At top178, your privacy is a foundational commitment — not an afterthought. This Privacy Policy explains precisely what personal data we collect from Indonesian players, why we collect it, how we use and protect it, and what rights you hold over your information.
A plain-language overview of our core privacy commitments. The full legal text of each commitment follows in the policy sections below.
Every data transmission between your device and the top178 platform is encrypted using industry-standard 256-bit SSL/TLS technology. Your personal details, payment information, and gaming activity are protected against interception at every step.
Personal data — including KTP copies, bank account details, and KYC documents — is stored on encrypted servers with strict access controls. Only authorized compliance and support personnel may access sensitive records, and all access is logged and audited.
top178 does not sell, rent, or trade your personal data to third-party marketers. Data sharing is strictly limited to service providers who assist in platform operations, and only under binding data processing agreements that prohibit independent commercial use.
You retain the right to access, correct, and request deletion of your personal data at any time. Marketing communications can be opted out of through your account settings or by contacting support. Requests are processed within 30 days of receipt.
We use cookies and similar tracking technologies solely to improve your platform experience, remember your preferences, and measure platform performance. Strictly necessary cookies cannot be disabled, but analytics and marketing cookies are optional.
Our data practices are designed to meet applicable international data protection standards, including principles equivalent to those in the GDPR framework. We maintain a formal data retention schedule and conduct periodic privacy impact assessments.
1.1 top178 ("we", "us", "our", "the Platform") operates as an international online gaming platform serving players in Indonesia. We are committed to handling your personal data responsibly, transparently, and in accordance with applicable data protection principles. This Policy sets out, in plain and formal terms, how we collect, process, store, share, and protect personal information relating to registered players, prospective players, and visitors to our website.
1.2 We recognize that Indonesian players entrust us with sensitive personal and financial information — including government-issued identity documents, bank account details, and transaction histories. That trust is not taken lightly. Every system, process, and third-party relationship we maintain is evaluated against the standard of whether it adequately protects the data you share with us.
1.3 This Policy should be read alongside our Terms & Conditions, which govern your use of the Platform as a whole, and our Responsible Gaming policy, which addresses how we use behavioral data to support safer gambling practices.
For the purposes of this Policy, the following terms carry the meanings assigned below:
3.1 We collect the following categories of Personal Data, depending on the nature of your interaction with the Platform:
4.1 Directly from you: The majority of Personal Data is provided directly by you during registration, KYC submission, deposit and withdrawal requests, customer support interactions, and participation in promotions.
4.2 Automatically through platform use: Technical and device data, gaming activity records, and cookie-derived information are collected automatically when you access and interact with the Platform. You may limit automatic data collection through your browser's cookie settings, though doing so may impair certain Platform features.
4.3 From third-party payment providers: When you make a deposit or withdrawal via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, or LinkAja, we receive transaction confirmation data from the relevant payment service provider, including transaction reference numbers and timestamps.
4.4 From KYC and fraud-prevention services: We may use third-party identity verification and fraud-detection services to cross-reference the information you provide during KYC. These services return a verification outcome (pass / refer / fail) to top178; they do not independently store your documents beyond the period necessary to produce the outcome.
5.1 We process your Personal Data only where we ha ve a valid legal basis to do so. The table below summarises the primary purposes for which we process Personal Data and the corresponding legal basis for each:
| Processing Purpose | Legal Basis |
|---|---|
| Account registration and management | Performance of contract (Terms & Conditions) |
| Identity verification (KYC) and age confirmation (21+) | Legal obligation; legitimate interest in fraud prevention |
| Processing deposits and withdrawals via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja | Performance of contract |
| Anti-money laundering (AML) and fraud monitoring | Legal obligation; legitimate interest |
| Responsible gaming monitoring and intervention | Legitimate interest in player welfare; legal obligation |
| Customer support and dispute resolution | Performance of contract; legitimate interest |
| Promotional communications and personalized offers | Consent (opt-in); legitimate interest where existing customer relationship exists |
| Platform analytics and performance improvement | Legitimate interest |
| Legal compliance and regulatory reporting | Legal obligation |
5.2 Where we rely on your consent as the legal basis for processing (e.g., marketing emails, SMS promotions), you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. To withdraw consent, update your communication preferences in your Account settings or contact support.
5.3 We do not use your Personal Data to make solely automated decisions that produce significant legal effects upon you without human review, except where expressly permitted by applicable law and disclosed to you at the relevant point of interaction.
6.1 top178 does not sell, rent, or trade your Personal Data to any third party for their independent commercial purposes. We share Personal Data only in the circumstances described below, and only to the minimum extent necessary for the stated purpose:
We engage trusted third-party service providers to support Platform operations. These include:
All service providers are bound by written data processing agreements that prohibit use of your data for any purpose other than providing the contracted service to top178.
We may disclose Personal Data to law enforcement agencies, regulatory bodies, or courts where we are legally required to do so, or where disclosure is necessary to protect the rights, property, or safety of top178, its players, or the public. We will notify you of any such disclosure where legally permitted to do so.
In the event of a merger, acquisition, restructuring, or sale of all or part of top178's business, your Personal Data may be transferred to the acquiring entity as part of that transaction. You will be notified via email and a prominent Platform notice prior to any such transfer, and the acquiring entity will be required to honor this Policy or provide a materially equivalent level of data protection.
7.1 top178 operates as an internationally licensed platform. Your Personal Data may be transferred to and processed in countries outside Indonesia where our servers, service providers, or operational teams are located. Not all such countries maintain data protection laws equivalent to those in Indonesia or the European Economic Area.
7.2 Where Personal Data is transferred internationally, we implement appropriate safeguards to ensure an equivalent level of protection, including:
7.3 By using the Platform, you acknowledge and consent to the international transfer of your Personal Data under the safeguards described in this section.
