Privacy Policy

Introduction

topanwin ("we", "us", "our") is the operator of the online platform accessible at topanwin.cam. We take the privacy of our players seriously and are committed to handling personal data responsibly in a manner consistent with applicable data protection obligations.

This Privacy Policy ("Policy") describes how topanwin collects, processes, stores, shares and protects personal information obtained from individuals who access or use our platform, including Malaysian residents in Kuala Lumpur, Penang, Johor Bahru, Petaling Jaya, Shah Alam and elsewhere in Malaysia.

By registering a topanwin account, making a deposit using services such as Touch 'n Go eWallet, DuitNow, FPX, Maybank or CIMB, or by otherwise accessing our platform, you confirm that you have read this Policy and understand how your personal data will be handled. If you do not agree with any part of this Policy, you should discontinue use of topanwin immediately and contact us to request account closure.

Definitions

The following terms carry the meanings set out below wherever they appear in this Policy:

Data We Collect

topanwin collects Personal Data across several categories depending on how you interact with the Platform. The categories listed below describe what we may hold about you:

We do not intentionally collect sensitive Personal Data categories such as racial or ethnic origin, religious beliefs or health information unless this appears incidentally within a document submitted for KYC and cannot reasonably be separated.

How Data Is Collected

topanwin collects Personal Data through the following mechanisms:

• Direct Submission: Information you provide when registering, completing KYC, making deposits or withdrawals, updating account settings or contacting support.
• Automated Technical Collection: Data gathered automatically when you access the Platform, including IP addresses, device identifiers, browser logs and session activity recorded by our servers.
• Cookies and Similar Technologies: Session cookies, preference cookies and analytics tools that collect usage and behavioural data when you browse topanwin. See Section 10 for details.
• Payment Processor Data: Confirmation and reference data returned by Malaysian payment partners, including DuitNow, FPX, and participating banks, when a deposit or withdrawal is processed.
• Third-Party Verification Services: Identity verification results from KYC Processors contracted to topanwin where automated document checks are used.

Purposes of Processing

topanwin processes Personal Data for the following stated purposes:

• Account Management: Creating and maintaining your topanwin account, verifying your identity and age (minimum 21 years), and managing login credentials.
• Service Delivery: Processing bets and game transactions, crediting winnings, managing bonus allocations, and providing access to sports markets such as Liga Super Malaysia, EPL and UFC fixtures.
• Payment Processing: Executing deposits and withdrawals through supported Malaysian payment channels, reconciling transactions and maintaining financial records.
• Fraud Prevention and Security: Detecting and investigating suspicious account activity, enforcing restrictions on excluded or banned players, and protecting the integrity of the Platform.
• Legal Compliance: Meeting anti-money laundering (AML) obligations, fulfilling KYC requirements, responding to lawful regulatory or law enforcement requests, and maintaining records required by applicable law.
• Responsible Gambling: Monitoring account behaviour to identify potential problem gambling indicators, administering deposit limits, cooling-off periods and self-exclusion requests.
• Customer Support: Responding to account queries, resolving disputes, processing complaints and maintaining support records.
• Platform Improvement: Analysing aggregated usage data to improve platform navigation, game selection and payment reliability.
• Communications: Sending transactional notifications, security alerts and, where separately consented, promotional updates about topanwin offers.

Legal Basis for Processing

topanwin relies on one or more of the following grounds when processing your Personal Data:

• Contractual Necessity: Processing required to fulfil topanwin's obligations under the Terms and Conditions, including account creation, wagering, payment processing and dispute resolution.
• Legal Obligation: Processing necessary to comply with AML regulations, KYC requirements, tax record obligations and lawful requests from regulatory or law enforcement bodies.
• Legitimate Interests: Processing carried out for fraud prevention, platform security, responsible gambling monitoring and service quality improvement, where such interests are not overridden by your privacy rights.
• Consent: Where you have provided explicit consent — for example, to receive promotional communications — processing will be limited to the scope of that consent. You may withdraw consent at any time by contacting support.

Data Sharing and Disclosure

topanwin does not sell Personal Data to third parties. We may share data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment Service Providers: Malaysian payment partners such as DuitNow, FPX, Touch 'n Go eWallet, Boost, GrabPay and the relevant participating banks (Maybank, CIMB, Public Bank, Hong Leong and others) receive the minimum data required to execute a transaction.
• KYC and Identity Verification Processors: Third-party verification services contracted to topanwin for automated document review and age confirmation. These Processors act under data processing agreements and are not authorised to use the data for their own purposes.
• Fraud Prevention and Risk Services: Industry-standard fraud detection tools that help identify unusual account activity, duplicate registrations or suspicious payment patterns.
• Game Studio Platform Providers: Where game sessions are hosted by third-party studio platforms, session identifiers and game results may be passed to that provider solely to deliver the game.
• Legal and Regulatory Authorities: Courts, regulatory bodies, law enforcement agencies and similar authorities, where topanwin is legally required or permitted to disclose information.
• Professional Advisers: Legal counsel, auditors and compliance consultants operating under professional confidentiality obligations.

