top464 Privacy Policy

1. Introduction

This Privacy Policy ("Policy") applies to all personal data collected and processed by top464 ("top464," "we," "us," or "our") in connection with your use of the top464 online casino and sports betting platform, including the website at top464.com and all associated services, features, and content (collectively, the "Platform").

By registering for a top464 account or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not use the top464 Platform.

This Policy should be read alongside the top464 Terms & Conditions, which govern your use of the Platform generally. Capitalized terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

2. Personal Data We Collect

top464 collects the following categories of personal data from players and platform users:

2.1 Identity & Contact Information

• Full legal name as it appears on your government-issued identification
• Date of birth (used to verify that you meet the 21+ age requirement)
• Nationality and country of residence
• Residential address, including barangay, city, and province
• Email address
• Mobile phone number

2.2 Identity Verification Documents

• Copies of government-issued photo identification (e.g., Philippine passport, driver's license, SSS ID, PhilSys National ID, UMID)
• Proof of address documents (e.g., utility bills, bank statements)
• Proof of payment method ownership where required for KYC purposes

2.3 Financial Information

• GCash account details (mobile number associated with your GCash wallet)
• PayMaya account details
• Bank account details for BPI, BDO, Metrobank, or other supported banks
• Transaction history, including deposit amounts, withdrawal amounts, and dates

2.4 Gaming Activity Data

• Game session history, including games played, wagers placed, and outcomes
• Sports betting history, including markets selected, odds accepted, and results
• Account balance history and bonus usage records
• Responsible gaming tool usage (deposit limits, session reminders, self-exclusion records)

2.5 Technical & Usage Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser information
• Pages visited on the top464 Platform and time spent on each page
• Referring URLs and navigation paths within the Platform
• Cookie identifiers and session tokens

Data Category	Examples	Primary Purpose
Identity & Contact	Name, DOB, email, mobile number	Account creation, KYC, communications
Verification Documents	Government ID, proof of address	Age & identity verification, AML compliance
Financial	GCash number, bank account, transactions	Payment processing, fraud prevention
Gaming Activity	Bets placed, game history, balances	Service delivery, responsible gaming monitoring
Technical & Usage	IP address, device info, cookies	Security, platform performance, analytics

3. How We Collect Your Data

top464 collects personal data through the following means:

• Directly from you – when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotions.
• Automatically – through cookies, server logs, and similar tracking technologies when you access and navigate the top464 Platform.
• From third parties – including identity verification service providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), fraud prevention services, and regulatory authorities where required by law.

4. How We Use Your Personal Data

top464 uses the personal data we collect for the following purposes:

• To create and manage your top464 player account and verify your identity and age (21+ requirement).
• To process deposits and withdrawals in Philippine Peso (PHP) via your chosen payment method.
• To deliver the gaming and sports betting services you request, including slots, live casino, bingo, fishing games, and PBA/NBA/UFC betting markets.
• To comply with our legal and regulatory obligations, including anti-money laundering (AML) requirements and responsible gaming obligations.
• To detect, investigate, and prevent fraud, cheating, bonus abuse, and other prohibited conduct.
• To send you transactional communications, including deposit confirmations, withdrawal notifications, and account security alerts.
• To send you promotional communications about top464 offers and bonuses, where you have consented to receive such communications.
• To monitor and improve the performance, security, and user experience of the top464 Platform.
• To enforce our Terms & Conditions and resolve disputes.

5. Legal Basis for Processing

top464 processes your personal data on the following legal bases under the Data Privacy Act of 2012 of the Philippines:

• Contractual necessity: Processing required to perform our contract with you, including account management, payment processing, and service delivery.
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML obligations, KYC requirements, and regulatory reporting.
• Legitimate interests: Processing necessary for top464's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights.
• Consent: Processing based on your freely given, specific, and informed consent, including the sending of promotional communications. You may withdraw your consent at any time by contacting top464 support.

