Privacy Policy

1. Definitions

For the purposes of this Privacy Policy, the following terms carry the meanings given below:

• "top123," "we," "us," or "our" — the legal entity operating the gaming platform accessible at https://top123.cam.
• "Platform" or "Website" — the top123 website, mobile applications, and all associated digital services.
• "User," "you," or "your" — any individual who visits, registers on, or interacts with the top123 Platform.
• "Personal Data" — any information relating to an identified or identifiable natural person, including name, email address, phone number, payment details, IP address, and device identifiers.
• "Processing" — any operation performed on personal data, including collection, storage, use, disclosure, and deletion.
• "Data Controller" — top123, the entity that determines the purposes and means of processing personal data.
• "Third Party" — any natural person, legal entity, or organization other than you and top123.
• "KYC" — Know Your Customer; the identity-verification process we are obligated to conduct for regulatory and security compliance.
• "Cookies" — small text files placed on your device by a website to remember preferences and enable analytics.

2. Information We Collect

top123 collects personal data through several channels during your registration, account use, and interactions with our platform. We only collect the information necessary to deliver our services, comply with legal obligations, and improve your experience.

2.1 Information You Provide Directly

• Registration Data: Full name, date of birth, email address, phone number, and chosen username when you create an account.
• Identity Verification Documents: Copies of your Indonesian KTP (national identity card), passport, or other government-issued photo identification submitted during KYC verification.
• Address Verification: Proof-of-address documents such as utility bills or bank statements dated within the past three months.
• Payment Information: Bank account numbers (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja), and transaction reference numbers. We do not store full bank credentials on our servers — payment data is tokenized by certified payment processors.
• Communication Data: Messages, complaints, and support requests you submit via live chat, email, WhatsApp, or in-app messaging.
• Responsible Gaming Preferences: Deposit limits, session limits, self-exclusion requests, and other self-regulation settings you configure.

2.2 Information Collected Automatically

• Technical Data: IP address, browser type and version, operating system, device type, screen resolution, and language settings.
• Usage Data: Pages visited, games played, bets placed, session duration, clicks, and navigation paths within the Platform.
• Transaction Data: Records of all deposits, withdrawals, bonuses claimed, wager amounts, wins, losses, and account balance history.
• Location Data: Approximate geographic location derived from your IP address. We do not collect GPS-precise location data unless you explicitly grant permission in a mobile app.
• Cookie and Tracking Data: Session identifiers, analytics tokens, and advertising identifiers as described in Section 6.

2.3 Information Received from Third Parties

• Payment Processors: Confirmation of transaction status (success, failure, pending) and basic payment method details for fraud-prevention purposes.
• Identity Verification Partners: Results of document authenticity checks and sanctions-screening outcomes used to complete KYC.
• Fraud Prevention Services: Risk scores and flags associated with IP addresses, device fingerprints, or payment methods identified as high-risk.

3. How We Use Your Information

top123 uses personal data for the following purposes. Each purpose is matched to a legal basis described in Section 4.

3.1 Marketing Communications

top123 will only send you promotional emails, SMS messages, or push notifications if you have explicitly opted in to receive marketing communications at the time of registration or through your account settings. You may withdraw your consent and unsubscribe from marketing communications at any time by contacting our customer support team or updating your notification preferences in your account dashboard. Withdrawing marketing consent does not affect our ability to send you transactional communications (deposit confirmations, withdrawal notices, security alerts) that are necessary for the operation of your account.

3.2 Automated Decision-Making

top123 uses automated systems to detect fraud, assess risk, and flag potentially problematic gambling behavior. These systems may automatically suspend account access or flag transactions for manual review without prior human intervention. If an automated decision materially affects you, you have the right to request human review of that decision by contacting our compliance team. We will respond to such requests within 10 business days.

4. Legal Basis for Processing

top123 processes your personal data under one or more of the following legal bases:

• Contract Performance: Processing is necessary to fulfill our obligations under the Terms & Conditions you accepted when registering, including operating your account, processing transactions, and providing gaming services.
• Legal Obligation: We are required to process certain personal data to comply with applicable laws and regulations, including anti-money laundering (AML) requirements, Know Your Customer (KYC) obligations, and responsible gaming regulations.
• Legitimate Interest: We process certain data where it is in our legitimate interests to do so and those interests are not overridden by your privacy rights. This includes fraud prevention, platform security, product improvement, and responsible gaming monitoring.
• Consent: Where we rely on consent — primarily for marketing communications and optional analytics cookies — you may withdraw that consent at any time without affecting the lawfulness of prior processing.

