PRIVACY POLICY

Privacy Policy top138
Our Commitment to Protecting Your Data

Your privacy is not just a priority — it is our responsibility. This document transparently explains how top138 collects, uses, stores, and protects your personal information.

Updated: 1 January 2026
Quick Summary: top138 only collects data that is strictly necessary to operate the platform safely and efficiently. We do not sell your personal data to third parties. You have the right to access, correct, or request deletion of your data at any time.
1

Introduction

This Privacy Policy explains top138's ("Platform", "We") practices regarding the collection, use, disclosure, and protection of personal information you provide to us when using the top138.pro website and all related services.

Top138 takes our responsibilities under Malaysia's Personal Data Protection Act 2010 (PDPA) and related data protection laws seriously. By using our platform, you agree to the practices described in this Privacy Policy.

This Privacy Policy should be read together with Terms and Conditions us. Any terms not defined here shall have the same meaning as in those Terms and Conditions.


2

Data We Collect

Top138 collects various categories of information depending on how you interact with our platform. Below is a detailed breakdown of the data we collect:

Data Category Example Information Main Purpose
Identity Data Full name, date of birth, MyKad number, selfie photo for KYC Identity verification & compliance
Contact Data Email address, mobile number, residential address Communication & account verification
Financial Data Bank account number, eWallet details, transaction records Payment processing & withdrawals
Technical Data IP address, device type, browser, operating system Platform security & improvement
Usage Data Games played, bets placed, wins, session duration Experience personalization & compliance
Communication Data Support chat logs, emails, and submitted feedback Customer support & improvement

We also automatically collect information when you visit our platform through the use of cookies and similar tracking technologies. This includes pages you visit, links you click, and time spent in each section of the platform.


3

How Your Data Is Used

Top138 uses your personal data solely for legitimate and necessary purposes to operate the platform efficiently and responsibly. The purposes for data use are as follows:

  • Account Management: Create, verify, and manage your account including mandatory KYC processes
  • Transaction Processing: Process deposits, withdrawals, and financial records accurately and securely
  • Platform Security: Detect and prevent fraud, money laundering, and unlawful activity
  • Customer Support: Provide effective assistance when you contact our support team
  • Legal Compliance: Meet obligations under anti-money laundering (AML) laws and other compliance requirements
  • Personalize Experience: Personalize content, offers, and game recommendations based on your preferences
  • Marketing Communications: Send promotional information, bonuses, and platform updates — only with your consent
  • Platform Improvement: Analyze usage patterns to improve functionality and user experience
  • Responsible Gaming: Monitoring gameplay patterns to identify signs of problem gambling and provide appropriate assistance
Our commitment: top138 will not use your data for any purpose beyond those stated above without first obtaining your explicit consent.

4

Legal Basis for Data Processing

Top138 processes your personal data on valid legal grounds in accordance with Malaysia's PDPA. The legal basis we rely on depends on the type of data and the purpose of its use:

  • Contract Performance: Processing necessary to fulfill the agreement between you and top138, including delivering gaming services and processing payments
  • Legal Obligation: Processing required to comply with applicable Malaysian law, including KYC and AML requirements
  • Legitimate Interest: Processing for platform security, fraud prevention, and service improvement purposes that do not override your privacy rights
  • Consent: Processing for direct marketing and promotional communications, where you may withdraw consent at any time

5

Data Sharing with Third Parties

Top138 does not sell, rent, or trade your personal data to any third party for their own marketing purposes. However, we may share your data with certain parties under limited and controlled circumstances:

  • Service Providers: Third parties that help operate our platform, such as payment service providers (FPX, DuitNow, eWallet), gaming technology providers, and cloud infrastructure providers — all bound by strict confidentiality agreements
  • Relevant Authorities: Law enforcement agencies, regulatory bodies, or courts when required by law or a valid court order
  • Identity Verification: Licensed third-party identity verification services to meet KYC requirements
  • Business Transfer: If top138 is involved in a merger, acquisition, or asset sale, user data may be transferred as part of that transaction — you will be notified in advance

Every instance of data sharing is carried out with appropriate contractual safeguards and only to the extent necessary for the stated purpose.


