top1 Privacy Policy

01About This Policy

This Privacy Policy ("Policy") describes how top1 ("top1," "we," "us") collects, uses, stores, and protects the personal information of players ("you," "Player") who register and use the top1 online gaming and betting platform.

top1 is committed to handling your personal data responsibly and transparently. This Policy applies to all interactions with top1, including account registration, deposits and withdrawals in PHP, participation in games such as slots, live casino, eBingo, fish games, and sports betting, as well as any communication with our support team.

This Policy should be read together with the Terms & Conditions, which govern your use of the top1 platform as a whole.

02Information We Collect

top1 collects personal information that is necessary to provide you with a secure, functional gaming account. The categories of information we collect are set out below.

Information you provide directly:

• Full name and date of birth (for identity verification and age compliance)
• Philippine mobile number used for registration and OTP authentication
• Email address, if provided during registration or account recovery
• Government-issued ID details submitted during KYC verification
• Payment information including bank account details or e-wallet identifiers used for PHP deposits and withdrawals

Information collected automatically:

• Device information including device type, operating system, and browser
• IP address and general location data
• Session activity logs including login timestamps, games played, and bets placed
• Cookie and session identifiers used to maintain your logged-in state

03How We Use Your Data

top1 uses your personal information for the following purposes:

04Legal Basis for Processing

top1 processes your personal data on the following grounds:

• Contractual necessity – processing your registration, managing your account, and fulfilling PHP wallet transactions are required to deliver the services you have signed up for.
• Legal obligation – identity verification, age checks, and transaction records may be required by applicable laws and regulations.
• Legitimate interests – platform security, fraud prevention, and anonymised analytics serve top1's legitimate interest in maintaining a safe and functional service for all players.
• Consent – where we send optional marketing communications, we rely on your explicit opt-in consent, which you may withdraw at any time by contacting support.

05Data Sharing and Third Parties

top1 does not sell your personal data to any third party. We may share your information only in the following limited circumstances:

• Payment processors – your payment details are shared with the relevant local payment provider (such as Philippine bank transfer services or supported e-wallet processors) solely to complete your PHP transaction. These providers operate under their own privacy and security standards.
• Identity verification partners – where KYC verification is required, a specialist identity verification service may process your submitted documents. This is done under strict confidentiality and data processing agreements.
• Legal and regulatory requirements – top1 may disclose personal data to law enforcement or regulatory bodies if required to do so by applicable law, court order, or other legal process.
• Platform infrastructure providers – trusted technology partners that host or support the top1 platform may process data on our behalf under contractual obligations that restrict their use of that data.

06Cookies and Tracking Technologies

top1 uses cookies and similar session technologies to keep you logged in, remember your preferences, and maintain the security of your session. The types of cookies we use include:

• Essential cookies – required for the platform to function. These include your authentication session token and security identifiers. The platform cannot operate without these.
• Functional cookies – used to remember your language or display preferences within the top1 platform.
• Analytics cookies – used to collect anonymised information about how players navigate the platform, which helps us identify areas for improvement. This data is aggregated and does not identify you individually.

You can manage cookie settings through your browser. Disabling essential cookies may affect your ability to log in and use the platform normally. top1 does not use cookies to serve third-party advertising on the platform.

07Data Retention

top1 retains your personal data for as long as your account is active and for a reasonable period thereafter, as required to comply with legal obligations, resolve disputes, and maintain accurate transaction records.

Specifically:

• Account and identity data is retained for the duration of your account and for a period following closure as required by applicable law.
• Transaction records including PHP deposits, bets, wins, and withdrawals are kept for a minimum period to satisfy record-keeping obligations.
• Support correspondence is retained for a reasonable period after the issue is resolved.
• Where you have given consent to receive marketing communications, your contact details for that purpose are retained until you withdraw your consent.

When your data is no longer required, top1 will securely delete or anonymise it in a manner that prevents its reconstruction.

08Data Security

top1 takes the security of your personal data seriously. We implement a range of technical and organisational measures to protect your information from unauthorised access, disclosure, alteration, and loss.

Our security measures include:

• SSL/TLS encryption across all platform connections
• OTP-based two-step authentication for account login and sensitive account changes
• Restricted internal access to player data, limited to staff with a direct operational need
• Regular security monitoring and review of platform systems
• Secure storage of sensitive data including identity documents submitted for KYC

While top1 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are also responsible for keeping your own login credentials safe. If you suspect your account has been compromised, contact us immediately at [email protected].

09Your Rights Over Your Personal Data

As a top1 player, you have the following rights in relation to your personal data:

• Access – you may request a summary of the personal data top1 holds about you.
• Correction – if any of your personal data is inaccurate or out of date, you can request that it be corrected.
• Deletion – you may request the deletion of your personal data, subject to top1's legal obligations to retain certain records.
• Withdrawal of consent – where your data is processed on the basis of consent (such as for marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.
• Account closure – you may request to close your top1 account at any time by contacting our support team. Any eligible PHP balance will be processed in accordance with standard withdrawal procedures.

To exercise any of these rights, please contact top1 support at [email protected]. We will respond to your request within a reasonable timeframe. Note that some requests may require identity verification before they can be actioned.

10Children's Privacy

top1 is strictly an adult platform. Registration and use of the top1 platform is only permitted for individuals who are 21 years of age or older, in accordance with Philippine regulations applicable to online gaming.

top1 does not knowingly collect personal data from individuals under the age of 21. If we become aware that a registered account belongs to a person under 21, that account will be closed immediately and any associated data will be handled in accordance with applicable law.

If you believe a minor has registered on top1, please contact us at [email protected] so we can investigate promptly.

11Updates to This Privacy Policy

top1 may update this Privacy Policy from time to time to reflect changes in our data practices, platform features, or applicable legal requirements. When updates are made, the revised Policy will be published on this page with an updated "Last updated" date.

We encourage you to review this page periodically. Continued use of the top1 platform after a revised Policy is published constitutes your acceptance of the updated terms. For material changes, we may also notify registered players directly through their registered mobile number or email address.

12Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please get in touch with the top1 support team: