Privacy Policy
This Privacy Policy explains how FUN PLAY GROUP LIMITED collects, uses, stores, shares and protects personal information when you access or use TopupClub’s websites, applications, game top-up services, live-streaming / voice-chat / social-entertainment app top-up services, checkout functions, customer support, promotional activities and related services (collectively, the “Services”).
The primary operator of the Services is FUN PLAY GROUP LIMITED. In Europe and certain other regions, the name JUST HAVE FUN LIMITED may appear on invoices, payment receipts, billing records, bank statements, card statements or other payment-related records for regional billing display, collection support and internal group accounting purposes. In this Privacy Policy, “we”, “us” and “our” refer to FUN PLAY GROUP LIMITED and, where applicable, affiliates, subsidiaries and service partners involved in providing or supporting the Services.
By using the Services, you acknowledge that personal information will be processed in accordance with this Privacy Policy. Your use of the Services is also subject to the Terms of Service and the Refund and Payment Dispute Policy.
1. Personal Information We Collect
We collect personal information reasonably necessary to provide, secure, improve, support and operate the Services. The information collected may depend on how you use the Services, your country or region, payment method, products or services purchased and whether additional verification is required.
1.1 Information You Provide
• Account and contact information, such as email address, phone number, username, account ID, login credentials, country or region and communication preferences.
• Order and top-up information, such as selected product, order amount, order status, recipient account, UID, player ID, platform account, server, region, email address, phone number or other information required for fulfillment.
• Payment-related information, such as billing information, payment-method type, transaction reference, payment status, refund records, chargeback or dispute information and information provided by Payment Partners. Full payment-card details are generally collected and processed by independent Payment Partners rather than stored by us, unless expressly stated otherwise.
• Verification information, such as identity-verification information, proof of payment authorization, supporting documents, screenshots or other information required for security, payment protection, compliance, anti-fraud, sanctions screening, dispute handling or legal reasons.
• Customer-support and communication information, such as messages, emails, chat records, complaints, feedback, reviews, survey responses and other communications with us.
• Promotional and marketing information, such as campaign participation, invitation information, coupon usage, marketing preferences and responses to campaigns or surveys.
Unless we expressly request it for a lawful and necessary purpose, please do not provide sensitive personal information. If you voluntarily provide sensitive information, we process it only to the extent reasonably necessary for verification, risk handling, dispute resolution, legal compliance or user protection, and we delete, anonymize, restrict access to or securely retain it according to applicable law, internal retention rules and case or dispute needs.
1.2 Information Collected Automatically
• Device, browser, network and technical information, such as IP address, device type, browser type, operating system, language setting, access time, error log, session information, device identifiers and similar technical information.
• Usage, log and security information, such as pages visited, actions taken, order activity, login activity, checkout activity, customer-support activity, service-performance information and security logs.
• Approximate location information, such as country, region or city inferred from IP address or similar technical information where permitted by law.
• Cookie, pixel, SDK, local-storage and similar technology information.
1.3 Information from Third Parties
Where permitted by law, we may obtain personal information from independent payment service providers, acquiring banks, issuing banks, card schemes, wallet providers, local payment partners, identity-verification providers, KYC providers, compliance and sanctions-screening providers, anti-fraud and security providers, third-party login providers, suppliers, fulfillment partners, customer-support tools, analytics providers, advertising partners, technology providers, law-enforcement agencies, regulators, courts, dispute-resolution bodies or other relevant parties.
2. How We Use Personal Information
1. Provide and operate the Services, including account creation, login, order processing, top-up fulfillment, payment confirmation, customer support, service notices and account management.
2. Process orders and transactions, including payment confirmation, fulfillment, failed-order handling, reprocessing, cancellation, refund, dispute and chargeback handling.
3. Verify identity, payment authorization and transaction legitimacy where reasonably required for security, compliance, payment protection, anti-fraud, user protection, customer support or legal reasons.
4. Protect the security and integrity of the Services, including detecting, preventing and responding to fraud, scams, induced top-ups, account abuse, payment abuse, promotion abuse, technical abuse, sanctions risks, security incidents and violations of applicable policies.
5. Provide customer support and respond to inquiries, complaints, requests, feedback and service issues.
6. Maintain and improve the Services, including debugging, analytics, performance monitoring, system testing, product improvement, user-experience improvement and internal reporting.
7. Send service-related notices, including order updates, security notices, verification requests, policy updates, refund notices, dispute notices, anti-scam warnings and legal or compliance notices.
