Your privacy matters to topbos. This Policy explains exactly what personal data we collect, why we collect it, how we use and protect it, and what rights you have over your own information as a Member of our platform.
Summary: topbos collects only the data necessary to operate your account, process payments, verify your identity, and comply with our legal obligations. We do not sell your personal data to third parties. You retain meaningful rights over your information at all times. Read the full policy below for complete details.
1.1 topbos ("we", "us", "our", "the Platform") operates the online gaming and sports betting service available at topbos.cam. We are committed to protecting and respecting the privacy of every individual who accesses or uses our platform ("you", "Member", "User").
1.2 This Privacy Policy describes how topbos collects, uses, stores, shares, and safeguards personal data in connection with the provision of our services. It applies to all personal data processed through the Platform, our customer support channels, and any associated digital touchpoints.
1.3 This Privacy Policy forms part of, and should be read in conjunction with, our Terms & Conditions and our Responsible Gaming Policy. By registering an account or using any topbos service, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.
1.4 topbos serves Members primarily located in Indonesia, and our data practices are designed to meet international privacy standards while reflecting the realities of operating within the Indonesian market. References to local services — such as BCA, BRI, BNI, Mandiri, OVO, DANA, and GoPay — reflect payment integrations that necessarily involve the exchange of certain transactional data between the Platform and those providers.
2.1 For the purposes of this Privacy Policy, the following terms have the meanings set out below:
| Term | Meaning |
|---|---|
| "Personal Data" | Any information relating to an identified or identifiable natural person — including name, identification number, location data, online identifiers, or one or more factors specific to that person's physical, economic, or social identity. |
| "Processing" | Any operation performed on personal data, including collection, recording, storage, adaptation, retrieval, use, disclosure, or deletion. |
| "Controller" | The entity that determines the purposes and means of processing personal data — in this context, topbos. |
| "Processor" | A third party that processes personal data on behalf of topbos, under instruction and contractual obligation. |
| "Data Subject" | The identified or identifiable natural person to whom the personal data relates — in this context, a Member or visitor to the Platform. |
| "KYC Data" | Identity verification documents and information submitted by a Member during the Know Your Customer (KYC) process, including government-issued ID, proof of address, and payment method verification. |
| "Cookies" | Small data files placed on your device by the Platform to enable or enhance functionality, measure performance, or personalise the user experience. |
3.1 topbos collects personal data that is necessary and proportionate to the purposes for which it is processed. The categories of personal data we may collect include:
Note: topbos does not collect sensitive special-category personal data — such as racial or ethnic origin, political opinions, religious beliefs, biometric data, or health information — and will not request such data from Members under any circumstances.
4.1 topbos collects personal data through the following primary channels:
4.2 topbos does not purchase personal data lists from data brokers or any other commercial data vendors.
5.1 topbos processes personal data on the following legal bases, depending on the purpose and nature of the processing activity:
| Legal Basis | When It Applies |
|---|---|
| Contractual Necessity | Processing required to perform our obligations under the Terms & Conditions — including account management, payment processing, bet settlement, and customer support. |
| Legitimate Interests | Processing necessary for topbos's legitimate business interests, such as fraud prevention, platform security, product improvement, and responsible gaming monitoring, provided these interests are not overridden by your rights. |
| Legal Obligation | Processing required to comply with applicable anti-money-laundering (AML) laws, gaming regulations, and other legal obligations to which topbos is subject under its international operating licence. |
| Consent | Processing for optional purposes — such as sending promotional emails or SMS marketing — where you have given clear, freely revocable consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing. |
6.1 topbos uses the personal data we collect for the following purposes:
6.2 topbos will not use your personal data for any purpose incompatible with the purposes listed above without first notifying you and, where required, obtaining your consent.
7.1 topbos does not sell, rent, or trade your personal data to any third party for commercial purposes. We share personal data only in the following limited circumstances:
We engage carefully vetted third-party service providers who process personal data on our behalf, under written data processing agreements that prohibit them from using your data for any purpose beyond the specific service they provide to topbos. These include:
topbos may disclose personal data to law enforcement agencies, regulatory authorities, or courts of competent jurisdiction where required to do so by applicable law, valid legal process, or our obligations under our international gaming licence. We will notify affected Members of such disclosures to the extent permitted by law.