Any third-party Processor engaged by topanwin is required to implement appropriate technical and organisational security measures and to process Personal Data only in accordance with topanwin's documented instructions.

Data Retention

topanwin retains Personal Data for as long as necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by applicable law or regulation.

Where data is retained beyond the period of active account use, access is restricted to personnel and systems with a specific operational need. At the end of each applicable retention period, data is securely deleted or anonymised.

Data Security

topanwin implements technical and organisational security measures appropriate to the risk level of each data category. Key security controls in place include:

• HTTPS encryption for all data transmitted between your browser or device and the topanwin Platform.
• Encryption of sensitive stored data, including identity documents and financial records, using industry-standard algorithms.
• Role-based access controls restricting which staff members may access each category of Personal Data.
• Automated monitoring for unusual login patterns, multiple account attempts and suspicious payment activity.
• Regular internal security reviews and periodic assessments of third-party Processor security standards.

While topanwin applies reasonable security measures, no internet-based system is entirely immune from risk. In the event of a data security incident affecting your Personal Data, topanwin will notify affected users in accordance with applicable legal requirements.

Cookies and Tracking Technologies

topanwin uses cookies and similar technologies to operate and improve the Platform. The following categories of cookies may be active during your visit:

• Strictly Necessary Cookies: Required for the Platform to function. These include session cookies that maintain your login state and security tokens. They cannot be disabled without preventing core functionality.
• Functional Cookies: Store your language preference, display settings and other interface choices so you do not need to re-enter them on subsequent visits.
• Analytics Cookies: Collect aggregated, anonymised data about how pages are used, which features are accessed most frequently and where technical errors occur. This data helps topanwin improve the Platform experience.
• Security Cookies: Detect and help prevent fraudulent login attempts, bot activity and unusual geographic access patterns.

topanwin does not use third-party advertising or behavioural tracking cookies that profile your activity across other websites for commercial advertising purposes.

You may manage or delete cookies through your browser settings. Disabling functional or analytics cookies will not prevent access to the Platform but may affect the consistency of certain preferences.

Your Rights

Subject to applicable law and verification of your identity, you have the following rights in relation to Personal Data held by topanwin:

• Right of Access: You may request a copy of the Personal Data topanwin holds about you.
• Right to Correction: You may request correction of inaccurate or incomplete Personal Data.
• Right to Erasure: You may request deletion of Personal Data where topanwin no longer has a lawful basis or legal obligation to retain it.
• Right to Restriction: You may ask topanwin to restrict processing of your data in certain circumstances, for example while a correction or objection request is being assessed.
• Right to Object: You may object to processing carried out on the basis of legitimate interests, including marketing communications.
• Right to Data Portability: Where technically feasible and legally applicable, you may request Personal Data provided directly by you in a structured, machine-readable format.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of the rights above, please contact topanwin through the email address displayed in the footer of this page. We aim to respond to all verifiable requests within 30 calendar days. Requests that are manifestly unfounded or repetitive may be subject to a reasonable administrative charge or may be declined with explanation.

Minors and Age Restriction

topanwin is strictly intended for adults aged 21 years and above. We do not knowingly collect Personal Data from individuals under the age of 21. Age verification is a mandatory step in the account registration and KYC process.

If topanwin becomes aware that Personal Data has been collected from an individual under the age of 21 — whether through inaccurate registration information or any other means — we will take immediate steps to close the associated account, reverse any deposits where possible and delete the relevant data in accordance with our retention obligations.

If you believe a person under 21 has registered a topanwin account, please notify us at the contact details in Section 15.

International Data Transfers

Some of topanwin's service providers and technology partners operate infrastructure located outside Malaysia. Where Personal Data is transferred to servers or processors in other jurisdictions, topanwin takes steps to ensure that appropriate safeguards are in place, including:

• Contractual clauses requiring the recipient to maintain equivalent data protection standards.
• Transferring only the minimum data necessary for the specific service function.
• Periodic review of the security posture of third-party partners located overseas.

By using topanwin, you acknowledge that your Personal Data may be processed in jurisdictions outside Malaysia. We take reasonable measures to ensure that any such processing is conducted lawfully and with appropriate protections in place.

Policy Amendments

topanwin reserves the right to update this Privacy Policy at any time. When material changes are made — such as new categories of data being collected or changes in how data is shared — we will make reasonable efforts to inform registered players via the email address associated with their account or through an on-platform notice.

The revised Policy will be published on this page with an updated effective date. Continued use of the Platform after any amendment takes effect constitutes your acceptance of the revised Policy. We encourage you to review this page periodically.

Contact Us

If you have questions about this Privacy Policy, wish to exercise a data rights request or want to report a data protection concern, please reach us through the following channels. Contact details are provided as plain text only and are not clickable links.

• Website Email: [email protected]
• Live Chat: Available 24/7 through the on-platform chat widget, in English, Bahasa Melayu and Chinese.
• Response Target: Data rights requests are acknowledged within 5 business days and resolved within 30 calendar days where possible.

Please include your full registered name and account username in any data rights request so that we can verify your identity before actioning the request.