8. Send marketing communications and measure marketing effectiveness where permitted by law and subject to available choices.
9. Comply with legal, tax, accounting, audit, regulatory and contractual obligations, including recordkeeping and responding to lawful requests.
10. Protect our rights and legitimate interests, including enforcing terms and policies, defending legal claims, investigating suspicious activity, preventing losses, supporting operations and conducting internal audits.
11. Support business transactions, such as due diligence, financing, restructuring, merger, acquisition, asset sale, business transfer, insolvency or similar transactions.
3. Legal Bases for Processing
Where applicable law requires a legal basis, we may rely on one or more of the following: performance of a contract; steps taken at your request before entering into a contract; your consent; compliance with legal obligations; our legitimate interests or those of a third party; protection of vital interests; substantial public interests where recognized by law; and the establishment, exercise or defence of legal claims.
Where we rely on legitimate interests, those interests may include operating and securing the Services, preventing fraud and abuse, improving products, handling disputes, protecting users and partners, and supporting ordinary business administration, provided that those interests are not overridden by your rights and interests under applicable law.
4. Automated Risk Assessment and Profiling
We may use automated tools, rules, device signals, transaction patterns and third-party risk information to assess fraud, security, payment, sanctions or compliance risk. These tools may affect whether an order is approved, delayed, rejected, refunded, sent for manual review or subject to additional verification.
Where applicable law grants rights relating to solely automated decisions that produce legal or similarly significant effects, you may request information, human review or contest a decision, subject to legal exceptions and security limitations. We may not disclose detailed fraud-detection logic, thresholds or signals where disclosure would undermine security or enable abuse.
5. How We Share Personal Information
We do not sell personal information for money. We may share personal information where reasonably necessary for the purposes described in this Privacy Policy, including with:
• Group affiliates and related entities supporting regional billing, collection support, internal accounting, operations, customer support, compliance, risk control or service delivery.
• Payment Partners, issuing banks, card schemes, fraud-prevention providers and dispute-handling providers.
• Identity-verification, KYC, compliance, sanctions-screening, anti-fraud, cybersecurity and risk-review providers.
• Suppliers and fulfillment partners where reasonably necessary to process, fulfill, verify, investigate, reprocess, cancel or support an order.
• Technology and business service providers, such as cloud-hosting providers, IT vendors, customer-support tools, analytics providers, email / SMS providers, communication tools, auditors, insurers, legal advisers and other operational providers.
• Advertising and analytics partners where permitted by law, subject to applicable consent or opt-out requirements and cookie preferences.
• Regulators, courts, law-enforcement agencies, government authorities, payment institutions, banks, card schemes, dispute-resolution bodies or other parties where disclosure is permitted or required by law or reasonably necessary to prevent harm, investigate unlawful activity, handle disputes or protect legal rights.
• Parties and advisers involved in a merger, acquisition, financing, restructuring, asset sale, business transfer, due-diligence process, insolvency or similar transaction.
Internal group sharing is limited to service provision, order fulfillment, accounting reconciliation, compliance and risk control, customer support, dispute handling, internal management and other purposes described in this Policy. Service providers are expected to process personal information only for authorized purposes and apply appropriate security measures where required by law.
Some privacy laws define certain disclosures for interest-based advertising as a “sale” or “sharing” even where no money is paid. Where those laws apply, you may exercise available opt-out rights through our cookie-preference tools or by contacting us.
6. Cross-Border Transfers
We operate globally. Personal information may be transferred to, stored in or processed outside your country or region, including in Hong Kong, the United Kingdom, Singapore, the European Economic Area, the United States or other locations where our affiliates, Payment Partners, verification providers, anti-fraud providers, suppliers or technology partners operate.
Where required by law, we use appropriate transfer safeguards, such as contractual protections, standard contractual clauses, adequacy mechanisms or other lawful transfer mechanisms. Different jurisdictions may provide different levels of data protection.
7. Data Retention
We retain personal information only for as long as reasonably necessary to achieve the purposes described in this Privacy Policy, including providing services, processing orders, refunds, disputes and chargebacks, complying with legal, tax, accounting, audit and regulatory obligations, preventing fraud and abuse, and protecting legitimate interests.
If there is an ongoing complaint, dispute, chargeback, investigation, legal request or reasonable possibility of legal claims, we may extend the retention period. Even after an account is deleted or terminated, certain transaction, risk-control, dispute and compliance records may continue to be retained as required by law, Payment Partner rules or internal retention policies.
