Privacy Policy

1 Introduction

top77fn ("the Platform", "we", "us", "our") is committed to protecting the privacy and personal data of all users who access or register with our online gaming platform at https://top77fn.cam. This Privacy Policy ("Policy") describes how top77fn collects, processes, stores, shares, and protects personal data in connection with the provision of its Services.

This Policy applies to all registered users and visitors to the top77fn website. It should be read alongside our Terms & Conditions and Responsible Gambling Policy, which are incorporated by reference. By using the top77fn Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

top77fn is the data controller responsible for personal data collected through the Platform. If you have any questions about this Policy or wish to exercise your data rights, please contact us using the details set out in Section 15 of this document.

2 Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information that identifies or can reasonably be used to identify a living individual, either directly or in combination with other data.
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure, or deletion.
• "Data Controller" means the entity that determines the purposes and means of processing personal data — in this context, top77fn.
• "Data Processor" means a third party that processes personal data on behalf of the data controller, under contractual obligation.
• "User" means any individual who has registered an account with, or otherwise accesses, the top77fn Platform.
• "KYC Data" means identity and address verification documents submitted by a user as part of the Know Your Customer process.
• "Cookies" means small text files placed on your device by the Platform for session management, analytics, and functionality purposes.
• "Services" means the full suite of gaming, betting, payment, support, and related features provided through the top77fn Platform.

3 Personal Data We Collect

top77fn collects personal data in the following categories. We collect only data that is necessary for the specific purpose stated:

4 How We Collect Personal Data

top77fn collects personal data through the following means:

• Direct submission: When you register an account, complete KYC verification, make a deposit or withdrawal request, contact our support team, or respond to any platform communication.
• Automated technical collection: Through cookies, server logs, and analytics tools when you browse or interact with the Platform. This includes IP address logging, session tracking, and device fingerprinting for fraud prevention purposes.
• Payment processors: When you transact via Malaysian payment channels (DuitNow, FPX, Touch 'n Go eWallet, Maybank, CIMB, Public Bank, Hong Leong), transaction reference data is shared with top77fn by the relevant payment service provider to confirm the transaction.
• Third-party verification services: Where identity verification is supported by a third-party KYC provider, data submitted for verification may be processed by that provider under their own privacy terms, which top77fn reviews and approves prior to engagement.
• Publicly available sources: In certain fraud investigation or AML compliance scenarios, top77fn may cross-reference publicly available information (such as sanctions lists) against user data.

5 Purposes of Processing

top77fn processes your personal data for the following specific purposes:

• Account Management: Creating, maintaining, and administering your user account, including password recovery, account settings, and preference management.
• Identity & Age Verification: Confirming that you are at least 21 years of age and that your identity matches the information provided during registration, as required for responsible gaming compliance.
• Payment Processing: Facilitating deposits and withdrawals in MYR via your chosen Malaysian payment method, and maintaining accurate transaction records.
• Fraud Prevention & Security: Detecting and preventing fraudulent activity, account takeovers, money laundering, and abuse of bonuses or promotions.
• Regulatory & AML Compliance: Meeting anti-money laundering obligations, sanctions screening, and record-keeping requirements applicable to online gaming platforms.
• Responsible Gambling: Monitoring usage patterns to identify potential problem gambling behaviour, implementing player-requested limits, and facilitating self-exclusion requests.
• Customer Support: Responding to inquiries, resolving disputes, and providing technical assistance via live chat and email.
• Platform Improvement: Using aggregated and anonymised usage data to improve the functionality, performance, and user experience of the top77fn Platform.
• Marketing Communications: Sending you relevant promotional offers and platform updates where you have given your consent to receive such communications. You may withdraw this consent at any time by contacting support or updating your notification preferences.

6 Legal Basis for Processing

top77fn processes your personal data on one or more of the following legal bases, depending on the specific purpose:

• Contractual Necessity: Processing that is necessary to perform the contract between you and top77fn — including account registration, payment processing, and delivery of gaming services.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including KYC/AML requirements, age verification obligations, and record-keeping mandates.
• Legitimate Interests: Processing carried out in pursuit of top77fn's legitimate business interests — including fraud prevention, platform security, and responsible gambling monitoring — where these interests are not overridden by your data protection rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — principally for direct marketing communications. Consent can be withdrawn at any time.

7 Data Sharing & Disclosure

top77fn does not sell, rent, or trade your personal data with any third party for commercial marketing purposes. We may share your personal data with the following categories of recipients, strictly for the purposes set out in this Policy:

• Payment Service Providers: Malaysian payment processors (including those facilitating DuitNow, FPX, Touch 'n Go eWallet, and bank transfer transactions) receive the minimum transaction data necessary to process your payment.
• KYC / Identity Verification Providers: Contracted third-party identity verification services that process your KYC documents on our behalf, bound by data processing agreements with confidentiality and security obligations equivalent to those in this Policy.
• Game Content Providers: Licensed game studios and live dealer operators who power games on the top77fn Platform receive anonymised or pseudonymised session data necessary to deliver game functionality. They do not receive your full personal profile.
• IT Infrastructure Providers: Cloud hosting, server management, and cybersecurity service providers who process data on our behalf under strict data processing agreements.
• Regulatory & Law Enforcement Authorities: Where required by law, court order, or regulatory direction, top77fn may disclose personal data to the relevant authorities. We will always seek to verify the legitimacy of such requests.
• Professional Advisors: Legal, financial, or compliance advisors engaged by top77fn, bound by professional confidentiality obligations.

