top77 Privacy Policy

1. Introduction

top77 ("we", "us", "our") operates the online gaming and sports-betting platform accessible at https://top77.cam (the "Platform"). This Privacy Policy sets out, in clear and plain terms, how top77 collects, processes, stores, and protects personal data belonging to registered members and visitors located in Indonesia and elsewhere.

We are committed to handling personal data responsibly, transparently, and in accordance with internationally recognised data-protection standards. By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of it, please discontinue use of the Platform and contact us to close your account.

This Privacy Policy should be read alongside our Terms & Conditions and our Responsible Gaming policy, which together govern your relationship with top77.

2. Personal Data We Collect

2.1 Data You Provide Directly

When you register, verify your account (KYC), make deposits or withdrawals, or contact support, you may provide the following categories of personal data:

• Identity Data: Full legal name, date of birth, nationality, and government-issued ID number (e.g., Indonesian KTP, passport, or driver's licence number).
• Contact Data: Email address, mobile phone number, and residential address in Indonesia.
• Financial Data: Bank account details (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, BSI), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja), and Visa/Mastercard details where applicable. We store only the minimum necessary for transaction processing; full card numbers are never stored on our servers.
• Verification Documents: Copies of identity documents, proof-of-address documents, and selfie photographs submitted during KYC verification.
• Communications Data: Records of live-chat transcripts, emails, or support ticket exchanges between you and our team.

2.2 Data Collected Automatically

When you access the Platform, certain technical data is collected automatically by our systems:

• Device & Technical Data: IP address, browser type and version, operating system, device identifiers, screen resolution, and time-zone settings.
• Usage Data: Pages visited, games played, session duration, bet history, deposit and withdrawal history, and click-path data.
• Location Data: Approximate geographic location derived from your IP address. We do not collect precise GPS location without your explicit consent.
• Cookie Data: Session tokens, preference settings, and analytics identifiers (see Section 5).

3. How We Use Your Personal Data

top77 processes your personal data for the following lawful purposes:

1. Account Management: To create, maintain, verify, and manage your player account, including age and identity verification to ensure compliance with the 21+ eligibility requirement.
2. Service Delivery: To process deposits and withdrawals through local Indonesian payment channels, settle bets and game winnings, and provide access to all features of the Platform.
3. Security & Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, money laundering, identity theft, bonus abuse, and other prohibited activities. This includes automated screening against sanctions and watchlists.
4. Customer Support: To respond to your inquiries, resolve disputes, and provide 24/7 Indonesian-language and English-language assistance through our support team.
5. Responsible Gaming: To monitor gaming activity for indicators of problem gambling and, where appropriate, to contact players proactively with responsible gaming information or to enforce self-exclusion and deposit limit requests.
6. Legal & Regulatory Compliance: To comply with anti-money laundering (AML) obligations, know-your-customer (KYC) requirements, and any lawful requests from competent authorities.
7. Platform Improvement: To analyse aggregate, anonymised usage patterns, improve game performance, fix technical issues, and enhance the user experience.
8. Marketing Communications: To send you personalised promotions, bonus offers, and platform updates — but only if you have opted in to receive them. You may opt out at any time.

4. Sharing and Disclosure of Personal Data

top77 does not sell, rent, or trade your personal data. We may share it with the following categories of third parties only where strictly necessary:

• Payment Processors and Banking Partners: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, BSI) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) receive the minimum data necessary to execute your transactions.
• Identity Verification Providers: Authorised third-party KYC service providers used to verify identity documents and perform AML screening. These providers are contractually bound to process data only on our behalf and in accordance with this Policy.
• Game and Software Providers: Licensed game studios (such as Pragmatic Play, Evolution Gaming, Microgaming, and others) may receive non-personally-identifiable session data necessary for game delivery and audit purposes.
• Customer Support Platforms: Third-party live-chat and ticketing software providers used to deliver 24/7 player support. Data processed through these platforms is subject to the same confidentiality obligations.
• Regulators and Law Enforcement: Where required by law, court order, or at the lawful request of a competent authority, we may disclose personal data without notice. We will notify you unless prohibited by law from doing so.
• Corporate Transfers: If top77 undergoes a merger, acquisition, or sale of assets, your data may be transferred to the acquiring entity, which will be bound by this Privacy Policy or a successor policy that provides equivalent protection.

5. Cookies and Tracking Technologies

top77 uses cookies and similar technologies (local storage, pixel tags) to operate the Platform, personalise your experience, and analyse performance. The types of cookies we use are:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication tokens, security cookies, and load-balancing cookies. These cannot be disabled without breaking the service.
• Functional Cookies: Remember your preferences such as language, currency display (IDR), and game lobby filters so you don't need to reset them each visit.
• Analytics Cookies: Collect anonymised data about how users interact with the Platform — which pages are visited most, where users encounter errors — helping us improve performance. Data is aggregated and does not identify individuals.
• Marketing Cookies: Used only with your consent to measure the effectiveness of promotional campaigns and to deliver relevant offers. You may opt out of marketing cookies at any time through your account settings.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair functionality, including the ability to log in. For mobile users accessing the Platform on Android or iOS, equivalent device-level controls apply.

