Privacy Policy

Introduction

TopSport ("TopSport", "we", "us", "our") operates the online sports betting and casino platform accessible at topsport.cam. We take the protection of your personal data seriously and are committed to handling it with transparency, integrity, and care.

This Privacy Policy ("Policy") describes the types of personal data we collect from users ("you", "User", "Player") of the TopSport platform, the purposes for which we process that data, the parties with whom it may be shared, the period for which it is retained, and the rights available to you in relation to your personal data.

This Policy applies to all personal data collected through the TopSport website, any associated mobile interfaces, customer support communications, and any other interaction you have with TopSport as a registered or prospective player. It should be read in conjunction with our Terms & Conditions, which govern the general use of the Platform.

By registering an account on TopSport or using any of our Services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you should not use the TopSport platform.

Definitions

For the purposes of this Privacy Policy, the following terms shall carry the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, or one or more factors specific to the physical, economic, or social identity of that person.
• "Processing" means any operation or set of operations performed upon personal data, whether or not by automated means, including collection, recording, organisation, storage, adaptation, retrieval, use, disclosure, or erasure.
• "Data Controller" means the entity that determines the purposes and means of processing personal data. TopSport is the Data Controller in respect of all personal data collected from users of the Platform.
• "Data Processor" means a third party that processes personal data on behalf of the Data Controller, under documented instructions from the Data Controller.
• "Data Subject" means the natural person whose personal data is being processed — in the context of this Policy, this is you, the registered or prospective user of TopSport.
• "Cookies" means small data files placed on your device by a website to store information about your session, preferences, or usage behaviour.
• "KYC" means Know Your Customer — the regulatory process of verifying the identity, age, and source of funds of a user, as required under our licensing obligations.

Data Controller Information

TopSport acts as the Data Controller with respect to all personal data collected from users of the platform accessible at topsport.cam. TopSport operates under international online gaming licensing and is subject to the data protection obligations imposed by its licensing jurisdiction.

All enquiries, requests, and complaints relating to the processing of your personal data should be directed to TopSport's designated data protection contact, accessible via the contact details set out in Section 17 of this Policy.

Where TopSport engages third-party service providers to process personal data on its behalf (for example, payment processors, KYC verification providers, or cloud hosting services), those parties act as Data Processors under documented data processing agreements that require them to handle your data in accordance with applicable data protection standards.

Personal Data We Collect

TopSport collects the following categories of personal data, depending on your interaction with the platform:

How We Collect Your Data

TopSport collects personal data through the following channels and mechanisms:

• Direct Submission: Data you provide actively during account registration, KYC document upload, deposit or withdrawal requests, contact form submissions, or live chat interactions.
• Automated Technical Collection: Data collected automatically when you access the Platform, including your IP address, device identifiers, browser session data, and interaction logs — gathered via server logs, cookies, and similar tracking technologies.
• Payment Processors: Transaction confirmation data and payment status information received from our payment processing partners (DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, Hong Leong) when you make a deposit or withdrawal.
• KYC Verification Partners: Identity verification data returned by our certified KYC service providers following document verification checks.
• Third-Party Fraud Detection: Risk signals and device reputation data received from fraud detection services used to protect the Platform and its users.
• Public Sources: Where required for AML or enhanced due diligence purposes, TopSport may verify information against publicly available registers or databases.

Legal Basis for Processing

TopSport processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing that is necessary for the performance of the contract between you and TopSport — including operating your account, processing deposits and withdrawals, and delivering the betting and gaming services you have requested.
• Legal Obligation: Processing required to comply with applicable laws and our licensing obligations — including KYC verification, age verification (21+ minimum), anti-money-laundering checks, and regulatory reporting to competent authorities.
• Legitimate Interests: Processing for purposes that serve TopSport's legitimate business interests, where those interests are not overridden by your privacy rights — including fraud prevention, platform security, responsible gambling monitoring, and internal analytics to improve the Platform.
• Consent: Where we rely on your consent as the legal basis for processing — for example, in relation to optional marketing communications — you may withdraw that consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

How We Use Your Personal Data

TopSport uses the personal data we collect for the following specific purposes:

