top64 Privacy Policy

Section 1

Introduction

top64 ("top64", "we", "us", or "our") is committed to protecting the privacy and personal data of every individual who accesses or uses the top64 online casino and sports betting platform available at top64.org and all associated mobile interfaces and related services (collectively, the "Platform").

This Privacy Policy describes how top64 collects, uses, stores, shares, and protects personal data relating to registered players, prospective players, and visitors to the Platform ("you", "your", or "Player"). It also explains the rights available to you in relation to your personal data and how you may exercise those rights.

This Privacy Policy should be read alongside our Terms & Conditions and our Responsible Gaming Policy, both of which are incorporated by reference into this policy. In the event of any inconsistency between this Privacy Policy and any other document on the Platform, this Privacy Policy shall prevail with respect to the handling of personal data.

top64 acts as the data controller in respect of personal data collected through the Platform. If you have any questions about how we handle your data, you may contact us at [email protected].

Section 2

Data We Collect

top64 collects personal data in the following categories. The specific data points collected within each category depend on the features you use and the stage of your relationship with the Platform.

Section 3

How We Collect Your Data

top64 collects your personal data through the following methods:

• Direct collection: Data you actively provide when registering your account, completing KYC verification, making a deposit or withdrawal, contacting customer support, participating in promotions, or updating your account profile;
• Automated collection: Technical and usage data collected automatically when you visit or interact with the Platform, including through cookies, web beacons, pixel tags, and server logs (see Section 8 for full cookie details);
• Third-party collection: Data received from third-party KYC and identity verification providers, payment processors (GCash, Maya, BPI, BDO, Metrobank, USDT, Coins.ph), fraud detection services, and gaming content providers in the course of providing services on the Platform;
• Publicly available sources: In limited circumstances, top64 may supplement your data with information from publicly available sources to assist with fraud prevention or AML compliance obligations.

Section 4

How We Use Your Data

top64 processes your personal data only where a lawful basis for processing exists. The following table sets out our key processing activities, their purposes, and the legal basis on which we rely.

Where top64 relies on your consent as the legal basis for processing, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to the withdrawal. Withdrawal of consent for certain non-essential data processing may limit some features of the Platform but will not affect your ability to play.

Section 5

Data Sharing & Disclosure

top64 does not sell your personal data. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection obligations:

• Payment processors: GCash, Maya, BPI, BDO, Metrobank, Coins.ph, and USDT processing partners, for the purpose of processing your deposits and withdrawals in Philippine Peso;
• KYC and identity verification providers: Third-party services that assist with document verification, age verification, and facial matching as part of our KYC process;
• Fraud prevention and AML service providers: Third-party platforms that analyze transaction patterns, IP addresses, and behavioral signals to detect and prevent fraud and financial crime;
• Game studio and content providers: Providers of the casino games, live dealer games, sports betting, bingo, and slot content available on the Platform may receive session and gameplay data necessary to deliver their services;
• IT and platform infrastructure providers: Cloud hosting, database management, and cybersecurity service providers who process data on our behalf under strict data processing agreements;
• Regulatory and law enforcement authorities: top64 will disclose personal data to competent Philippine regulatory bodies (including PAGCOR where applicable), law enforcement agencies, and courts where we are legally required to do so or where disclosure is necessary to protect the rights, property, or safety of top64, our players, or the public;
• Professional advisers: Lawyers, accountants, auditors, and insurers who provide professional services to top64, subject to professional confidentiality obligations.

All third-party service providers who process personal data on behalf of top64 are required to execute data processing agreements that impose obligations consistent with applicable data protection standards. top64 does not permit its service providers to use your personal data for their own independent purposes.

