Privacy Policy — top66

top66 ("we", "us", "our", "the Platform") is committed to protecting the privacy and personal data of all players and visitors who interact with our platform. This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by top66.

We recognize that privacy is a fundamental right. As an online gaming platform serving players across Indonesia — including major cities such as Jakarta, Surabaya, Bandung, Medan, Bali, and Yogyakarta — we take our data protection responsibilities seriously and apply rigorous standards to every aspect of how personal data is handled within our operations.

This policy has been drafted in plain, professional English to ensure that our obligations and your rights are clearly understood. Where we use technical or legal terms, we have provided definitions or plain-English explanations alongside them. If anything in this document is unclear to you, please contact us at [email protected] and our team will be happy to assist.

This Privacy Policy should be read in conjunction with our Terms & Conditions, which govern your contractual relationship with top66, and our Responsible Gaming guidelines, which address specific obligations related to player welfare.

top66 collects the following categories of personal data, depending on your interaction with the platform:

2.1 Identity Data

Full legal name, date of birth, Indonesian National Identity Card (KTP) number or passport number, photograph (where submitted as part of KYC identity verification), and nationality.

2.2 Contact Data

Email address, Indonesian mobile phone number, and residential address (including city and province within Indonesia, e.g., Jakarta, Bandung, Surabaya).

2.3 Account Data

Username, hashed and salted password, account creation date, account status, security question responses, and any voluntary profile information you choose to provide.

2.4 Financial Data

Bank account details for deposits and withdrawals (including BCA, BRI, BNI, Mandiri, and CIMB Niaga account numbers), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja), transaction history, deposit and withdrawal amounts denominated in Indonesian Rupiah (IDR / Rp), and bonus redemption records.

2.5 Gaming and Betting Data

Wager history, game session logs, bet amounts, game outcomes, bonus usage, and any activity relating to sports betting markets, live casino sessions, slot gameplay, crash games, and togel (Indonesia's traditional numbers lottery) draws.

2.6 Technical Data

IP address, browser type and version, device type and operating system, screen resolution, referring URL, pages visited, session duration, and time-zone setting (typically WIB/UTC+7 for our Indonesian player base).

2.7 Communications Data

The content of messages you send to our support team via live chat or email, including any attachments or screenshots you provide in connection with support requests or dispute resolution.

We collect personal data through the following channels and mechanisms:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal request, participating in a promotion, or contacting our support team.
• Automated technologies: As you navigate the platform, we automatically collect Technical Data via cookies, server logs, and similar tracking technologies. See Section 7 for details on our cookies practices.
• Third-party payment processors: When you conduct a transaction via a local Indonesian bank or e-wallet provider, our payment processing partners may share transaction confirmation data with us to reconcile your account balance.
• KYC and fraud-prevention partners: In connection with identity verification and anti-money laundering screening, we may receive data from specialist third-party compliance services that cross-reference the information you provide against relevant databases.
• Public sources: Where permitted and necessary, we may consult publicly available information (such as published sanctions lists) to fulfill our regulatory obligations.

top66 uses the personal data it collects for the following clearly defined purposes:

top66 processes your personal data under the following legal bases, consistent with internationally recognized data protection principles:

• Contractual necessity: Processing required to enter into and perform the contract between you and top66 — including account registration, transaction processing, and service delivery.
• Legal obligation: Processing required to comply with applicable legal and regulatory requirements, including KYC identity verification, anti-money laundering screening, and record-keeping obligations.
• Legitimate interests: Processing carried out for the legitimate business interests of top66, including fraud prevention, platform security, service improvement through analytics, and responsible gaming monitoring, provided that those interests do not override your fundamental privacy rights.
• Consent: Processing for purposes where you have given us your explicit, freely given, and informed consent — principally marketing communications. You may withdraw this consent at any time without affecting the lawfulness of processing carried out before withdrawal.

top66 does not sell, rent, or trade your personal data to any third party. We share data only with the categories of recipients listed below, and only to the extent strictly necessary for each purpose:

6.1 Payment Service Providers

We share the minimum necessary financial data with our payment processing partners to facilitate deposits and withdrawals via Indonesian bank transfer and e-wallet services. These partners are contractually bound to process your data securely and solely for the purpose of executing your transaction.

6.2 Identity Verification and Compliance Partners

We engage specialist third-party KYC and anti-money laundering service providers to assist with identity verification and sanctions screening. These partners receive only the specific data elements required to perform these checks and are prohibited from using your data for any other purpose.