In the event of a merger, acquisition, restructuring, or sale of all or part of the topbos business, personal data held by the Platform may be transferred to the acquiring entity as part of that transaction. We will notify affected Members in advance of any such transfer and ensure that the receiving entity is bound by privacy obligations no less protective than those in this Policy.
We may share your personal data with additional third parties for purposes not described in this Policy where you have given your explicit prior consent. You may withdraw such consent at any time by contacting our support team.
8.1 topbos retains personal data for as long as necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, accounting, and reporting obligations. The following indicative retention periods apply:
| Data Category | Retention Period |
|---|---|
| Account & registration data | Duration of membership plus 5 years after account closure. |
| KYC documents | Duration of membership plus 5 years after account closure, in line with AML compliance standards. |
| Financial & transaction records | 7 years from the date of the transaction, to satisfy financial record-keeping obligations. |
| Betting / wagering history | Duration of membership plus 3 years after account closure. |
| Customer support communications | 3 years from the date of the interaction. |
| Marketing consent records | Until consent is withdrawn, plus 2 years thereafter as proof of prior consent. |
| Technical / device / log data | 13 months on a rolling basis. |
8.2 Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents its re-identification. Anonymised, aggregated data may be retained indefinitely for statistical and analytical purposes.
9.1 topbos employs a comprehensive, layered information security framework designed to protect your personal data against unauthorised access, loss, alteration, or disclosure. Our security measures include:
9.2 While topbos takes all reasonable and appropriate technical and organisational measures to protect your data, no method of internet transmission or electronic storage is completely infallible. We encourage Members to use strong, unique passwords, to enable 2FA, and to contact support immediately if they suspect any unauthorized activity on their account.
If you suspect that your topbos account has been compromised, contact our support team immediately at [email protected] (plain text — not a clickable link). Our security team operates around the clock and will respond as a priority.
10.1 topbos uses cookies and similar tracking technologies to operate the Platform effectively, enhance your user experience, and gather analytical insights. The following categories of cookies are used:
| Cookie Type | Purpose |
|---|---|
| Strictly Necessary | Essential for the Platform to function — these enable session management, authentication, and security features. They cannot be disabled without breaking core functionality. |
| Performance & Analytics | Collect aggregated, anonymised data about how Members use the Platform — page load times, most-visited sections, error rates — to help us improve performance and usability. |
| Functional | Remember your preferences — such as language settings, default bet stake, and favourite sports markets — to personalise your experience across sessions. |
| Marketing & Retargeting | Used only with your explicit consent to deliver relevant promotional content. You may withdraw consent at any time via your account settings or by contacting support. |
10.2 You can control cookie settings through your browser preferences. Disabling strictly necessary cookies will impair your ability to use the Platform. Disabling performance or functional cookies will reduce personalisation but will not prevent you from accessing core features.
10.3 topbos does not use third-party advertising cookies to build profiles about you for the benefit of external advertisers. Any marketing cookies placed are operated solely for topbos's own promotional communications.
11.1 As a data subject, you hold the following rights with respect to the personal data topbos holds about you. To exercise any of these rights, contact us at the details provided in Clause 15.
Request a copy of all personal data we hold about you, together with information about how it is used.
Ask us to correct inaccurate or incomplete personal data without undue delay.
Request deletion of your personal data where there is no compelling legal ground for continued retention.
Ask us to limit the processing of your data while a dispute about its accuracy or lawful basis is being resolved.
Receive a structured, machine-readable copy of the data you provided to us, for transfer to another service.
Object to processing based on legitimate interests, including profiling for direct marketing purposes.
Revoke any consent you have given at any time, without affecting the lawfulness of prior processing.
Submit a complaint to the relevant supervisory authority if you believe your data rights have been violated.
11.2 topbos will respond to all verifiable data subject requests within 30 calendar days of receipt. For complex requests, this period may be extended by a further 30 days, with notice provided to the requesting Member. We may need to verify your identity before fulfilling a request to protect against unauthorised access to another person's data.