Section 6

Data Retention

top64 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

As a general guide, top64 applies the following retention periods:

• Active account data: Retained for the duration of your registered account plus a minimum of five (5) years after account closure, in accordance with applicable AML record-keeping obligations;
• KYC and identity verification documents: Retained for a minimum of five (5) years from the date of verification or from the date of account closure, whichever is later;
• Financial transaction records: Retained for a minimum of five (5) years from the transaction date in accordance with applicable financial record-keeping requirements;
• Customer support communications: Retained for two (2) years from the date of the interaction, unless retention is required for longer by virtue of an ongoing dispute or legal proceeding;
• Marketing consent records: Retained for three (3) years from the date consent was last confirmed or until consent is withdrawn, whichever is earlier;
• Technical and log data: Retained for up to twelve (12) months from collection unless retention for longer is necessary for security investigations or legal proceedings.

When personal data is no longer required, top64 will securely delete or anonymize it in accordance with our internal data disposal procedures.

Section 7

Data Security

top64 implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Transport Layer Security (TLS 1.2 or higher) encryption for all data transmitted between your device and the top64 Platform;
• AES-256 encryption for sensitive personal and financial data stored in our systems;
• Role-based access controls ensuring that only authorized top64 personnel with a legitimate business need may access personal data;
• Multi-factor authentication requirements for all top64 staff accessing systems containing personal data;
• Regular penetration testing and vulnerability assessments conducted by qualified security professionals;
• Comprehensive audit logging of all access to and modifications of personal data records;
• Incident response procedures designed to detect, contain, and remediate data security incidents promptly, including notification to affected players where required by applicable law.

While top64 takes every reasonable precaution to secure your data, no digital system is entirely immune to risk. You are responsible for maintaining the confidentiality of your own account credentials. If you suspect unauthorized access to your top64 account, please contact us immediately at [email protected].

Section 8

Cookies & Tracking Technologies

top64 uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyze usage patterns, and deliver relevant content. The following categories of cookies are used on the top64 Platform:

• Strictly necessary cookies: These cookies are essential for the Platform to function and cannot be disabled. They include session management cookies, authentication tokens, and security cookies. No consent is required for strictly necessary cookies;
• Functional cookies: These cookies remember your preferences (such as preferred language, deposit limits display, and odds format) to provide a more personalized experience;
• Analytics cookies: These cookies collect aggregated, anonymized information about how players use the Platform — pages visited, time spent, and navigation patterns — to help us improve Platform performance and user experience;
• Marketing cookies: Where you have given consent, these cookies may be used to track your activity on the Platform and display relevant promotional content about top64 games and offers.

You can manage your cookie preferences through the cookie consent settings available on the Platform. Please note that disabling certain cookie categories may affect the functionality of some Platform features. Most web browsers also provide settings to control cookie behavior at the browser level.

Section 9

Your Data Rights

Subject to applicable Philippine data protection law, you have the following rights in relation to the personal data top64 holds about you:

• Right to be informed: You have the right to be informed about how your personal data is collected and used — which is the primary purpose of this Privacy Policy;
• Right of access: You have the right to request a copy of the personal data top64 holds about you, along with information about how it is being processed;
• Right to rectification: You have the right to request the correction of any inaccurate or incomplete personal data top64 holds about you;
• Right to erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations;
• Right to data portability: Where processing is based on your consent or the performance of a contract, you have the right to receive your personal data in a structured, commonly used, machine-readable format;
• Right to object: You have the right to object to the processing of your personal data where that processing is based on legitimate interests, including profiling for direct marketing purposes;
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please submit a written request to [email protected] with the subject line "Data Rights Request". top64 will acknowledge your request within five (5) business days and aim to respond substantively within thirty (30) calendar days. We may ask you to verify your identity before processing your request.

Section 10

Minors & Age Verification

During the registration process, all applicants are required to confirm their date of birth and agree that they are 21 years of age or older. top64 conducts age verification as part of its KYC process, which may include verification of a government-issued identity document showing the applicant's date of birth.