6.3 Technology and Infrastructure Providers

We use third-party cloud hosting, content delivery, and cybersecurity services to operate the platform. These providers act as data processors on our behalf under strict contractual data processing agreements and may only access data as necessary to perform their contracted functions.

6.4 Game Studios and Software Providers

Some games available on top66 are supplied by licensed third-party studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft. These providers may receive technical session data (such as a session token and wager amounts) for the purpose of delivering the game and recording outcomes. They do not receive your identity or contact data.

6.5 Law Enforcement and Regulatory Authorities

We may disclose personal data to law enforcement agencies, regulatory bodies, or other competent authorities where we are required to do so by applicable law, a valid court order, or where disclosure is necessary to prevent or detect crime, including fraud and money laundering.

top66 uses cookies and similar tracking technologies to operate and improve the platform. A cookie is a small text file stored on your device by your browser when you visit a website. We use the following categories of cookies:

7.1 Strictly Necessary Cookies

These cookies are essential for the platform to function. They enable core features such as secure login session management, maintaining your account balance display, and remembering your language and currency preferences. The platform cannot operate correctly without these cookies; they cannot be disabled.

7.2 Performance and Analytics Cookies

These cookies collect anonymized and aggregated data about how players use the platform — such as which pages are visited most frequently, where players navigate after the homepage, and how long sessions typically last. This data is used exclusively to improve platform performance and user experience. No individually identifiable data is shared with third parties through these cookies.

7.3 Functional Cookies

These cookies allow the platform to remember choices you have made — such as your preferred deposit method or whether you have dismissed a notification — in order to provide a more personalized and convenient experience across sessions.

7.4 Managing Cookies

You can control and delete cookies at any time through your browser settings. Please note that disabling certain cookies may affect the functionality of the platform. For guidance on managing cookies in your specific browser, refer to your browser's help documentation. Common browsers used by Indonesian players include Chrome, Firefox, Safari, and Samsung Internet.

top66 retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following retention periods apply as a general guide:

At the end of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be associated with any individual. Anonymized data may be retained indefinitely for statistical and analytical purposes.

top66 applies a layered security framework to protect your personal data against unauthorized access, accidental loss, alteration, or disclosure. Our key security measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and the top66 platform, ensuring that login credentials, financial details, and personal information cannot be intercepted in transit.
• At-rest encryption for all stored personal and financial data, including database-level encryption for KYC documents and transaction records.
• Password hashing using industry-standard cryptographic algorithms. top66 never stores plaintext passwords.
• Multi-factor authentication (MFA) available for player accounts to provide an additional layer of login security beyond username and password.
• Access controls based on the principle of least privilege, ensuring that only authorized personnel whose role requires it can access personal data, and only to the minimum extent necessary.
• Continuous monitoring of platform infrastructure for anomalous activity, intrusion attempts, and data breach indicators, with automated alerting and incident response protocols in place.
• Regular security audits and penetration testing conducted by independent cybersecurity specialists to identify and remediate vulnerabilities before they can be exploited.

As a player on the top66 platform, you hold the following rights in relation to your personal data. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request". We will respond within a reasonable timeframe and will not charge a fee for standard requests.

The top66 platform does not contain links to external third-party websites as a general practice. However, some game interfaces provided by licensed third-party studios may load content from those studios' own servers. top66 is not responsible for the privacy practices of third-party game studios or any other external services. We encourage you to review the privacy policies of any third parties whose services you access in connection with your gaming activity.

top66 strictly prohibits use of the platform by any person under the age of 21 years. We do not knowingly collect or process personal data from individuals under this age. If we discover that personal data has been collected from a person under 21, we will immediately delete that data and suspend the associated account. If you are a parent or guardian and believe that your child may have used the top66 platform, please contact us immediately at [email protected].

top66 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform features. When we make material changes to this policy, we will notify registered players via the email address associated with their account at least 7 days before the revised policy takes effect.

The "Last Updated" date displayed at the top of this page reflects the date of the most recent revision. We encourage you to review this policy periodically. Your continued use of the top66 platform following the effective date of a revised Privacy Policy constitutes your acceptance of the updated terms.

If you have any questions, concerns, or requests regarding this Privacy Policy or the way top66 processes your personal data, please reach out to us using the contact details below:

For account-specific support, including deposit and withdrawal queries, bonus inquiries, and general platform questions, please also visit our FAQ page which covers the most common topics in detail.