11.3 Certain rights — particularly the right to erasure — may be limited where topbos has an overriding legal obligation to retain the relevant data, such as AML record-keeping requirements. We will explain any such limitation clearly in our response to your request.
12.1 topbos is strictly an adults-only platform. We do not knowingly collect personal data from any person under the age of 21 years. Age verification is a mandatory step in the registration process, and KYC checks confirm the age of all Members prior to the processing of any withdrawal.
12.2 If topbos becomes aware that personal data has been collected from a person under 21 years of age — whether through registration, KYC review, or any other means — we will immediately close the associated account, delete all personal data collected in connection with that account, and return any deposited funds in accordance with our Terms & Conditions.
12.3 If you believe that a minor has registered or attempted to register an account on topbos, please contact our support team immediately at [email protected]. We treat all such reports as high-priority and will investigate and respond within 24 hours (WIB).
21+ Only: Gambling is for adults. If you are a parent or guardian and believe your child has accessed this platform, contact us immediately. We will act without delay.
13.1 topbos's primary server infrastructure is located in jurisdictions with robust data protection frameworks. However, some of our service providers — including KYC verification platforms, fraud detection vendors, and cloud infrastructure partners — may process data in countries outside Indonesia.
13.2 Where personal data is transferred internationally, topbos ensures that appropriate safeguards are in place to protect that data to a standard equivalent to the protections described in this Policy. These safeguards include contractual clauses, data processing agreements, and, where applicable, transfers to countries recognised as providing adequate levels of data protection.
13.3 By registering an account with topbos, you acknowledge that your personal data may be transferred to and processed in countries other than Indonesia as described in this Clause. topbos remains accountable for the protection of such data regardless of where it is processed.
14.1 topbos reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or platform operations. When we make material changes — those that meaningfully affect how we collect, use, or share your personal data — we will notify you by email and post a prominent notice on the Platform at least seven (7) days before the changes take effect.
14.2 The "Last Updated" date at the top of this page reflects the date of the most recent revision. We encourage Members to review this Policy periodically to stay informed of how topbos protects their data.
14.3 Your continued use of the Platform after the effective date of any updated Privacy Policy constitutes your acknowledgment of the revised terms. If you do not agree with the updated Policy, you must discontinue use of the Platform and may request account closure by contacting support.
15.1 If you have any questions about this Privacy Policy, wish to exercise a data subject right, or wish to raise a concern about how topbos handles your personal data, please contact us through any of the following channels:
15.2 When submitting a privacy-related request or complaint, please include your full registered name, the email address associated with your account, and a clear description of your request or concern. This will allow us to locate your account and respond as efficiently as possible.
15.3 topbos aims to resolve all privacy-related enquiries within 30 calendar days. For complaints that cannot be resolved directly, you retain the right to escalate to the relevant data protection supervisory authority in the jurisdiction applicable to your circumstances.
Effective Date: This Privacy Policy is effective as of January 2026. This document supersedes all previous versions of the topbos Privacy Policy.
Our data protection commitments go beyond legal compliance — they reflect our core belief that every Member deserves full transparency and control over their personal information.
Every byte of data transmitted between your device and topbos servers is protected by bank-grade 256-bit SSL encryption. Your personal details, payment information, and account credentials are secured at every point of transit.
topbos does not sell, rent, or trade your personal data to third-party advertisers, data brokers, or any external commercial entity. Your information exists solely to power your account and protect your experience on our platform.
You retain meaningful rights over your personal data at all times — including the right to access, correct, delete, restrict, and port your information. Submit a request to our support team and we will respond within 30 days.
We keep your data only for as long as legally required or operationally necessary. Once retention periods expire, data is securely deleted or anonymised — never retained indefinitely or repurposed without your knowledge.
We use cookies only for essential platform operation, performance analytics, and — with your explicit consent — personalised promotions. We do not run third-party advertising networks. You control your cookie preferences at any time.
topbos is an adults-only platform. Age verification is mandatory at registration and confirmed through KYC review. Any account found to belong to a person under 21 years of age is immediately closed and all associated data deleted.
Our support team is available around the clock to address any data privacy questions or requests. You can also review our Terms & Conditions, explore our Responsible Gaming commitments, or visit our FAQ for quick answers.