Privacy Policy

Data protection policy within the company Top Pay Service SRL


  1. Introduction and general terms
  2. Who are we?
  3. How can you contact us?
  4. What types of personal information do we collect?
  5. Why do we collect your personal data and on what basis?
  6. When do we transmit your personal information?
  7. We transfer your data outside the EEA
  8. How long will Top Pay Service keep my data?
  9. Your rights and options regarding personal information
  10. Security of your data
  11. Complaints
  12. Top Pay Service Notification Changes


Introduction and general terms:

At Top Pay Service, we are committed to protecting you, respecting your privacy and maintaining the trust of our customers.

This Privacy Notice explains how and why your personal information is collected, why it is collected, and how it is kept secure. 

Who are we?

Top Pay Service is the sole owner of the Pokerfest brand and is currently the only licensed operator to hold festival-style poker tournaments.


Top Pay Service collaborates annually with the largest operators on the market, Pokerstars, 888 and Unibet. 

How can you contact us?

For general questions, do not hesitate to contact our team at 0733450808 or by e-mail at 

What types of personal data do we process?

The information you provide us

Upon registration:

-Your personal details, such as name, email address, mailing address, telephone or mobile number, gender, or date of birth;

-Photo ID identification and scanning

-Bank and financial details (if you choose to transfer your money to your account)

Other sources of personal data

-If we offer personalized services, we may use third-party data about you, such as your social media feeds, to get to know you better and to provide you with more effective personalization.

-Data received from our business partners and other organizations, such as specialized verification companies, credit reporting agencies, and fraud prevention agencies.

 Third party information

It is forbidden to provide information about another person without the permission of that person. If the information provided by you about someone else or someone else discloses information about you, it may be added to any personal information we already hold and use in the manner described in this Privacy Notice.


This list of types of personal data collected by Top Pay Service is not exhaustive and you may be asked for additional information when Top Pay Service deems it appropriate and necessary to do so.

Special categories of data

Personal data collected by Top Pay Service may include so-called „special categories of data”, such as data that reveal health (related to Responsible Gaming).

We apply additional measures to protect your sensitive personal data and its confidentiality.

Why do we collect your personal data and on what basis?

-To offer you our services:

-To provide you with information about the events we organize and to handle your requests and questions;

-To process your transactions

 To personalize your experience

-To provide a more relevant and tailored service; for example, we may use your game history to give you recommendations.

To improve our services and products

-For analysis and research, so that we can improve the services offered by Top Pay Service

-Testing new systems and checking for updates to existing systems;

-Evaluating the effectiveness of marketing and market research and training;

-Customer modeling, statistical analysis and trends, in order to develop and improve products and services.

 To contact you and interact with you


To contact you about our services, for example, by phone, email, email or social media;

To manage the promotions and contests you choose to participate in;

To invite you to participate in and manage customer surveys, questionnaires, and other market research conducted by Top Pay Service and other organizations on our behalf, we conduct market research to improve our services, however, if we contact you. , you are not obliged to participate in the activities. If you tell us that you do not want to be contacted for market research, we will respect this choice and this will not affect your ability to use our services);

To answer your questions and complaints. 

Based on the legal obligation

-when this is necessary to comply with the legal obligations to which we are subject under EU or local law:

-to ensure that we offer our services to eligible individuals;

-crime detection, prevention and investigation;

-to confirm your identity and determine the source of funds in any transaction;

-to perform appropriate anti-fraud checks (by conducting online searches using a third party identity provider). Please note that this will not affect your credit rating;


Based on your consent


Marketing and market research

We’ll send you relevant offers and news about our products and services in a variety of ways, including email, SMS, phone, mail, targeted advertising on social media, but only if you have previously agreed to receive such marketing communications. When you sign up with us, we’ll ask if you’d like to receive marketing communications, and you can change your online, telephone, or written marketing options at any time.

More information.

We may use the information we hold about you to show you relevant advertising on third-party sites (e.g., Facebook, Google, Instagram, Snapchat, and Twitter). If you don’t want to see targeted advertising from us, some third-party sites allow you to request that you stop seeing messages from certain advertisers in the future.


We also want to hear from you to help us improve our services, so we can contact you for market research purposes. You can always choose to participate in our market research.


When do we transmit your personal information?


We do not share your personal information with third parties outside of Top Pay for marketing purposes. There are situations in which we pass on your personal data to other companies, to third parties providing services on our behalf and to other third parties in fulfillment of our legal obligations. Other examples of situations in which we transmit your personal information include our participation in any merger or sale of the business. Even when transmitted, we assure you that your personal information will only be used for the purposes set out in this policy.