8.1 We retain your Personal Data for as long as your Account remains active and for such additional periods as are required by applicable law or legitimate business necessity. The table below provides indicative retention periods for the primary data categories we hold:
| Data Category | Retention Period |
|---|---|
| Account registration data | Duration of Account + 5 years from closure |
| KYC identity documents | Duration of Account + 5 years from closure (AML requirement) |
| Financial transaction records | Duration of Account + 7 years from closure |
| Gaming activity logs | Duration of Account + 3 years from closure |
| Customer support communications | 3 years from the date of each interaction |
| Marketing consent records | Until consent is withdrawn + 2 years |
| Technical / server log data | 13 months from collection |
8.2 Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymized so that it can no longer be associated with any identifiable individual. Anonymized, aggregated data may be retained indefinitely for statistical and platform improvement purposes.
8.3 Where you request deletion of your Personal Data prior to the end of the applicable retention period, we will action your request to the fullest extent possible while retaining only such data as we are legally required or legitimately entitled to hold.
9.1 top178 employs a layered security architecture designed to protect Personal Data against unauthorized access, accidental loss, alteration, disclosure, or destruction. Our primary security measures include:
9.2 While we maintain robust technical and organizational security measures, no online platform can guarantee absolute security. You play an important role in protecting your own data by maintaining a strong, unique password for your Account, never sharing login credentials, and promptly reporting any suspected unauthorized access to support.
10.1 top178 uses cookies, web beacons, pixel tags, and local storage objects (collectively "Cookies") to deliver and improve the Platform experience. The categories of Cookies we deploy are as follows:
| Cookie Category | Purpose | Can Be Disabled? |
|---|---|---|
| Strictly Necessary | Authentication, session management, security tokens, fraud prevention flags. Essential for Platform functionality. | No — disabling these prevents Platform use |
| Functional / Preference | Storing your language preferences, odds format selection, and last-used payment method to personalize your experience. | Yes — via browser settings; may reduce personalization |
| Analytics / Performance | Aggregated, anonymized data on pages visited, session duration, and feature usage — used to improve Platform performance and content. | Yes — via browser settings or opt-out tools provided |
| Marketing / Targeting | Recording your interactions with promotional content to deliver relevant bonus offers. Only deployed where you have consented. | Yes — withdraw consent via Account settings |
10.2 Most web browsers accept Cookies by default. You can configure your browser to refuse all Cookies or to alert you when Cookies are being sent. Please note that disabling Strictly Necessary Cookies will prevent you from logging in and using the Platform.
10.3 We do not use third-party advertising networks or cross-site tracking technologies that follow your activity across unrelated websites without your explicit consent.
11.1 Subject to applicable law and certain exceptions, you hold the following rights in respect of your Personal Data held by top178:
11.2 To exercise any of the rights above, contact our Data Protection team at [email protected] with the subject line "Privacy Rights Request". We will acknowledge your request within 5 business days and aim to fulfill it within 30 calendar days, subject to identity verification and any applicable legal exceptions.
11.3 We will not charge a fee for processing privacy rights requests unless the request is manifestly unfounded, repetitive, or excessive, in which case a reasonable administrative fee may apply or the request may be refused with written explanation.
12.1 The top178 Platform is strictly for adults aged 21 years and older. We do not knowingly collect or process Personal Data from individuals under the age of 21. Age verification is a mandatory step of the KYC process, and any Account found to belong to a person under 21 will be immediately terminated and all associated data deleted or retained only as required for compliance reporting purposes.
12.2 If you believe that a minor has accessed the Platform or provided Personal Data to us, please contact support immediately at [email protected] so that we may investigate and take appropriate action without delay.
13.1 The Platform may contain references to third-party services, payment providers, and game studios (such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft). When you interact with third-party services — for example, by navigating to a payment provider's own authentication page — you do so under that third party's privacy policy, not ours.
13.2 top178 is not responsible for the privacy practices, data security measures, or content of third-party websites or services. We recommend reviewing the privacy policy of any third-party service before providing them with your Personal Data.
14.1 top178 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform features. Where changes are material — meaning they significantly affect how your Personal Data is processed or your rights in relation to it — we will provide at least 14 days' advance notice via email to your registered address and a prominent notice on the Platform prior to the amended Policy taking effect.
14.2 The most current version of this Policy, along with the date of last revision displayed at the top of this page, is always available at https://top178.cam/privacy-policy. We encourage you to review this Policy periodically. Your continued use of the Platform following the effective date of any amendment constitutes acceptance of the revised Policy.
14.3 If you do not accept a material amendment to this Policy, you may request Account closure in accordance with Section 14.1 of our Terms & Conditions, and any Real-Money Balance will be returned to your verified payment method after completion of any required security review.
15.1 If you have any questions about this Privacy Policy, wish to exercise your privacy rights, or wish to raise a concern about how top178 handles your Personal Data, please contact us through any of the following channels:
Email: [email protected] — use subject line "Privacy Rights Request" for data subject requests.
Live Chat: Available 24/7 via the Platform homepage. Indonesian-speaking agents are available at all hours.
Response Time: Acknowledgment within 5 business days; full response within 30 calendar days of a verified request.
15.2 If you are not satisfied with our response to your privacy concern, you have the right to escalate your complaint to the relevant data protection supervisory authority in the jurisdiction governing our gaming licence. We take all privacy complaints seriously and will cooperate fully with any regulatory investigation.
15.3 For disputes relating to specific data processing activities, please include your Account ID, the nature of the processing you are querying, and the approximate date of the activity when contacting us. This will help us locate the relevant records and respond to your concern more efficiently.
Our support team is available around the clock to address any data-related concerns. You can also explore our FAQ for quick answers or review our full Terms & Conditions.
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