• To register and maintain your Account, including processing your initial registration, KYC verification, and ongoing account management.
• To process deposits and withdrawals in MYR via your chosen payment method (DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, or Hong Leong).
• To deliver and operate all betting and gaming Services available on the Platform, including sports betting markets (EPL, Liga Super Malaysia, UFC, and others), live casino games, and slot titles.
• To administer our VIP loyalty programme and calculate tier-appropriate cashback, bonuses, and rewards.
• To enforce our 21+ age requirement and responsible gambling obligations, including operating deposit limits, loss limits, session time reminders, cooling-off periods, and self-exclusion.
• To detect, investigate, and prevent fraud, money laundering, match-fixing, and other prohibited activities on the Platform.
• To respond to your customer support requests and maintain records of support interactions for quality and compliance purposes.
• To send you transactional communications — including deposit confirmations, withdrawal notifications, KYC status updates, and security alerts — that are necessary for the operation of your Account.
• To send you promotional communications about bonuses, offers, and events, where you have provided consent or where we have a legitimate interest in doing so. You may opt out of marketing communications at any time.
• To comply with legal and regulatory obligations under our gaming licence, including mandatory reporting to competent regulatory or law enforcement authorities.
• To conduct internal analytics, A/B testing, and platform performance optimisation, using aggregated and pseudonymised data where possible.

Data Sharing & Disclosure

TopSport does not sell your personal data to any third party. We may share your personal data with the following categories of recipient, strictly on a need-to-know basis and under appropriate contractual or legal safeguards:

• Payment Processors: We share the minimum necessary transaction data with our licensed payment processing partners to facilitate deposits and withdrawals — including DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay, Maybank, CIMB, Public Bank, and Hong Leong.
• KYC & Identity Verification Providers: We share identity documents and personal information with certified KYC verification service providers to complete mandatory age and identity verification checks.
• Fraud Prevention & Security Services: We share technical and transactional data with fraud detection and cybersecurity service providers to protect the Platform from abuse, unauthorised access, and financial crime.
• Cloud Infrastructure & Hosting Providers: Our Platform is hosted on secured cloud infrastructure. Hosting providers may have technical access to stored data, subject to strict data processing agreements.
• Regulatory Authorities & Law Enforcement: We are obligated to disclose personal data to our gaming regulator, competent financial intelligence authorities, or law enforcement agencies when required by law, court order, or regulatory instruction. Such disclosures are made without prior notice to the affected user where legally required.
• Professional Advisers: We may share personal data with our legal advisers, auditors, and accountants, subject to professional confidentiality obligations, where necessary for the conduct of our business.

International Data Transfers

As an internationally licensed online gaming platform, TopSport may transfer personal data to countries outside your country of residence for processing and storage purposes. Such transfers may include, for example, the use of cloud hosting infrastructure or KYC verification services located in other jurisdictions.

Where personal data is transferred internationally, TopSport ensures that appropriate safeguards are in place to protect your data, including:

• Transfers to jurisdictions that provide an adequate level of data protection under applicable standards;
• The use of standard contractual clauses or equivalent data transfer mechanisms where required;
• Binding data processing agreements with all third-party processors that include data protection obligations consistent with applicable laws.

By using the TopSport Platform, you acknowledge that your personal data may be transferred to and processed in countries outside Malaysia. TopSport takes all reasonable steps to ensure such transfers are conducted securely and in accordance with applicable data protection obligations.

Data Retention

TopSport retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable laws and our licensing obligations. The following general retention periods apply:

• Active Account Data: Personal data associated with an active Account is retained for the duration of the Account's existence plus any mandatory post-closure retention period.
• Financial and Transaction Records: Deposit, withdrawal, and betting transaction records are retained for a minimum of seven (7) years following the relevant transaction, in compliance with anti-money-laundering and licensing record-keeping requirements.
• KYC Documentation: Identity verification documents are retained for a minimum of five (5) years following Account closure or the completion of the relevant KYC process, whichever is later.
• Customer Support Records: Live chat transcripts and support correspondence are retained for a minimum of two (2) years for quality assurance and compliance purposes.
• Marketing Consent Records: Records of marketing consent and opt-out requests are retained for a minimum of three (3) years following the last interaction.
• Closed Account Data: Following Account closure, personal data is retained for a minimum of seven (7) years to satisfy regulatory and legal obligations, after which it is securely deleted or anonymised.

Upon expiry of the applicable retention period, personal data is securely deleted, destroyed, or anonymised in accordance with TopSport's data disposal procedures.