5. Sharing of Personal Data

top123 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share personal data only in the following circumstances:

5.1 Service Providers and Partners

We engage trusted third-party companies to help us operate the platform. These service providers process personal data strictly on our instructions and are contractually bound by confidentiality and data protection obligations. Categories of service providers include:

• Payment Processors: BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, OVO, DANA, GoPay, ShopeePay, and LinkAja for processing deposits and withdrawals.
• Identity Verification Providers: Third-party KYC vendors that verify the authenticity of identity documents and screen against sanctions lists.
• Fraud Prevention Services: Vendors that analyze transaction patterns and device data to identify and prevent fraudulent activity.
• Game Providers: Software studios such as Evolution Gaming, Pragmatic Play, NetEnt, and Microgaming receive session tokens and anonymized user identifiers necessary to deliver games. They do not receive your full name, payment details, or identity documents.
• Cloud and Hosting Providers: Infrastructure partners who host our servers, databases, and application environments under strict data processing agreements.
• Customer Support Tools: Live chat and helpdesk software providers who process your support conversations on our behalf.
• Analytics Providers: Web analytics platforms that help us understand user behavior in aggregate. Where possible, we use anonymized or pseudonymized data for analytics purposes.

5.2 Legal and Regulatory Disclosure

top123 may disclose personal data to law enforcement agencies, regulatory bodies, courts, or other government authorities where we are legally required to do so, including:

• Responding to lawful requests, court orders, or subpoenas.
• Reporting suspicious transactions to financial intelligence authorities under AML obligations.
• Complying with licensing requirements and regulatory audits.
• Cooperating with investigations into fraud, money laundering, or other criminal activity.

5.3 Business Transfers

In the event that top123 undergoes a merger, acquisition, sale of assets, or corporate restructuring, your personal data may be transferred as part of that transaction. We will provide reasonable notice before your personal data becomes subject to a materially different privacy policy and will ensure the acquiring entity agrees to honor the protections described in this Policy.

5.4 Inter-Operator Information Sharing

Where legally permitted, top123 may share information about players who have breached our Terms & Conditions, engaged in fraud, or been self-excluded with other gaming operators to protect the integrity of the online gaming ecosystem and support responsible gaming efforts across the industry.

6. Cookies and Tracking Technologies

top123 uses cookies and similar tracking technologies to operate the platform effectively, personalize your experience, and analyze usage patterns. Below is a breakdown of the cookie categories we use:

6.1 Strictly Necessary Cookies

These cookies are essential for the platform to function and cannot be disabled. They enable core features such as secure login session management, account balance display, bet placement, and payment processing. No personal data collected via strictly necessary cookies is used for marketing purposes.

6.2 Functional Cookies

Functional cookies remember your preferences — such as your preferred language, display settings, and notification preferences — so you do not have to re-enter them each visit. These cookies improve usability but are not strictly required for the platform to operate.

6.3 Analytics Cookies

We use analytics cookies to understand how users navigate the platform, which games are most popular, and where technical issues occur. Analytics data is aggregated and anonymized where possible. This helps us improve platform performance and user experience.

6.4 Marketing and Retargeting Cookies

With your consent, we may use cookies to deliver personalized promotions and track the effectiveness of marketing campaigns. You can withdraw consent for marketing cookies at any time by updating your browser settings or contacting our support team.

6.5 Managing Your Cookie Preferences

Most modern browsers allow you to control cookie settings via their built-in privacy tools. You can typically block or delete cookies by modifying browser settings. Please note that disabling strictly necessary cookies will prevent you from logging in and using core platform features. For detailed browser-specific instructions, consult your browser's help documentation.

7. Data Security

top123 implements robust technical and organizational measures to protect your personal data against unauthorized access, accidental loss, alteration, or destruction. Our security framework includes:

7.1 Technical Safeguards

• 256-bit SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted using the same standard employed by Indonesian banks.
• Data Encryption at Rest: Sensitive personal data stored in our databases is encrypted at rest using AES-256 encryption.
• Payment Tokenization: Bank account and e-wallet details are tokenized by certified payment processors; full credentials are never stored on our servers.
• Two-Factor Authentication (2FA): Available for all accounts to add an extra layer of protection beyond username and password.
• Firewalls and Intrusion Detection: Multi-layer network security including firewalls, intrusion detection systems, and real-time threat monitoring.
• Regular Penetration Testing: Independent security experts conduct periodic penetration tests to identify and remediate vulnerabilities.

7.2 Organizational Safeguards

• Access to personal data is restricted on a strict need-to-know basis. Staff access is logged, monitored, and reviewed regularly.
• All employees and contractors with access to personal data are bound by confidentiality agreements and receive data protection training.
• We maintain a formal data breach response plan and will notify affected users and relevant authorities in the event of a breach that poses a risk to your rights.

