) before approving withdrawals, and meeting anti-money laundering (AML) obligations;
4. Fraud prevention and platform integrity: Detecting and investigating suspicious activity, duplicate accounts, bonus abuse, and unauthorized access attempts;
5. Customer support: Responding to queries, complaints, and responsible gaming requests submitted via live chat or email;
6. Responsible gaming: Administering self-exclusion requests, deposit limits, and session-time controls in accordance with the Responsible Gaming program;
7. Platform improvement: Analyzing aggregated and anonymized behavioral data to improve game selection, user experience, and website performance;
8. Direct communications: Sending account notices, deposit confirmations, withdrawal approvals, and — where you have provided consent — promotional communications about bonuses and new game launches.

top69 does not use personal data for automated decision-making that produces legal effects or similarly significant consequences for Players, except where such processing is required for fraud detection, in which case Players may request human review of any automated outcome by contacting support.

top69 processes personal data on the following legal grounds:

• Contractual necessity: Processing required to perform the contract between you and top69 — including account management, transaction processing, and KYC verification — is lawful as it is necessary to deliver the services you have signed up for.
• Legal obligation: AML screening, age verification, and record-keeping are required by the licensing and regulatory framework under which top69 operates. Compliance with these obligations is a legal necessity.
• Legitimate interests: Fraud prevention, platform security, abuse detection, and service analytics are pursued on the basis of top69's legitimate business interests, balanced against your right to privacy. We apply proportionality and only collect data reasonably necessary for these purposes.
• Consent: Marketing communications (promotional emails, bonus notifications) are sent only where you have expressly opted in. Consent can be withdrawn at any time by updating your communication preferences in the account settings panel or by contacting support.

top69 may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment service providers: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata) and e-wallet platforms (OVO, DANA, GoPay, ShopeePay, LinkAja) receive the transaction data required to process your deposits and withdrawals. These institutions are independently regulated financial entities subject to their own privacy obligations.
• KYC and AML partners: Licensed identity verification and anti-money laundering screening providers receive identity documents and personal details solely for the purpose of completing the KYC process required before withdrawals are approved.
• Game content providers: Studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive anonymized session identifiers to enable fair game delivery and RNG certification auditing. They do not receive your identity or financial data.
• Technology and infrastructure providers: Cloud hosting, cybersecurity, and analytics platforms receive technical data to maintain Platform availability and performance.
• Regulatory and law enforcement authorities: top69 will disclose personal data where required to do so by a valid legal order, court process, or regulatory instruction from a competent authority.

All third-party data processors engaged by top69 are required to sign a data processing agreement confirming that they will process personal data solely on top69's instructions, will implement appropriate security measures, and will not sub-process data without top69's prior written approval.

top69 operates internationally and some of our third-party service providers process data in jurisdictions outside Indonesia. Where personal data is transferred outside Indonesia to countries that may not provide an equivalent level of data protection, top69 takes the following safeguards:

• Transfers are made only to processors whose home jurisdiction has been assessed as providing an adequate level of data protection, or under contractual clauses that impose equivalent obligations on the receiving party;
• All international data transfer arrangements are reviewed periodically to ensure ongoing adequacy of protection;
• Players may request information about the specific safeguards applied to the transfer of their personal data by contacting the Data Protection contact provided in Clause 16.

top69 retains personal data only for as long as necessary for the purpose for which it was collected, subject to any longer retention periods required by applicable legal, regulatory, or licensing obligations. The following retention schedule applies:

At the end of the applicable retention period, personal data is either securely deleted or anonymized such that re-identification is not reasonably possible. Where deletion is not immediately practicable (e.g., data stored in backup archives), the data is isolated from active processing and deleted at the next scheduled archive purge cycle.

top69 uses cookies and similar tracking technologies to operate the Platform, personalize your experience, and analyze usage patterns. The following categories of cookies are used:

• Essential cookies: Required for the Platform to function. These include session authentication cookies, CSRF protection tokens, and load-balancing identifiers. These cookies cannot be disabled without impairing Platform functionality.
• Functional cookies: Remember your preferences, such as language settings and last-used payment method, to streamline your experience across sessions.
• Analytics cookies: Collect anonymized data on how Players navigate the Platform — which pages are visited most frequently, where users drop off, and which games attract the most engagement. This data informs platform improvements and is never linked to an identified individual.
• Security and fraud-detection cookies: Support device fingerprinting and bot-detection systems that protect the Platform's integrity and prevent unauthorized access.

top69 does not use third-party advertising cookies or behavioral retargeting pixels. You will not be tracked across external websites by top69's tracking technologies.

You may manage cookie preferences through your browser settings. Disabling essential cookies may impair your ability to log in or complete transactions on the Platform. Disabling non-essential cookies does not affect core Platform functionality.

As a Player on the top69 Platform, you hold the following rights over your personal data. To exercise any of these rights, contact us at the details provided in Clause 16. We will respond within 14 business days of receiving a verifiable request.

Age verification is performed during the KYC process before any withdrawal is approved. top69 reserves the right to request proof of age at any point during an account's lifecycle. If you have reason to believe a minor may have accessed the Platform using fraudulent details, please notify us immediately at the contact details in Clause 16.

top69 implements layered technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption in transit: All data transmitted between your device and top69's servers is protected by TLS 1.2 or higher;
• Encryption at rest: Sensitive data fields (including financial account details and KYC document content) are encrypted in storage using AES-256;
• Access controls: Internal access to personal data is strictly role-based; employees have access only to the data required for their specific function, under the principle of least privilege;
• Penetration testing: The Platform undergoes regular third-party security assessments to identify and remediate vulnerabilities before they can be exploited;
• Incident response: top69 maintains a documented data breach response plan. In the event of a breach affecting Player data, affected Players will be notified promptly with details of the nature of the breach and recommended protective steps.

Despite these measures, no internet transmission is completely secure. Players are advised to maintain strong, unique passwords for their top69 account, enable two-factor authentication (2FA), and contact support immediately if they suspect any unauthorized access to their account.

The top69 Platform does not contain links to third-party websites for advertising or commercial partnership purposes. Any external URLs referenced in support documentation or game provider credits are provided purely for informational context. top69 is not responsible for the privacy practices of any external website, and this Privacy Policy applies solely to data processed by top69 in connection with the top69.bet Platform.

top69 may update this Privacy Policy from time to time to reflect changes in data processing practices, regulatory requirements, or Platform functionality. When material changes are made, the "Last Updated" date at the top of this page will be revised. Where changes significantly affect how we process Player data, we will provide advance notice via email or in-platform notification where reasonably practicable.

Continued use of the top69 Platform following the effective date of any amended Privacy Policy constitutes acceptance of the revised terms. If you do not agree with any changes, you must cease using the Platform and may request account closure in accordance with the Terms & Conditions.

For any questions, concerns, or requests relating to this Privacy Policy, or to exercise any of your data rights described in Clause 11, please contact the top69 Data Protection team through the following channels:

• Email: [email protected] — please include "Privacy Request" in the subject line together with your registered username and the nature of your request. Responses are provided within 14 business days.
• Live Chat: Available 24/7 via the top69 Platform dashboard. For data rights requests, the live chat team will escalate your query to the Data Protection team and provide a reference number for tracking.

top69 provides 24/7 Indonesian-speaking customer support. Players who prefer to communicate in Bahasa Indonesia are welcome to do so via either of the above channels — native Indonesian-speaking agents are always available.