Where top64 has reason to believe that a player has provided a false date of birth and is under the age of 21, top64 will immediately suspend the account, freeze any account balance, conduct an investigation, and notify the relevant regulatory authority where required. Any winnings accrued by an underage player may be forfeited. The collection and use of personal data obtained from an underage player will be handled in accordance with applicable law, which may require immediate deletion subject to any regulatory reporting requirements.

If you are a parent or guardian and believe that your child under the age of 21 has registered on the top64 Platform, please contact us immediately at [email protected] so that we can investigate and take appropriate action.

Section 11

Marketing Communications

top64 will only send you direct marketing communications — including promotional emails, SMS notifications, and push notifications about bonuses, new games, and special offers — where you have provided your explicit consent to receive such communications during the registration process or subsequently through your account settings.

You may withdraw your consent to receive marketing communications at any time by:

• Clicking the "Unsubscribe" link included in every marketing email sent by top64;
• Updating your communication preferences in the notifications section of your top64 account dashboard;
• Sending a written request to [email protected] with the subject line "Marketing Opt-Out".

Withdrawal of marketing consent will be actioned within ten (10) business days. Please note that even after opting out of marketing communications, you will continue to receive transactional and service communications from top64 that are necessary for the operation of your account — such as deposit confirmations, withdrawal notifications, security alerts, and important policy updates. These operational communications are not marketing and cannot be disabled while your account remains active.

Section 12

Third-Party Services & Links

The top64 Platform may integrate third-party services — such as game studio platforms, live dealer streams, payment gateways, and analytics tools — that operate under their own independent privacy policies. top64 is not responsible for the privacy practices of these third-party providers. We encourage you to review the privacy policies of any third-party services you interact with through the Platform.

All third-party service providers who receive personal data from top64 in the course of providing services on the Platform are required to process that data strictly in accordance with the instructions of top64 and under data processing agreements that impose appropriate technical and organizational security measures. top64 does not permit third-party service providers to use your personal data for their own marketing or commercial purposes.

Section 13

Cross-Border Data Transfers

top64 primarily stores and processes personal data within the Philippines. In some cases, the use of internationally-based service providers (such as cloud infrastructure providers or game studio platforms) may result in personal data being transferred to, stored in, or processed in countries outside the Philippines.

Where such transfers occur, top64 ensures that adequate safeguards are in place to protect your personal data, including:

• Transfers to service providers in countries that offer an adequate level of data protection as determined by applicable Philippine regulatory guidance;
• Use of standard contractual clauses or equivalent data transfer mechanisms that impose data protection obligations on the receiving party;
• Binding corporate rules or equivalent approved frameworks where applicable.

You may request further information about the specific safeguards applicable to any cross-border transfers of your personal data by contacting top64 at [email protected].

Section 14

Changes to This Privacy Policy

top64 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made to this Privacy Policy, top64 will notify registered players by email to the address on file and by displaying a prominent notice on the Platform at least fourteen (14) days before the changes take effect.

The "Last Updated" date at the top of this page will always reflect the date of the most recent revision. We encourage you to review this Privacy Policy periodically. Your continued use of the top64 Platform following the publication of an updated Privacy Policy constitutes acceptance of the updated terms.

If you do not agree to any material change to this Privacy Policy, you have the right to close your account in accordance with the account closure procedure described in the top64 Terms & Conditions. Any personal data processed prior to account closure will be handled in accordance with the version of this Privacy Policy in effect at the time of collection, subject to our legal retention obligations.

Section 15

Contact & Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or the way top64 handles your personal data, please contact us through the following channel:

top64 will acknowledge privacy inquiries within five (5) business days. If you are not satisfied with our response to your privacy complaint, you have the right to escalate your complaint to the relevant Philippine data protection authority or gaming regulatory body.

For responsible gaming inquiries, self-exclusion requests, or deposit limit adjustments, please visit our dedicated Responsible Gaming page. For information about the broader terms governing your use of the top64 Platform, please review our Terms & Conditions.