At top66, your privacy is treated as a fundamental right, not an afterthought. This Privacy Policy explains exactly what personal data we collect from Indonesian players, why we collect it, how we use and store it, who we may share it with, and what rights you hold over your own information. We encourage you to read this document in full before registering an Account.
For the purposes of this Privacy Policy, the following terms carry the meanings set out below:
2.1 This Privacy Policy applies to all Personal Data collected by top66 from Players and prospective Players who access or use the Platform, regardless of the device or network used to do so.
2.2 This Policy applies in addition to, and should be read alongside, top66's Terms & Conditions and Responsible Gaming policy. In the event of any conflict between this Privacy Policy and the Terms & Conditions with respect to data-privacy matters, this Privacy Policy shall prevail.
2.3 The Platform is operated for and targeted at adult players primarily located in Indonesia, including in Jakarta, Surabaya, Bandung, Medan, Semarang, Makassar, Palembang, Bali, and Yogyakarta. Players outside Indonesia may access the Platform subject to applicable local law, but Indonesian data-protection standards inform the baseline protections applied by top66 across its entire player base.
2.4 By registering an Account or continuing to use the Platform after this Policy has been updated, you acknowledge that you have read, understood, and agreed to the collection and use of your Personal Data as described herein.
3.1 top66 collects the following categories of Personal Data from Players:
4.1 top66 collects Personal Data through the following channels:
5.1 top66 processes Personal Data on the following legal bases, depending on the nature and purpose of the Processing activity:
| Processing Purpose | Legal Basis |
|---|---|
| Account registration and management | Performance of a contract (Account Agreement with the Player) |
| KYC identity and age verification | Legal obligation (AML/CTF compliance) and legitimate interests (fraud prevention) |
| Processing IDR deposits and withdrawals | Performance of a contract |
| Customer support communications | Performance of a contract and legitimate interests |
| Fraud detection and security monitoring | Legitimate interests (protecting the Platform and Players from harm) |
| Responsible gaming interventions | Legal obligation and legitimate interests (player welfare) |
| Promotional and bonus communications | Consent (opt-in at registration or in Account settings) |
| Analytics and Platform improvement | Legitimate interests (improving service quality) |
| Compliance with regulatory requests | Legal obligation |
5.2 Where top66 relies on consent as the legal basis for Processing, you retain the right to withdraw that consent at any time without affecting the lawfulness of Processing carried out prior to withdrawal. To withdraw consent for promotional communications, update your preferences in Account settings or contact [email protected].
6.1 top66 uses the Personal Data collected from Players for the following purposes:
7.1 top66 does not sell, rent, or trade your Personal Data to any third party for commercial purposes. Data is shared only in the limited circumstances described below:
top66 engages carefully vetted third-party processors to operate specific technical and operational functions on our behalf. These include:
All third-party processors are bound by data-processing agreements that restrict their use of Personal Data strictly to the purposes for which they were engaged and require them to maintain appropriate technical and organisational security measures.
top66 may disclose Personal Data to competent regulatory authorities, law-enforcement agencies, or courts where required to do so by applicable law or by a valid legal process (such as a court order or regulatory notice). top66 will, where legally permitted, notify the affected Player of such a disclosure request before complying with it.
In the event of a merger, acquisition, restructuring, or sale of all or substantially all of top66's assets, Personal Data held by top66 may be transferred to the acquiring entity as part of that transaction. Players will be notified of any such transfer and of any material changes to the applicable privacy terms before the transfer takes effect.
8.1 top66 uses the following categories of cookies and tracking technologies on the Platform:
| Cookie Type | Purpose | Duration |
|---|---|---|
| Strictly Necessary | Session management, login authentication, fraud prevention, load balancing. Cannot be disabled without affecting core Platform functionality. | Session / up to 24 hours |
| Functional | Remembering Account preferences (language, display settings, responsible-gaming notifications). Improves the quality of your experience on return visits. | Up to 12 months |
| Analytics | Aggregated data on how Players navigate the Platform, which game categories are most visited, and where users exit the registration funnel. Used to improve Platform design and performance. | Up to 13 months |
| Marketing / Retargeting | Tracking visits across sessions to support personalised promotional content delivery. Applied only where you have provided explicit consent. | Up to 90 days |
8.2 You may manage your cookie preferences at any time through your browser settings. Disabling strictly necessary cookies will impair your ability to use the Platform. Disabling analytics or marketing cookies will not affect your ability to log in, deposit, withdraw, or play.
8.3 top66 does not use cookies to collect Personal Data from Players who have not registered an Account, beyond the technical data required to serve the Platform correctly to your browser.