6. Data Security Measures

top77 implements a layered security architecture to protect your personal data against unauthorised access, disclosure, alteration, and destruction:

• Transport Security: All data in transit is encrypted using TLS 1.2 or higher with 256-bit SSL certificates, preventing interception during transmission.
• Data-at-Rest Encryption: Sensitive fields in our databases — including identity document references and financial account identifiers — are encrypted at rest using AES-256.
• Access Controls: Role-based access control (RBAC) ensures staff can only access data relevant to their operational role. Privileged access is subject to multi-factor authentication and comprehensive audit logging.
• Penetration Testing: We commission regular independent security assessments and penetration tests to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: In the event of a confirmed data breach that poses a material risk to your rights, we will notify affected users within 72 hours of becoming aware, and will cooperate fully with relevant authorities.

While we implement industry-leading controls, no system can guarantee absolute security. You are also responsible for maintaining the confidentiality of your account credentials. Please never share your top77 password with anyone, including individuals claiming to be top77 staff.

7. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy or as required by applicable law. Our standard retention schedule is as follows:

• Active Account Data: Retained for the duration of your account's active status plus a post-closure period of 5 years to comply with anti-money laundering record-keeping requirements.
• Transaction Records: Deposit, withdrawal, and bet history records are retained for a minimum of 5 years following the date of the transaction in accordance with financial regulatory obligations.
• KYC Documentation: Identity verification documents are retained for 5 years from the date of account closure or the last KYC review, whichever is later.
• Support Communications: Chat logs and email correspondence are retained for 3 years to assist in dispute resolution and service quality improvement.
• Marketing Data: Where you have opted in to marketing, your preference and contact data is retained until you opt out. Upon opt-out, marketing data is deleted within 30 days.
• Analytics Data: Aggregated, anonymised analytics data may be retained indefinitely as it cannot be used to identify individuals.

Upon expiry of the applicable retention period, data is securely deleted or irreversibly anonymised. If you request deletion of your data before the minimum retention period has expired, we will restrict processing of that data to compliance purposes only and delete it as soon as the legal obligation allows.

8. Your Data Rights

As a player at top77, you have the following rights with respect to your personal data. To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

• Right of Access: You may request a copy of all personal data we hold about you, including the categories of data, the purposes of processing, and the third parties with whom it has been shared.
• Right to Rectification: If any personal data we hold is inaccurate or incomplete, you may request that we correct or update it without undue delay.
• Right to Erasure ("Right to Be Forgotten"): You may request 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 Restrict Processing: You may request that we restrict processing of your data in certain circumstances, for example while a dispute is being resolved.
• Right to Data Portability: You may request your personal data in a structured, commonly used, machine-readable format for transfer to another service provider.
• Right to Object: You may object to processing of your personal data for direct marketing purposes at any time, with immediate effect.
• 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.

We will not charge a fee for reasonable data requests. We may request proof of identity before fulfilling any request to protect against fraudulent access to another person's data.

9. Minors and Age Restriction

The top77 Platform is strictly intended for adults. You must be at least 21 years of age to register, deposit funds, and participate in any gaming or betting activities on the Platform. We do not knowingly collect personal data from individuals under the age of 21.

If we discover or are notified that a minor has registered an account, we will immediately suspend the account, void all associated transactions, and delete the minor's personal data from our systems as promptly as our legal obligations permit. If you believe a minor has registered on top77, please notify us immediately at [email protected].

We use age-verification controls during the registration process and during KYC review to prevent underage access. Parents and guardians concerned about underage gambling may also utilise third-party parental-control software to block access to gambling websites.

10. Changes to This Privacy Policy

top77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our practices, legal obligations, or operational requirements. The "Last Updated" date at the top of this page indicates when the Policy was most recently revised.

For material changes — those that significantly affect how we collect or use your data — we will provide prominent notice on the Platform and, where we hold your email address, send a direct notification at least 14 days before the changes take effect. Continued use of the Platform after the effective date constitutes acceptance of the revised Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

11. Contact and Data Inquiries

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact our Data Protection team:

• Email: [email protected]
• Live Chat: Available 24/7 through the Platform — request to speak with the Data Protection team
• Response Time: All privacy requests are acknowledged within 48 hours and resolved within 30 days

For general platform questions, our FAQ page covers topics including account management, payment methods, and security. For the full terms governing your use of the Platform, please review our Terms & Conditions.