top64 Privacy Policy

1. Introduction and Scope

This Privacy Policy (the "Policy") applies to all personal information collected by top64 through our website (https://top64.cam), mobile applications, customer support channels, and any other platforms or services we operate (collectively, the "Services"). top64 acts as the data controller for all personal information collected through the Services and is responsible for ensuring compliance with applicable data protection laws.

This Policy describes the types of personal information we collect, the purposes for which we use that information, the circumstances under which we share information with third parties, the security measures we implement to protect your information, and the rights you have regarding your personal data. We are committed to maintaining the highest standards of data protection and transparency in all our data processing activities.

By registering for a top64 account or using any of our Services, you expressly consent to the collection, use, disclosure, and processing of your personal information in accordance with this Policy. If you do not agree with any aspect of this Policy, you must immediately cease using top64 Services and contact us to request deletion of your personal information.

2. Information We Collect

2.1 Account Registration Information

When you register for a top64 account, we collect personal information necessary to create and maintain your account, verify your identity, and comply with legal and regulatory requirements. This information includes:

• Personal Identifiers: Full legal name as it appears on government-issued identification, date of birth, gender, nationality, and residential address including city, province, and postal code.
• Contact Information: Email address, mobile phone number, and alternative contact methods you choose to provide.
• Authentication Credentials: Username, password (stored in encrypted form), and security questions and answers for account recovery purposes.
• Identity Verification Documents: Copies of government-issued identification documents such as Philippine passport, driver's license, national ID, or other acceptable forms of identification; proof of address documents such as utility bills, bank statements, or government correspondence; and photographic identity verification including selfies for facial recognition comparison.
• Financial Information: Payment method details including bank account information, e-wallet account identifiers (GCash, PayMaya), credit or debit card information (processed securely through our payment partners), and transaction history including deposits, withdrawals, wagers, and winnings.

2.2 Automatically Collected Information

When you access or use top64 Services, we automatically collect certain technical and behavioral information necessary for providing, securing, and improving our Services:

• Device Information: Type of device (mobile, tablet, desktop), operating system and version, browser type and version, device identifiers (IMEI, MAC address, advertising ID), screen resolution, and device language settings.
• Network and Connection Data: IP address, internet service provider, connection type, geographic location data derived from IP address, and network performance metrics.
• Usage Information: Pages visited, features used, time spent on different sections of the Services, game play history including games played, bet amounts, game outcomes, and session duration, clickstream data showing your navigation path through our Services, and search queries entered within our platform.
• Communication Records: Records of your interactions with our customer support team including chat transcripts, email correspondence, phone call recordings (where permitted by law), and feedback or surveys you complete.

2.3 Information from Third Parties

We may receive information about you from third-party sources to verify your identity, prevent fraud, and comply with our legal obligations. These sources include payment processors providing transaction verification and fraud detection services, identity verification services confirming the authenticity of your identification documents, credit reference agencies (where applicable), publicly available databases and government registries, and social media platforms if you choose to register or authenticate using social media credentials.

3. How We Use Your Information

top64 uses your personal information for legitimate business purposes necessary to provide, maintain, and improve our Services. We process your data based on the following legal grounds: contractual necessity (to fulfill our obligations under our Terms and Conditions), legal compliance (to meet regulatory and statutory obligations), legitimate interests (to operate, secure, and improve our business), and your explicit consent (for marketing communications and certain data processing activities).

3.1 Core Service Provision

We use your information to provide you with access to top64 Services, including:

• Creating, maintaining, and authenticating your account.
• Processing deposits, withdrawals, and other financial transactions.
• Enabling you to place bets and participate in games.
• Calculating, crediting, and paying out winnings.
• Providing customer support and responding to your inquiries.
• Sending transactional notifications about your account activity, deposits, withdrawals, bonuses, and promotional eligibility.
• Customizing your experience based on your preferences and play history.

3.2 Legal and Regulatory Compliance

We process your information to comply with our legal and regulatory obligations under Philippine law and gaming regulations, including:

• Verifying your age and identity to prevent underage gaming.
• Conducting Know Your Customer (KYC) and anti-money laundering (AML) checks.
• Detecting, preventing, and investigating fraud, money laundering, terrorist financing, and other illegal activities.
• Maintaining records of gaming transactions as required by regulatory authorities.
• Reporting suspicious activities to relevant government agencies.
• Responding to lawful requests from courts, law enforcement, and regulatory bodies.
• Complying with tax reporting obligations and supporting responsible gaming initiatives including self-exclusion programs.