More information.

For other partner companies

We may pass on the personal data we collect to Top Pay Service companies for the following purposes:

-to provide you with products and services and to notify you of important changes or developments in the features and operation of those products and services;

-to answer your questions and complaints;

-manage offers, contests and promotions;

-to update, consolidate and improve the accuracy of our records

-for testing new systems and checking for upgrades to existing systems;

-for detecting, preventing and investigating crimes, as well as for complying with regulatory requirements;

-for evaluating the effectiveness of marketing and for market research and training;

-customer modeling, statistical analysis and trends, in order to develop and improve products and services.

-To book accommodation on behalf of our current and future partners on your behalf.


To third parties

We may disclose personal information to third parties in the following situations:


-when we are instructed to do so by any regulatory body and / or on the basis of any legal provision contained in applicable law;

-we may inform and authorize the Financial Institution to which the Account Holder’s account is opened to disclose any information that the Regulatory Authority may request regarding the Account Holder’s account;

-to establish, exercise or defend our legal rights;

-In order to detect and control fraud, we may transfer your personal data to third parties, including, but not limited to, so-called Address Verification System Providers, Payment Service Providers and Financial Institutions. In addition, we reserve the right to disclose the Account Holder’s personal data to relevant parties if Top Pay Service has reasonable grounds to suspect irregularities involving a customer with service providers to enable us to provide our services, such as companies that it helps us with technology services, storage and combination of data, as well as payment processing or the provision of online advertising relevant to our products and services;

-external auditors, who may perform independent audits within our accreditations

-to an organization that we sell or transfer (or with which we enter into sale or transfer negotiations) with any of our business or any of our rights or obligations under any agreement we may have with you or the sale has instead, the organization that receives your personal data may use it in the same way as we do; or

-to any other legal successors in our business.


Are we transferring your data outside the EEA?


The personal data we collect from you may be transferred and stored to a destination outside the European Economic Area (EEA). They may also be processed by companies operating outside the EEA and working for us or one of our service providers. For example, the computer servers used to host a website may be located outside the EEA – this is not uncommon, given that the Internet is a global environment. Your personal information may be stored at a destination that offers a different level of data protection than the EEA, including Australia, Serbia, India, USA. To ensure that your personal information remains secure when it is transferred in this way, we will take all reasonable steps to maintain an adequate level of protection in accordance with this Policy.


Any transfer of your personal information to a location outside the EEA will be based on:


-Model contract terms adopted by the European Commission or a relevant data protection authority; or

-a decision on the appropriateness of the European Commission confirming that the third country provides adequate protection for your personal information; or

-Privacy Assurance When Transferring to the US (this is a form of certification that ensures that your data is treated in a manner that is compatible with strong EU safeguards); or

-Your consent or any other legal basis on which we have the right to make the transfer.


How long will Top Pay Service keep my data?


We will retain your information for as long as is reasonably necessary to fulfill the purposes described above and to fulfill our legal obligations. As long as you are our client, we usually need to keep your information in order to meet our legal and contractual requirements. However, when you stop using Top Pay Service, we will normally retain your personal information for a period of time.


More information.


We typically retain your personal information for ten years after you cease to be a Top Pay Service customer, starting with the date your account is closed. There are several reasons we keep your information, including:


-Compliance with legal obligations under EU / local laws (eg anti-money laundering or licensing regulations);

-To establish or defend rights in court (for example, negligence actions) that may be brought against us.


Your rights and choices regarding your personal information

We appreciate that under the law and subject to certain conditions, you have certain rights with respect to the personal information we hold about you. If you wish to exercise these rights, you must contact us using the details in section 3. These rights include the right to access, modify and delete the personal information we hold about you, the right to object to the processing of your data. the right to withdraw consent and the right to data portability. You also have the right to complain to the competent data protection authority if you are concerned about how we process your information. In addition, you have certain rights related to automatic decision-making and „profiling”. Further information and advice on your rights can be obtained from the competent data protection authority in our case, IDPC, or from the data protection regulatory authority in your country.


The right to access and rectify the information we hold about you


You have the right to request a copy of the personal information we hold about you, known as the data subject’s access request. You also have the right to request that the information we hold about you, which may be inaccurate or have changed since you first notified us, be updated or removed. These requests are free and can be emailed. 