8. Data Retention

top123 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws and regulations. Our standard retention periods are as follows:

When personal data is no longer required, it is securely deleted or anonymized in a manner that prevents reconstruction of the original information. Anonymized data may be retained indefinitely for statistical and analytical purposes.

9. Your Rights Over Your Personal Data

As a user of the top123 platform, you hold the following rights in relation to your personal data. To exercise any of these rights, contact our privacy team via email at [email protected] with the subject line "PRIVACY REQUEST." We will respond within 30 days and may request proof of identity before processing your request.

9.1 Right of Access

You have the right to request a copy of the personal data top123 holds about you, along with information about how it is being used, where it came from, and with whom it has been shared. We will provide this information free of charge in a structured, commonly used format.

9.2 Right to Rectification

If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected or updated. You can update basic account information (email address, phone number, notification preferences) directly through your account settings. For changes to identity documents, please contact our KYC team.

9.3 Right to Erasure ("Right to Be Forgotten")

You may request that we delete your personal data where it is no longer necessary for the purpose it was collected, where you have withdrawn consent and no other legal basis applies, or where the data was processed unlawfully. Please note that we may be legally required to retain certain data (such as financial transaction records) even after an account is closed, in which case erasure requests will be fulfilled to the maximum extent permitted by law.

9.4 Right to Restriction of Processing

You have the right to request that we restrict the processing of your personal data in certain circumstances — for example, while we investigate a dispute about data accuracy or while assessing a legitimate-interest objection.

9.5 Right to Data Portability

Where processing is based on your consent or contract performance and is carried out by automated means, you have the right to receive your personal data in a structured, machine-readable format and to request its transfer to another service provider where technically feasible.

9.6 Right to Object

You have the right to object to processing of your personal data where we rely on legitimate interest as the legal basis. You also have an absolute right to object to the use of your data for direct marketing, including profiling for marketing purposes. Upon receiving such an objection, we will immediately cease using your data for direct marketing.

9.7 Rights Related to Automated Decision-Making

You have the right not to be subject to decisions made solely by automated processes that produce significant legal or similarly significant effects. If you believe an automated decision has materially affected you, you may request human review as described in Section 3.2.

10. Minors and Age Verification

The top123 platform is strictly intended for adults aged 21 years and older. We do not knowingly collect personal data from individuals under 21. As part of our registration and KYC process, all users are required to confirm their age and provide government-issued identification that verifies they meet the minimum age requirement.

If we become aware that personal data has been collected from a user under the age of 21, we will immediately suspend the account, delete all associated personal data to the extent permitted by law, and refund any deposited funds after completing required AML checks. Any winnings generated by an underage account will be forfeited in accordance with our Terms & Conditions.

Parents or guardians who believe their child has registered on our platform should contact our support team immediately. We will treat such reports as urgent and act swiftly to investigate and remedy the situation.

11. International Data Transfers

To deliver our services, top123 may transfer your personal data to servers and service providers located outside Indonesia. When such transfers occur, we ensure that appropriate safeguards are in place to protect your data, including:

• Contractual data processing agreements with all third-party service providers that impose data protection standards equivalent to those described in this Policy.
• Transfer impact assessments for high-risk cross-border data flows.
• Technical security measures (encryption, access controls) applied regardless of where data is stored or processed.

By using the top123 platform, you acknowledge and consent to the transfer of your personal data to jurisdictions outside Indonesia where our service providers and infrastructure partners operate. We take all reasonable steps to ensure that transfers are handled securely and in accordance with applicable data protection principles.

12. Changes to This Privacy Policy

top123 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When we make changes, we will update the "Last Updated" date at the top of this page. Material changes — those that significantly affect how we collect or use your data — will be communicated to registered users via email notification at least 14 days before the change takes effect.

Your continued use of the top123 platform after the effective date of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the changes, you must stop using the platform and may request account closure and data deletion as described in Section 9.3.

We encourage you to review this Privacy Policy periodically to stay informed about how top123 protects your information.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way top123 handles your personal data, please contact us through any of the following channels. All privacy-related inquiries are handled with strict confidentiality.

• Email: [email protected] (use subject line "PRIVACY REQUEST" for data rights inquiries)
• Live Chat: Available 24/7 on the platform with average response time under 30 seconds
• WhatsApp Support: Available 24/7 for quick privacy-related questions
• Business Hours: Administrative privacy matters are handled 9:00 AM – 6:00 PM WIB (UTC+7), Monday to Friday

We aim to respond to all privacy inquiries within 5 business days. For formal data subject rights requests, we will respond within 30 calendar days as required under applicable data protection principles.