8 Data Retention

top77fn retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law or regulation. The following general retention periods apply:

• Active Account Data: Retained for the duration of your account's active status plus a minimum of five (5) years following account closure, to satisfy AML record-keeping obligations.
• KYC / Identity Documents: Retained for a minimum of five (5) years from the date of verification, or longer where required by applicable anti-money laundering or gaming regulation.
• Financial Transaction Records: Retained for a minimum of seven (7) years in accordance with applicable financial record-keeping requirements.
• Customer Support Correspondence: Retained for three (3) years from the date of the final interaction, for quality assurance and dispute resolution purposes.
• Technical Logs & IP Records: Retained for up to ninety (90) days for fraud prevention and security monitoring, unless a specific investigation requires longer retention.
• Marketing Consent Records: Retained until consent is withdrawn, plus a reasonable period thereafter to evidence the original consent.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction of the original data.

9 Data Security

top77fn implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include, but are not limited to:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the top77fn Platform.
• Encryption at rest for sensitive personal data stored on our servers, including identity documents and financial information.
• Role-based access controls ensuring that only authorised personnel with a legitimate business need can access personal data.
• Regular security audits, penetration testing, and vulnerability assessments conducted by qualified third-party security specialists.
• Multi-factor authentication requirements for staff accessing systems containing personal data.
• Documented incident response procedures for managing and reporting data security events.

While top77fn takes reasonable steps to protect your data, no internet transmission or electronic storage system is completely secure. You are responsible for maintaining the confidentiality of your account password and for notifying us immediately if you suspect unauthorised access to your account.

10 Cookies & Tracking Technologies

top77fn uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential / Session Cookies: Required for the Platform to function correctly. These enable your login session, cart functionality, and security features. They cannot be disabled without affecting your ability to use the Platform.
• Functional Cookies: Remember your preferences — such as language settings, game display preferences, and responsible gambling limit settings — to provide a personalised experience.
• Analytics Cookies: Collect aggregated and anonymised data about how users navigate the Platform, helping us identify which features are working well and where improvements are needed. These do not identify you personally.
• Security & Fraud Prevention Cookies: Help detect and prevent fraudulent activity by identifying unusual patterns of platform interaction, abnormal login behaviour, or device characteristics associated with known fraud patterns.

top77fn does not use cross-site advertising tracking cookies, behavioural profiling cookies for third-party ad networks, or any cookie that transmits your personal data to an external advertising platform.

You can manage or disable non-essential cookies through your browser settings. Note that disabling essential cookies will impair the functionality of the Platform. For guidance on cookie management, consult your browser's help documentation.

11 Your Data Rights

As a user of the top77fn Platform, you have the following rights in relation to your personal data. To exercise any of these rights, please contact our support team as set out in Section 15:

12 Minors & Age Restriction

The top77fn Platform is strictly for use by adults aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. If we discover that we have inadvertently collected data from an individual under 21, we will immediately suspend the associated account, delete the personal data collected, and if appropriate, report the incident to the relevant authorities.

If you believe that a minor may have registered an account with top77fn, please contact our support team immediately via live chat or at the email address listed in Section 15.

13 International Data Transfers

top77fn's primary operations are directed at users in Malaysia, and the majority of data processing takes place within the region. However, some of our third-party service providers — including certain cloud infrastructure providers and game content studios — may process data in jurisdictions outside Malaysia.

Where personal data is transferred to processors in other jurisdictions, top77fn ensures that such transfers are subject to appropriate contractual safeguards, including data processing agreements that require the recipient to maintain data protection standards no less stringent than those applied by top77fn. We review international transfer arrangements periodically as part of our ongoing data governance programme.

14 Updates to This Privacy Policy

top77fn may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or the structure of the Platform. When we make material changes, we will update the "Last Updated" date at the top of this document and, where the changes significantly affect your rights, notify you via email or an in-platform notification.

We encourage you to review this Privacy Policy periodically. Your continued use of the top77fn Platform following the publication of an updated Policy constitutes your acceptance of the revised terms.

15 Contact Us

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or wish to raise a data protection concern, please contact the top77fn data team through the following channels:

• Live Chat: Available 24/7 directly on the Platform. This is the fastest way to reach us — average response time is under 5 minutes.
• Email: [email protected] (plain text — not a clickable link). Responses provided within 24 hours for general queries; within 5 business days for formal data rights requests.

When submitting a data rights request, please provide your registered email address and a clear description of the request so that we can verify your identity and respond effectively. We may request additional verification before processing a deletion or data portability request.