6

Data Storage & Security

Top138 protects your personal data using the latest industry security standards. All data is stored on secure servers with layered protection, including 256-bit SSL encryption for all transmitted data, database-level encryption for sensitive information, strict access controls based on a need-to-know principle, and continuous 24-hour security monitoring.

Top138 retains your personal data for as long as your account is active. Following account closure, we retain transaction records and financial data for a minimum of 7 years in accordance with applicable legal requirements. Data that is no longer needed will be securely deleted or anonymized.

While we employ the best available security measures, no digital system can guarantee 100% absolute security. You also play an important role by keeping your account password confidential.

7

Cookies & Tracking Technology

Top138 uses cookies and similar tracking technologies to enhance your experience on the platform. Cookies are small text files stored on your device when you visit our website.

The types of cookies we use are as follows:

  • Essential Cookies: Required for core platform functions such as login verification and session security. These cookies cannot be disabled.
  • Performance Cookies: Collect information on how you use the platform to help us improve functionality and performance
  • Functional Cookies: Save your preferences such as language and display settings for a more personalized experience
  • Analytics Cookies: Help us understand overall platform usage patterns in aggregate and anonymous form

You can manage cookie settings through your internet browser. Disabling certain cookies may affect the functionality of some sections of the top138 platform.


8

Your Rights as a Data Subject

Under Malaysia's PDPA and our privacy policy, you have the following rights regarding your personal data that we hold:

Right of Access

Request a copy of your personal data we hold, including information on how it is used

Right to Rectification

Request correction of inaccurate or incomplete data via account settings or customer support

Right to Erasure

Request deletion of your data under certain circumstances, subject to legal retention obligations

Right to Object

Object to the processing of your data for direct marketing purposes at any time without providing any reason

Right to Portability

Receive your data in a structured, machine-readable format for transfer to another platform

Right to Restrict Processing

Request that we restrict the processing of your data under certain circumstances while a dispute is being resolved

To exercise any of the rights above, please contact the top138 support team via live chat. We will process your request within 30 working days. In some cases, we may need to verify your identity before processing the request.


9

Children's Data

The top138 platform is exclusively for individuals aged 18 and above. We do not knowingly collect or process personal data of anyone under the age of 18.

If we find that we have collected data from an underage individual, we will take immediate steps to delete that data and close the relevant account. If you believe your child has provided us with data without your knowledge, please contact our support team immediately.


10

Privacy Policy Amendments

Top138 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or technology. Any material amendments will be communicated to you via your registered email or a prominent notice on the platform at least 14 days before the changes take effect.

Your continued use of the top138 platform after any amendments take effect constitutes your acceptance of the updated policy. The latest revision date will always be displayed at the top of this document for your reference.


11

Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy or how top138 handles your personal data, please do not hesitate to contact us through the following channels:

  • Live Chat: Available 24 hours a day, 7 days a week via the chat icon in the corner of the platform
  • Support Email: [email protected] (displayed as plain text only)
  • FAQ: Visit page FAQ us for answers to common questions

We are committed to addressing every privacy-related inquiry seriously and responding within a reasonable timeframe. Your satisfaction and trust are what matter most to us at top138.

How top138 Protects Your Privacy

Data protection is more than a written policy — it is a daily practice we apply at every level of the platform.

256-bit SSL Encryption

All data transmitted between your device and top138 servers is protected by the same military-grade encryption used by leading banking institutions worldwide.

Two-Factor Authentication

An additional security layer through 2FA ensures only you can access your account, even if your password is compromised.

Encrypted Database

Sensitive data such as financial information and identification documents are stored in encrypted databases with strictly enforced access controls at the infrastructure level.

No Data Sales

Top138 has never and will never sell, rent, or share your personal data with advertisers or third parties for their own marketing purposes. This is our unconditional commitment.

24/7 Security Monitoring

Our automated monitoring system works around the clock to detect unusual activity, unauthorized access attempts, and security threats before they can affect your account.

Malaysia PDPA Compliance

Top138 operates in full compliance with Malaysia's Personal Data Protection Act 2010, ensuring your rights as a data subject are respected and protected at all times.

PLAY WITH PEACE OF MIND AT top138

Your Privacy is Protected — Enjoy Your Gaming Experience with Peace of Mind

Register your top138 account today and play with full confidence that your personal and financial data is always under the best protection.

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