The right to delete your data


In certain situations, you may ask us to delete any personal information we hold about you („right to be forgotten”). This includes situations where:


-the information is no longer needed in relation to the purpose for which it was collected (as explained in our privacy notice);

-if you have given your prior consent to the use of your information but have decided to withdraw it, and we cannot justify another legal basis for its use under data protection law;

-we process your information on the basis of our legitimate interests, and we cannot demonstrate any legitimate grounds for continuing to process the information;

-we do not have a legitimate basis under data protection law to process your information;

-the data must be deleted in order to comply with a legal requirement;


This right is subject to mandatory retention periods under EU / local law.


The right to restrict processing


You have the right to ask us to restrict („block” or „delete”) the processing of your personal information. When processing is restricted, we may still store your information, but we will no longer use it. We keep lists of people who have requested that the subsequent use of their information be „blocked” to ensure that the restriction is followed in the future. Your right is available when:


-Contest the accuracy of personal information (as long as we check all aspects);

-the processing is illegal and you object to the deletion of the information and instead request that we restrict the processing;

-we no longer need data, but you request it in order to establish, exercise or defend a right in court; and

-we process your information for legitimate business purposes, but you object; and while verifying the basis for further processing.


The right to data portability

You have the right to receive personal information that you provide to us in a „regular, automatically readable” format. This allows you to obtain and re-use your information for your own purposes for various services. For example, if you choose to switch to another provider, this allows you to easily move, copy or transfer your information between our IT systems and theirs, safely and securely, without affecting their ease of use. However, this is not a general right and only occurs when your information is processed:


-based on your consent or if necessary for the performance of a contract

-when the information is processed exclusively by automatic means.


The right to object


Depending on your particular situation, you may object to the processing of your personal information, which is:


-based on our legitimate business interests (including profiling); or

-performed for research and statistical purposes.


You also have the right to object to the use of your personal information for direct marketing purposes (including profiling), such as when you receive emails from us informing you of other Top Pay Service services. which we think would interest you.


The right to withdraw consent


When we rely on your consent as a basis for the processing of your personal information – such as sales and marketing communications (see section 5D) – you have the right to withdraw your consent at any time. We will always strive to facilitate the withdrawal. your consent by choosing the „unsubscribe” option in every communication you receive from us. If you feel that this is not the case, just contact our Data Protection Officer as described above in Section 3 and we will try to resolve the matter as soon as possible.


Rights related to automatic decision making, including profiling


Sometimes we use systems to make automated decisions based on your personal information. This helps us to make sure that our decisions are fast, fair, efficient, and correct, based on what we know. These automated decisions may affect the products, services, or features we may offer you now or in the future, or the ability to use our services.


We can use automated decision making in the following situations:


-adapting products and services – we can include you in groups with similar customers (segments) to study and discover your preferences and needs and to give you a more tailored experience for you;

-fraud detection – we use your personal information to help you decide and detect whether your account may be used for fraud or money laundering. If we believe there is a risk of fraud, we may block or suspend your account;

-the risk assessment of your bet, as explained in more detail in Section 5A.


The Data Protection Act aims to protect people from the harm that may result from the decision-making process – including profiling – which takes place without human intervention. You have the right not to be subject to a decision – including profiling – when it is based on the automatic processing of your personal information and has a legal or similar significant effect on you.


Please note that the law does not apply when the processing is:


-necessary for the conclusion or conclusion of a contract concluded with you; or

-when it is authorized by law; or

-when it is based on your explicit consent.


Security of your data


Top Pay Service is committed to protecting the personal information you provide to us. We take all reasonable steps to ensure that all information collected through our sites is treated securely and in accordance with this Policy and strict data protection standards. As a result, we have adopted robust procedures and technologies to protect your data from unauthorized access and misuse.




If you wish to make a complaint about how we have handled your personal data, you may contact us to investigate the matter by emailing us at


If you are not satisfied with our response or believe that we are processing your personal data in an illegal manner, you can complain to the competent authority for data protection, in our case, the Office of the Commissioner for Information and Data Protection (IDPC ), or your national data protection authority.


Changes to the Privacy Notice


This privacy notice may be updated periodically to reflect changes in the way we work or the way our business is regulated – so you can check it every time you send us personal information. The date of the most recent revisions will appear on this page. If you do not agree with these changes, please do not continue to send personal information to Top Pay Service or use Top Pay Service in any way. Otherwise, if you continue to do so, we will consider that you have accepted the changes.

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