6. Data Sharing & Disclosure

top464 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, solely to process your financial transactions.
• Identity verification providers: Third-party KYC and age verification service providers engaged by top464 to verify your identity and age.
• Fraud prevention services: Service providers that assist top464 in detecting and preventing fraudulent activity on the Platform.
• Regulatory authorities: Government agencies, law enforcement bodies, and regulatory authorities (including PAGCOR and the Anti-Money Laundering Council) where disclosure is required by applicable law or regulation.
• IT and infrastructure providers: Cloud hosting, data storage, and cybersecurity service providers engaged by top464 to operate and secure the Platform.
• Professional advisers: Lawyers, auditors, and other professional advisers engaged by top464 in connection with the operation of its business.

7. Data Retention

top464 retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, including to satisfy legal, regulatory, accounting, and reporting requirements.

In general, top464 retains player account data and transaction records for a minimum of five (5) years following the closure of your account, in accordance with applicable Philippine anti-money laundering regulations. Identity verification documents are retained for the same minimum period.

Gaming activity data and responsible gaming records are retained for a minimum of three (3) years following account closure. Technical and usage data is typically retained for a shorter period unless required for security investigations or legal proceedings.

When personal data is no longer required for any lawful purpose, top464 will securely delete or anonymize it in accordance with our internal data retention and disposal procedures.

8. Cookies & Tracking Technologies

top464 uses cookies and similar tracking technologies (including web beacons and session tokens) on the Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and improve your experience on the top464 Platform.

8.1 Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in to your top464 account. These cannot be disabled.
• Performance cookies: Used to collect anonymized information about how players use the Platform, helping us identify and fix performance issues.
• Functional cookies: Used to remember your preferences, such as your preferred language and display settings.
• Analytics cookies: Used to understand aggregate usage patterns on the Platform to help us improve our services.

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the top464 Platform. top464 does not use cookies to serve third-party advertising.

9. Data Security

top464 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the top464 Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security assessments and penetration testing of the top464 Platform.
• Two-factor authentication options for player accounts to prevent unauthorized access.
• Incident response procedures for detecting, reporting, and responding to personal data breaches.

10. Your Data Subject Rights

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights with respect to your personal data held by top464:

• Right to be informed: The right to be informed that your personal data is being collected and processed, and the purposes for which it is being used.
• Right of access: The right to request a copy of the personal data top464 holds about you.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data top464 holds about you.
• Right to erasure: The right to request deletion of your personal data, subject to top464's legal and regulatory retention obligations.
• Right to object: The right to object to the processing of your personal data where top464 relies on legitimate interests as the legal basis for processing.
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe top464 has violated your data privacy rights.

To exercise any of these rights, please contact the top464 Data Privacy Officer at [email protected]. top464 will respond to all data subject requests within thirty (30) days of receipt, in accordance with applicable law.

11. Children's Privacy

The top464 Platform is strictly intended for adults aged 21 years and older, in accordance with Philippine gaming regulations. top464 does not knowingly collect personal data from individuals under the age of 21.

If top464 becomes aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the top464 Platform, please contact us immediately at [email protected].

12. Cross-Border Data Transfers

top464 primarily stores and processes personal data within the Philippines. In some cases, personal data may be transferred to and processed by service providers located outside the Philippines, including cloud infrastructure providers and identity verification services.

Where personal data is transferred outside the Philippines, top464 ensures that appropriate safeguards are in place to protect your data in accordance with the Data Privacy Act of 2012, including contractual data protection clauses with the relevant service providers.

13. Updates to This Privacy Policy

top464 reserves the right to update or modify this Privacy Policy at any time. Where changes are material, top464 will notify registered players via email or an on-platform notification prior to the changes taking effect. The revised Policy will be effective from the date of posting on the top464 Platform.

Your continued use of the top464 Platform following the effective date of any update constitutes your acceptance of the revised Privacy Policy. We encourage you to review this page periodically to stay informed of how top464 protects your personal data.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way top464 handles your personal data, please contact our Data Privacy Officer:

Email: [email protected]

top464 aims to acknowledge all privacy-related inquiries within two (2) business days and to resolve them within thirty (30) days of receipt. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.