Your privacy is a fundamental commitment at top69, not an afterthought. This Privacy Policy explains exactly what personal data we collect, why we collect it, how we use and protect it, and what rights you hold over your information as a Member of the top69 platform.
top69 ("we", "us", "our") operates the online betting and live casino platform accessible at https://top69.cam. This Privacy Policy describes how top69 collects, uses, stores, transfers, and protects the personal data of individuals ("you", "Member", "User") who visit, register on, or otherwise interact with the top69 platform.
top69 primarily serves the Indonesia market and has a Member base drawn from cities including Jakarta, Surabaya, Bandung, Medan, Semarang, Makassar, Yogyakarta, and Bali. This Policy reflects both our international data protection obligations under our licensing framework and our commitment to the privacy rights of our Indonesian Members.
By registering an account with top69, using the platform, or submitting any personal information to us, you confirm that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you should not use the top69 platform.
This Privacy Policy forms part of top69's broader legal framework alongside our Terms & Conditions and Responsible Gaming Policy. In the event of a conflict between this Policy and the Terms & Conditions, the Terms & Conditions shall prevail unless the conflict relates specifically to the processing of personal data, in which case this Privacy Policy governs.
top69 collects the following categories of personal data from Members and platform visitors:
| Category | Examples | Required? |
|---|---|---|
| Identity Data | Full legal name, date of birth, nationality, KTP (national ID) number, selfie photo | Mandatory (KYC) |
| Contact Data | Email address, mobile phone number, registered correspondence address | Mandatory |
| Financial Data | Bank account numbers (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI), e-wallet IDs (OVO, DANA, GoPay), transaction history, deposit and withdrawal amounts in IDR | Mandatory |
| Account Data | Username, encrypted password, account creation date, session history, balance, wager history, bonus claims | Mandatory |
| Technical Data | IP address, browser type and version, device type and operating system, time zone (WIB/WITA/WIT), cookie identifiers | Automatic |
| Usage Data | Pages visited, game titles played, bet types placed, session duration, click patterns, search queries within the platform | Automatic |
| Communications Data | Records of live chat sessions, support email correspondence, feedback submissions | When contacting support |
| Responsible Gaming Data | Self-exclusion requests, deposit limit settings, session time preferences, self-assessment quiz responses (anonymized) | When tools are used |
top69 does not collect payment card numbers (Visa, Mastercard) directly. Card-based transactions, where applicable, are processed entirely by PCI-DSS compliant third-party payment gateways that do not transmit full card data to top69's servers.
top69 collects personal data through the following channels:
top69 processes your personal data only for the purposes described below, each of which rests on a recognized legal basis:
| Purpose | Legal Basis |
|---|---|
| Account registration and platform access | Performance of contract (Terms & Conditions) |
| Identity verification (KYC) and age verification (21+) | Legal obligation; performance of contract |
| Processing deposits and withdrawals in IDR to Indonesian bank accounts and e-wallets | Performance of contract |
| Anti-money laundering (AML) and fraud prevention monitoring | Legal obligation; legitimate interests |
| Customer support and complaint resolution | Performance of contract; legitimate interests |
| Responsible gaming monitoring and tool administration | Legal obligation; legitimate interests (player protection) |
| Sending transactional communications (deposit confirmations, withdrawal receipts, KYC status) | Performance of contract |
| Sending promotional communications (bonuses, seasonal offers) | Consent (opt-in marketing preferences) |
| Platform analytics and product improvement | Legitimate interests |
| Compliance with licensing authority reporting obligations | Legal obligation |
top69 does not sell, rent, or trade your personal data to any third party for commercial purposes. We share personal data with third parties only in the following limited and controlled circumstances:
top69 operates as an internationally licensed platform. As a result, your personal data may be transferred to and processed in countries outside of Indonesia, including the jurisdiction in which top69 holds its operating license and the locations of our game provider partners.
When transferring personal data internationally, top69 ensures that adequate safeguards are in place, including data processing agreements that incorporate internationally recognized data protection standards equivalent to those in this Policy. Where a country does not have a legal framework deemed adequate by our licensing authority, we apply contractual protections to ensure your data is handled with the same standard of care applied within top69's primary operating jurisdiction.
Specifically, personal data shared with Indonesian payment partners (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay) remains within Indonesia under Bank Indonesia's regulatory oversight. Personal data shared with international game providers may be processed in their respective data center locations — each operating under binding contractual data protection terms with top69.
top69 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by Applicable Law and our licensing obligations. The following retention periods apply:
Following the expiry of the applicable retention period, personal data is securely and permanently deleted or irreversibly anonymized. Where anonymization is applied, the resulting aggregate data no longer constitutes personal data and may be retained indefinitely for platform analytics.
top69 uses cookies and similar tracking technologies to operate the platform, maintain your session, detect fraud, and understand how Members use our services. The following categories of cookies are used:
top69 does not use third-party advertising or retargeting cookies. We do not place cookies that track your activity across other websites for commercial advertising purposes.