9.1 top66 retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, subject to any applicable legal or regulatory retention obligations. The following retention periods apply as a general guide:
| Data Category | Retention Period | Basis |
|---|---|---|
| Account registration data | Duration of Account plus 5 years post-closure | AML regulatory obligation |
| KYC documents (KTP, passport, selfie) | Duration of Account plus 5 years post-closure | AML regulatory obligation |
| Financial transaction records | Duration of Account plus 5 years post-closure | AML and tax-record obligations |
| Betting and gaming history | Duration of Account plus 2 years post-closure | Dispute resolution and regulatory audit |
| Customer support communications | 3 years from date of interaction | Legitimate interests (dispute resolution) |
| Marketing consent records | Until consent is withdrawn plus 1 year | Demonstrating consent validity |
| Analytics / technical logs | 13 months from collection | Legitimate interests (Platform improvement) |
9.2 Upon expiry of the applicable retention period, Personal Data will be securely deleted or anonymised in accordance with top66's data-destruction procedures. Anonymised data (where the link to the individual has been irreversibly severed) may be retained for statistical and analytical purposes indefinitely.
10.1 top66 implements a layered security architecture to protect Personal Data against unauthorised access, disclosure, alteration, or destruction. Key security measures include:
10.2 While top66 takes all reasonable technical and organisational steps to protect your Personal Data, no system of data transmission over the internet can be guaranteed to be entirely secure. Players are also responsible for maintaining the security of their own Account credentials and devices.
11.1 As a Player on the top66 Platform, you hold the following rights with respect to your Personal Data. To exercise any of these rights, please submit a written request to [email protected]. top66 will acknowledge your request within five (5) business days and respond in full within thirty (30) calendar days.
12.1 The top66 Platform is strictly intended for adults aged 21 years and above. top66 does not knowingly collect, process, or store Personal Data from persons under the age of 21.
12.2 If top66 discovers or is notified that Personal Data belonging to a person under 21 has been collected, that data will be permanently deleted from our systems and the associated Account will be immediately closed. Any winnings accrued on such an Account will be voided in accordance with the Terms & Conditions.
12.3 If you are a parent or guardian and believe that your child under the age of 21 has registered an Account on the top66 Platform, please contact us immediately at [email protected]. We take underage gambling extremely seriously and will act on all such reports without delay.
13.1 The top66 Platform may contain links to third-party websites or services, including game studio demonstration portals, payment provider information pages, and sports data feeds. These linked resources are operated independently of top66 and are governed by their own privacy policies.
13.2 top66 is not responsible for the privacy practices of any third-party website. We encourage Players to review the privacy policy of any external site before submitting Personal Data to it. The presence of a link on the top66 Platform does not constitute an endorsement of the linked site's privacy or data-security practices.
14.1 top66 reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, business operations, or data-processing practices. The version date at the top of this document will be updated to reflect any such changes.
14.2 Where changes are material — meaning they significantly affect your rights or how your Personal Data is used — top66 will provide at least fourteen (14) days' advance notice by posting a prominent notice on the Platform homepage and, where applicable, by sending an email notification to the address registered on your Account.
14.3 Your continued use of the Platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not accept the revised Privacy Policy, you must cease using the Platform and may request Account closure by contacting [email protected].
15.1 If you have any questions about this Privacy Policy, wish to exercise a data right, or wish to make a complaint about how top66 has handled your Personal Data, please contact the top66 Data Privacy team through the following channel:
15.2 top66 is committed to resolving all privacy complaints fairly and transparently. If you are not satisfied with top66's response to your complaint, you retain the right to escalate your complaint to the relevant data-protection supervisory authority in your jurisdiction.
Beyond the formal language of this Policy, here is what top66 pledges to every Indonesian player in plain terms.
top66 will never sell, rent, or trade your Personal Data to advertisers, data brokers, or any third party for commercial gain. Your data is used exclusively to operate your Account and improve the Platform experience.
Every data transmission between your device and top66's servers is protected by TLS 1.3 encryption. Data stored at rest — including your KTP details, BCA/BRI/OVO payment records, and gaming history — is encrypted using AES-256.
You can request a copy of all data top66 holds about you, correct inaccuracies, restrict processing, or request deletion — all by emailing [email protected]. We will respond in full within 30 calendar days.
top66 will only send you promotional communications — including Idul Fitri bonus offers, BRI Liga 1 free-bet campaigns, and Ramadhan cashback promotions — if you have explicitly opted in. You can unsubscribe at any point from your Account settings.
top66 publishes clear retention schedules for every category of data we hold. KYC documents and transaction records are kept for five years post-Account closure to meet AML obligations; analytics data is purged after 13 months. Nothing is kept longer than necessary.
Responsible gaming records — including self-exclusion requests, deposit limits, and cooling-off periods — are held with the highest level of confidentiality and are never used for marketing profiling. They exist solely to protect your wellbeing as a player.
Now that you understand how top66 handles your personal data, you can play with complete confidence. Explore our casino games, sportsbook markets, and exclusive IDR promotions — all secured by industry-leading encryption.