3.3 Security and Fraud Prevention

We use your information to protect the security and integrity of our Services and prevent unauthorized access, fraud, and abuse. This includes monitoring account activity for unusual or suspicious patterns, detecting and preventing multiple account creation and bonus abuse, implementing and improving security measures such as two-factor authentication, investigating potential violations of our Terms and Conditions, and protecting against cyber attacks, unauthorized access, and data breaches.

3.4 Service Improvement and Analytics

We analyze user behavior and preferences to improve top64 Services, including conducting statistical analysis of user behavior and game preferences, testing new features and functionality, optimizing user interface and user experience, developing new games and features based on user demand, improving customer support processes and response times, and personalizing game recommendations and promotional offers.

3.5 Marketing and Communications

With your consent, we may use your contact information to send you marketing communications about bonuses, promotions, new games, and special offers. You have the right to opt out of marketing communications at any time by adjusting your account preferences or clicking the unsubscribe link in our emails. Opting out of marketing communications does not affect transactional emails necessary for account management and service provision.

4. When We Share Your Information

top64 does not sell, rent, or trade your personal information to third parties for their marketing purposes. We share your information only in the limited circumstances described below, and we require all third parties who process your information on our behalf to maintain appropriate security measures and use your data only for the specified purposes.

4.1 Service Providers and Business Partners

We engage trusted third-party service providers to perform functions on our behalf and provide essential services. These partners include:

• Payment Processors: Financial institutions, e-wallet providers, and payment gateways that process your deposits and withdrawals.
• Identity Verification Services: Specialized providers that verify your identity documents and conduct fraud checks.
• Technology Infrastructure Providers: Cloud hosting services, data storage providers, content delivery networks, and IT security firms.
• Customer Support Platforms: Third-party platforms we use to manage customer inquiries and support tickets.
• Analytics Providers: Services that help us understand user behavior and improve our Services.
• Marketing Service Providers: Email delivery services and advertising platforms (only with your consent).

All service providers are bound by contractual obligations to protect your personal information and use it only for the specific purposes for which it was disclosed. We conduct due diligence on all service providers to ensure they maintain appropriate security and privacy standards.

4.2 Legal and Regulatory Disclosure

We may disclose your personal information when required or permitted by law, including to comply with court orders, subpoenas, or other legal processes, to respond to lawful requests from government authorities and law enforcement agencies, to report suspicious transactions to financial intelligence units and regulatory bodies, to comply with tax reporting and audit requirements, to enforce our Terms and Conditions and protect our legal rights, to protect the safety, security, and property of top64, our users, and the public, and to investigate and prevent fraud, money laundering, and other illegal activities.

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to a successor entity. We will notify you of any such transfer and provide you with choices regarding your information where required by law.

4.4 Consent-Based Sharing

We may share your information with third parties when you have provided explicit consent for such sharing. You may withdraw your consent at any time by contacting our privacy team.

5. How We Protect Your Information

top64 implements comprehensive technical, organizational, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. While we strive to protect your information, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

5.1 Technical Security Measures

• Encryption: All sensitive data, including passwords and financial information, is encrypted using industry-standard encryption protocols both in transit (TLS/SSL) and at rest (AES-256).
• Secure Authentication: We employ secure password policies, optional two-factor authentication, and account lockout mechanisms to prevent unauthorized access.
• Firewall Protection: Our systems are protected by advanced firewalls and intrusion detection systems that monitor and block malicious traffic.
• Regular Security Audits: We conduct regular security assessments, penetration testing, and vulnerability scans to identify and remediate potential security weaknesses.
• Secure Development Practices: Our development team follows secure coding standards and conducts security reviews of all new features and updates.

5.2 Organizational Security Measures

• Access Controls: Access to personal information is restricted to authorized personnel who require such access to perform their job functions, using role-based access controls and the principle of least privilege.
• Employee Training: All employees undergo data protection and security awareness training and are bound by confidentiality obligations.
• Incident Response: We maintain an incident response plan to quickly detect, respond to, and remediate security incidents and data breaches.
• Vendor Management: All third-party service providers are evaluated for security practices and bound by data protection agreements.