You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will prevent you from logging in to or using the top69 platform. Disabling analytics cookies will not affect your platform experience but will limit our ability to improve the service.
As a Member of the top69 platform, you hold the following rights with respect to your personal data. top69 will respond to all verifiable rights requests within 30 days of receipt. Complex requests may require up to 60 days, in which case we will notify you of the extended timeline within the initial 30-day window.
Request a copy of all personal data top69 holds about you, free of charge.
Request correction of any inaccurate or incomplete personal data in your account profile.
Request deletion of your personal data where there is no overriding legal basis for retention.
Request that processing of your data be suspended while a correction or objection is evaluated.
Receive a structured, machine-readable copy of the data you provided to top69 directly.
Object to processing based on legitimate interests, including direct marketing communications.
To exercise any of these rights, contact top69's Data Protection team by email at support@top69.cam with the subject line "Data Rights Request". Include your registered email address and a description of the right you wish to exercise. We may request identity verification before processing your request to ensure data security.
top69 is strictly an adult-only platform. The minimum age to register and use the top69 service is 21 years of age, consistent with Indonesia's legal minimum age for participation in gambling and wagering activities. top69 does not knowingly collect personal data from individuals under the age of 21.
Age is verified during the KYC process using government-issued identification (KTP). If top69 discovers or has reason to believe that a Member is under 21 years of age, we will immediately suspend the account, void all transactions, withhold any outstanding Balance or Bonus Funds pending investigation, and permanently delete the personal data of the underage individual in accordance with applicable law.
If you are a parent or guardian and believe your child has created an account on top69, please contact us immediately at support@top69.cam. We will take immediate action to close the account and will cooperate fully with any lawful investigation.
top69 implements a multi-layered technical and organizational security framework to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. Our security measures include:
Despite these measures, no data transmission over the internet or digital storage system can be guaranteed as entirely secure. top69 will notify affected Members and relevant authorities promptly in the event of a data breach that poses a risk to their rights and freedoms, in accordance with applicable data breach notification requirements under our licensing framework.
The top69 platform integrates third-party services to deliver its full range of features — including game content from providers such as Evolution Gaming, Pragmatic Play, Spribe, NetEnt, and Microgaming, and payment processing via Indonesian banks (BCA, BRI, BNI, Mandiri) and e-wallet platforms (OVO, DANA, GoPay).
Each third-party service provider engaged by top69 is subject to a binding data processing agreement that restricts their use of any personal data to the specific service they provide to top69. They are not permitted to use top69 Member data for their own marketing purposes or to share it with further parties without top69's explicit authorization.
The top69 platform does not contain links to third-party websites for commercial or advertising purposes. top69 is not responsible for the privacy practices of any external platform or service that a Member may access independently of the top69 platform.
top69 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, platform features, applicable law, or our licensing requirements. When material changes are made, we will notify registered Members by email to their registered address and display a prominent notice on the top69 platform.
For material changes that affect your rights or how we use your personal data, we will provide a minimum of 14 days' advance notice before the updated Policy takes effect, except where changes are required immediately by law or licensing authority directive.
Continued use of the top69 platform following the effective date of an updated Privacy Policy constitutes your acceptance of the revised terms. The "Last Updated" date at the top of this document indicates the effective date of the current version. We encourage you to review this Policy periodically.
For any questions, concerns, or formal requests relating to this Privacy Policy or to the handling of your personal data by top69, please contact our Data Protection team using the details below.
top69 is committed to resolving all privacy concerns promptly and transparently. If you are not satisfied with our response to your privacy inquiry, you may escalate the matter to the data protection supervisory authority under our licensing jurisdiction. Details of the applicable supervisory body are available upon request from our support team.
For Indonesian Members seeking guidance on personal data rights under Indonesian law (Undang-Undang Perlindungan Data Pribadi), top69 encourages consulting local legal counsel for jurisdiction-specific advice alongside our own Policy commitments as described here.
These six commitments define how top69 handles your personal information — built into our systems, not just written in a policy document.
top69 does not sell, rent, or broker your personal data to any third party for commercial, marketing, or advertising purposes — under any circumstances, with no exceptions.
Every data transmission between your device and top69 — login, deposit, withdrawal, KYC upload — is encrypted with 256-bit SSL. Your data in transit is protected at all times.
Documents you submit for identity verification — including your KTP and selfie — are used exclusively for age and identity confirmation. They are encrypted at rest and never shared with advertising partners.
You can request access, correction, restriction, portability, or deletion of your personal data at any time. top69 will respond to all verifiable data rights requests within 30 days.
Promotional communications are sent only with your consent. You can withdraw consent and opt out of all marketing from top69 at any time through your account settings — with immediate effect.
top69 does not use third-party advertising cookies or cross-site tracking technologies. We do not track your activity on other websites and do not share behavioral data with advertising networks.
Contact top69 support directly for any data protection inquiry, or review our Terms & Conditions and Responsible Gaming page to understand the full picture of how top69 protects its Members.