Cookies & Tracking Technologies

TopSport uses cookies and similar tracking technologies to operate the Platform and enhance your user experience. The following categories of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function correctly. They enable core functionality such as session management, login state, and security token validation. These cookies cannot be disabled without impairing Platform functionality.
• Functional Cookies: These cookies remember your preferences (such as your preferred language or display settings) to provide a more personalised experience. Disabling these cookies may affect the customisation of your experience.
• Analytics Cookies: We use anonymised analytics cookies to understand how users navigate the Platform — which pages are visited most frequently, where users exit, and how long sessions last. This data is used in aggregated form to improve Platform design and performance. We do not use third-party advertising analytics cookies.
• Security Cookies: Short-lived cookies are used to support our fraud detection and bot-prevention measures, including session fingerprinting and CSRF token validation.

You may manage or disable cookies through your browser's settings at any time. Please note that disabling strictly necessary cookies will impair your ability to use core Platform features, including logging in and placing bets. TopSport does not use cross-site tracking cookies or share cookie data with advertising networks.

Your Data Rights

As a data subject, you have the following rights in relation to your personal data held by TopSport. To exercise any of these rights, please contact us using the details in Section 17. We will respond to all verified requests within 30 days of receipt:

Children & Minors

TopSport's Services are strictly intended for individuals aged 21 years and above. We do not knowingly collect or process personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under the minimum age, we will immediately close the relevant Account, forfeit all associated balances in accordance with our Terms and Conditions, and delete the personal data in question.

TopSport employs mandatory KYC age verification as a standard requirement prior to granting full Account access. This ensures, to the maximum extent reasonably practicable, that only eligible adults access gambling-related services on our Platform.

Security Measures

TopSport implements a comprehensive suite of technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the TopSport Platform is encrypted using industry-standard SSL/TLS protocols.
• Encrypted Data Storage: Sensitive personal and financial data stored on our servers is encrypted at rest using AES-256 encryption.
• Access Controls: Personal data is accessible only to TopSport personnel and authorised third-party processors who require it to perform their specific functions. All staff with data access undergo data protection training and are bound by confidentiality obligations.
• Firewall and Intrusion Detection: Our infrastructure is protected by enterprise-grade firewalls and continuously monitored intrusion detection and prevention systems.
• Regular Security Audits: TopSport commissions periodic independent security audits and penetration testing to identify and remediate vulnerabilities in our systems.
• Two-Factor Authentication: 2FA is available to all registered users as an additional Account security measure. We strongly recommend enabling 2FA on your Account.

While TopSport takes all reasonable precautions to safeguard your personal data, no digital system can guarantee absolute security. In the event of a data breach that is likely to result in a risk to the rights and freedoms of affected users, TopSport will notify affected individuals and relevant regulatory authorities in accordance with applicable obligations.

Third-Party Links

The TopSport Platform may contain references or links to third-party websites or services — for example, responsible gambling support organisations or payment provider information pages. This Privacy Policy applies solely to data collected by TopSport and does not extend to any third-party websites, services, or platforms.

TopSport is not responsible for the privacy practices, data handling policies, or content of third-party websites. We recommend that you review the privacy policy of any third-party website you visit through a reference on the TopSport Platform before providing any personal information to that third party.

Amendments to This Policy

TopSport reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, regulatory requirements, or technological developments. When material changes are made, we will provide notice to registered users via email to the address on file and/or through a prominent notice on the Platform for a minimum of 14 days before the updated Policy takes effect.

The version number and effective date shown at the top of this Policy will be updated with each revision. The current version is Version 2.0, effective 1 January 2026. Previous versions of this Policy are available on request.

Your continued use of the TopSport Platform following the effective date of any revised Policy constitutes your acknowledgement and acceptance of the updated terms. If you do not agree with any revision, you should discontinue your use of the Platform and may request Account closure in accordance with our Terms and Conditions.

Contact Us

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or have a concern or complaint about TopSport's data processing practices, please contact us through one of the following channels:

• Live Chat: Available 24/7 directly within the Platform. Our support team can handle data-related enquiries in English, Bahasa Melayu, and Mandarin. Average response time is under 5 minutes.
• Email: For written data subject requests, privacy complaints, or formal enquiries, please contact us at the email address below. We aim to respond to all substantive data requests within 30 days of receipt.

When submitting a data subject request, please include your registered username and a clear description of your request to help us process it efficiently. We may ask for reasonable identity verification before acting on any request, to protect against unauthorised access to your personal data by third parties.

If you are not satisfied with our response to a privacy complaint, you may escalate the matter to the relevant data protection authority under our licensing jurisdiction, or seek independent legal advice in your own jurisdiction.