Privacy Policy TopX —
Your Data Is Fully Protected

Welcome to the TopX Privacy Policy. This document is published by TopX ("We", "Platform") and applies to all users who access or use our platform via the website topx.pw or the official TopX mobile app.

We understand that your trust depends on how we handle your personal information. We are therefore committed to being transparent about our privacy practices and to complying with Malaysia's Personal Data Protection Act 2010 (PDPA) and relevant international standards.

This Privacy Policy outlines:

• The types of personal information we collect from you.
• The purpose and manner in which we use that information.
• Who your information may be shared with under certain circumstances.
• Security measures we take to protect your data.
• Your rights as a data subject and how to exercise them.

By using the TopX platform, you agree to the collection and use of your information as described in this policy. If you do not agree, please discontinue use of our platform.

TopX collects your personal information through several means — directly from you during registration and platform use, automatically via tracking technologies, and in certain cases from trusted third-party sources.

Data you provide directly:

• Full name, date of birth, and identification number (MyKad/passport) at registration and KYC verification.
• A valid Malaysian email address and phone number.
• Bank account or e-wallet details for deposit and withdrawal purposes.
• Residential address during the identity verification process.
• Copies of identification documents submitted for KYC.
• Any information you provide to our customer support team.

Data collected automatically:

• IP address, device type, operating system, and web browser version.
• Login history including timestamps, approximate location, and devices used.
• Wagering activity records, transaction history, and platform usage patterns.
• Cookie and tracking technology data for an improved user experience.

Every piece of information we collect is used for a specific, lawful, and transparent purpose. TopX does not use your data for any purpose that conflicts with its original collection purpose without obtaining fresh consent from you.

• Account Management: Processing registration, verifying identity, enabling secure login, and managing your user profile.
• Transaction Processing: Processing deposits, withdrawals, and all other financial transactions on the platform securely and efficiently.
• Legal Compliance: Meeting KYC, AML (Anti-Money Laundering), and reporting requirements to the relevant authorities where mandated.
• Platform Security: Identifying and preventing fraud, unauthorised access, multi-account usage, and other harmful activities.
• Customer Support: Handling inquiries, complaints, and support requests more effectively.
• Service Improvement: Analysing aggregated usage patterns to improve user experience and platform performance.
• Important Communications: Sending security notifications, terms updates, and important account information.
• Promotions (with consent): Sending relevant promotional offers and bonuses if you have consented to receive them.

TopX does not sell, rent, or disclose your personal data to third parties for commercial purposes. However, in certain limited situations, we may need to share your information with the following parties:

• Payment Service Providers: Payment processors, banks, and e-wallet providers required to complete your transactions. They are bound by strict confidentiality agreements.
• Technology Providers: Companies that provide the technical infrastructure, cybersecurity, and cloud computing services used by our platform. Their access is limited to only the data required.
• Legal Authorities: Law enforcement agencies, courts, or regulatory bodies where we are legally required to do so, or where we believe disclosure is necessary to prevent criminal activity.
• Identity Verification Partners: Third-party KYC service providers that assist us in verifying user identities in accordance with compliance requirements.

In all data sharing instances, TopX ensures that the relevant third parties comply with data protection standards equal to or higher than those we uphold ourselves.

Your data security is our top technical and operational priority. TopX continually invests in cutting-edge security infrastructure to keep your information safe at all times.

Technical security measures we employ:

• Data encryption in transit using TLS 1.3 — the most current security standard for web communications.
• Data encryption at rest using AES-256 — the standard used by financial institutions and government agencies.
• Intrusion detection systems (IDS) and next-generation firewalls that monitor traffic 24/7.
• Two-factor authentication (2FA) is available and encouraged for all users.
• Real-time account activity log monitoring to detect suspicious patterns.
• Regular security testing by independent audit teams.

Organisational measures:

• Access to user data is restricted based on the principle of least privilege — only employees who require access to perform their duties are permitted.
• All staff who handle user data undergo strict and regular data protection training.
• Legally binding confidentiality agreements signed by all staff and third parties with access to our systems.

TopX uses cookies and similar technologies to ensure the platform functions properly, enhance user experience, and analyze platform performance. Cookies are small text files stored on your device by your web browser.

Types of cookies we use:

• Essential Cookies: Required for core platform functions such as login, secure sessions, and security. Cannot be disabled.
• Preference Cookies: Saving your preferences such as language, theme, and display settings for a more personalised experience.
• Analytics Cookies: Collecting aggregated and anonymised usage data to help us understand how users interact with the platform for improvement purposes.
• Security Cookies: Helps identify and prevent fraudulent activity and unauthorised access to your account.

You can manage cookie settings through your web browser settings. Disabling certain cookies may affect platform functionality. More information on managing cookies is available in your account settings.

Under Malaysia's Personal Data Protection Act 2010 (PDPA), you have the following rights regarding your personal data held by us. TopX is committed to respecting and facilitating the exercise of these rights.

The topx platform is strictly for adult users aged 18 and above. We do not knowingly collect or process personal data of individuals under the age of 18.

If we discover that personal data of a minor has been collected without our knowledge, we will take immediate steps to delete that data and close the account in question. Parents or guardians who become aware that their child has provided personal data to TopX without consent are welcome to contact us for prompt action.

TopX reserves the right to amend this Privacy Policy from time to time to reflect changes in our data practices, new legal requirements, or service improvements. All amendments will be communicated to you via:

• In-platform account notification at least 14 days before changes take effect.
• Email notification to your registered email address for significant changes.
• An updated "Last Updated" date displayed at the top of this document.

Continued use of the topx platform after amendments take effect constitutes acceptance of the revised terms. If you do not agree with the amendments, you have the right to close your account before the changes take effect.

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, we encourage you to reach out to us through the following channels:

• Live Chat: Available 24/7 within the TopX platform — the fastest way to get a response.
• Data Protection Email: [email protected] — for written inquiries and formal data subject rights requests.
• Response Time: We aim to respond within 3 business days for general inquiries and within 30 days for formal data subject rights requests.

If you are not satisfied with how we handle your privacy request, you have the right to file a complaint with the Department of Personal Data Protection (JPDP) Malaysia, the regulatory authority for data protection in Malaysia.