5.3 Your Security Responsibilities

While we implement strong security measures, you also play a crucial role in protecting your account. We recommend that you use a strong, unique password for your top64 account, enable two-factor authentication if available, never share your password or login credentials with anyone, log out after each session, especially on shared devices, keep your contact information current so we can notify you of security issues, monitor your account for unauthorized activity and report suspicious behavior immediately, and use secure networks and avoid accessing your account on public Wi-Fi without a VPN.

6. Data Retention

top64 retains your personal information for as long as necessary to fulfill the purposes for which it was collected, comply with legal and regulatory obligations, resolve disputes, enforce our agreements, and maintain security and business continuity. Retention periods vary depending on the type of information and the purposes for which it is used.

Data Category	Retention Period
Account Information	Duration of account plus 5 years after closure
Transaction Records	7 years from transaction date (regulatory requirement)
Identity Verification Documents	5 years after account closure or last verification
Communication Records	3 years from date of communication
Marketing Consent Records	Until consent is withdrawn plus 1 year
Technical Logs	90 days to 2 years depending on log type

After the applicable retention period expires, we will securely delete or anonymize your personal information in accordance with our data retention and destruction policies. In some cases, we may retain certain information in anonymized or aggregated form for statistical, research, or analytical purposes.

7. Your Privacy Rights

Under the Data Privacy Act of 2012 and other applicable Philippine privacy laws, you have the following rights regarding your personal information. To exercise any of these rights, please contact our Data Protection Officer using the contact information provided in Section 9.

7.1 Right to Access

You have the right to request access to the personal information we hold about you. Upon verification of your identity, we will provide you with a copy of your personal information in a commonly used electronic format. You may request information about the categories of personal data we collect, the purposes for which we use your data, the categories of third parties with whom we share your data, and the retention periods for different types of data.

7.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. You can update most of your information directly through your account settings. For information that cannot be self-updated, please contact customer support with the necessary corrections and supporting documentation.

7.3 Right to Erasure

You have the right to request deletion of your personal information in certain circumstances, including when the information is no longer necessary for the purposes for which it was collected, when you withdraw consent on which processing was based and there is no other legal ground for processing, when you object to processing and there are no overriding legitimate grounds, or when the information has been unlawfully processed. Note that we may be required to retain certain information to comply with legal obligations, resolve disputes, or enforce our agreements.

7.4 Right to Object and Restrict Processing

You have the right to object to processing of your personal information for direct marketing purposes at any time. You may also request restriction of processing in certain circumstances, such as while we verify the accuracy of disputed information or assess whether our legitimate interests override your objection to processing.

7.5 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that information to another service provider where technically feasible.

7.6 Right to Withdraw Consent

Where we process your personal information based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent before withdrawal.

7.7 Right to Lodge a Complaint

If you believe we have violated your privacy rights or applicable data protection laws, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Contact information for the NPC is available at www.privacy.gov.ph.

8. Cookies and Tracking Technologies

top64 uses cookies, web beacons, and similar tracking technologies to enhance your experience on our Services, analyze usage patterns, and deliver personalized content. Cookies are small text files stored on your device that allow us to recognize you and remember your preferences.

8.1 Types of Cookies We Use

• Essential Cookies: Necessary for the operation of our Services, enabling core functionality such as authentication, security, and network management. These cookies cannot be disabled.
• Performance Cookies: Collect information about how you use our Services to help us improve functionality and user experience. These cookies provide aggregated statistics about website traffic and usage patterns.
• Functional Cookies: Enable enhanced functionality and personalization, such as remembering your language preference, login status, and customized settings.
• Advertising Cookies: Used to deliver relevant advertisements and track advertising campaign effectiveness (only with your consent). These cookies may be set by third-party advertising partners.

8.2 Managing Cookies

Most web browsers allow you to control cookies through their settings. You can configure your browser to reject all cookies, accept only certain cookies, or notify you when a cookie is set. Please note that disabling essential cookies will prevent you from accessing certain features of our Services. Disabling non-essential cookies will not prevent you from using top64 but may affect your experience and the personalization of content.

9. Contact Information and Questions

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Officer through the following channels:

10. Updates to This Privacy Policy

top64 reserves the right to modify, amend, or update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. We will notify you of material changes by posting the updated Policy on our website with a new "Last Updated" date and, where required by law, by sending you an email notification or displaying a prominent notice on the Services.

Your continued use of top64 Services after any changes to this Policy constitutes your acceptance of the updated terms. We encourage you to review this Policy periodically to stay informed about how we protect your information. If you do not agree with any changes to the Policy, you must cease using our Services and may request deletion of your account and personal information.