When personal information is no longer needed, we delete, anonymize, aggregate or securely retain it where continued retention is required by applicable law or justified by an ongoing legal, security or dispute need.
8. Data Security
We take appropriate administrative, technical and organizational measures designed to protect personal information against accidental or unauthorized loss, misuse, access, disclosure, alteration or destruction. Measures may include access controls, encryption where appropriate, logging, monitoring, vendor controls, staff confidentiality and incident-response procedures.
No internet transmission, checkout process, payment process, storage system or security measure can be guaranteed to be completely secure or error-free. You are responsible for safeguarding your account credentials, email account, device and payment method and for contacting us promptly if you believe your account, payment method or transaction activity may have been compromised or used without authorization.
9. Your Privacy Rights and Choices
Depending on your location and applicable law, you may have rights to request access to, correction or deletion of, or a copy or portability of, personal information; to object to or restrict certain processing; to withdraw consent where processing is based on consent; to opt out of certain marketing or advertising uses; to appeal certain privacy decisions; and to complain to a competent data-protection authority.
These rights may be limited where we need to retain information for legal, security, anti-fraud, AML, counter-terrorist-financing, sanctions, accounting, tax, audit, dispute, chargeback, compliance or legitimate-business purposes, or where another exception applies.
To exercise a right, contact service@topupclub.com and use “Privacy Rights Request” in the subject line where possible. To protect privacy and prevent fraudulent requests, we may verify your identity and your relationship with the relevant account, order or transaction before responding. Authorized agents may be required to provide proof of authority. If we cannot verify a request, we may be unable to process it.
10. Cookies and Similar Technologies
We use cookies, pixels, SDKs, local storage and similar technologies to operate the website, remember preferences, maintain login status, improve performance, analyze traffic, measure marketing effectiveness, prevent fraud, enhance security and, where permitted by law, provide relevant content or advertising.
You may manage cookies through browser or device settings or through cookie-preference tools we provide. Disabling necessary cookies may affect login, checkout, payment, security or other essential functions. Where required by law, we provide additional choices or obtain consent for non-essential cookies and similar technologies. We may recognize legally required browser or device preference signals where applicable.
11. Marketing and Advertising Choices
Where law requires consent, we send marketing communications based on consent. Where otherwise permitted, we may send marketing communications related to your use of the Services based on legitimate interests and provide an unsubscribe or opt-out mechanism.
You may unsubscribe using the link in a marketing email, adjust available preferences or contact us. Transactional, security, order-related, customer-support, legal, compliance, anti-scam and service notices are not marketing communications and may still be sent when necessary.
12. Children and Minors
The Services are not directed to children below the age at which they may consent to personal-information processing or make online purchases under applicable law. A minor may use the Services only with the involvement and consent of a parent or legal guardian.
If we discover that a child’s personal information has been collected without required parental or guardian consent, we will take reasonable steps to delete or restrict the information as required by law, subject to transaction, anti-fraud, dispute, chargeback and legal-retention requirements. A parent or guardian may contact us to request access to or deletion of a child’s personal information, subject to verification and applicable exceptions.
13. Third-Party Services and Links
The Services may contain links to third-party websites, apps, platforms, payment pages, login services, social-media pages or other services. Third parties may collect and process personal information under their own privacy policies. We do not control and are not responsible for the privacy practices, security, content or performance of third-party services. You should review the terms and privacy policies of third-party services you use.
14. Business Transfers
If we are involved in a merger, acquisition, financing, reorganization, asset sale, business transfer, insolvency or similar transaction, personal information may be reviewed, transferred or otherwise processed as part of that transaction, subject to applicable confidentiality, notice and data-protection requirements.
15. Updates to This Privacy Policy
We may update this Privacy Policy to reflect changes in services, legal requirements, business operations, security practices or data-processing activities. Updated versions will be posted with a new effective date. Where required by law, we will provide additional notice or seek consent for material changes.
Continued use of the Services after an updated Privacy Policy takes effect means personal information will be processed in accordance with the updated Policy, except where applicable law requires another form of acceptance or consent.
16. Contact Us
Questions, requests, complaints or concerns about this Privacy Policy or our processing of personal information may be sent to service@topupclub.com.
Company Name: FUN PLAY GROUP LIMITED
Company Address: UNIT C21, 4/F, YIP WIN FACTORY BUILDING, NO. 10 TSUN YIP LANE, KWUN TONG, KOWLOON, HONG KONG
Registration No: 74456009