swertes99 Privacy Policy

1. Introduction

swertes99 ("we," "us," "the Company," or "swertes99") operates the online gaming platform accessible at swertes99.asia (the "Platform"). We are committed to protecting the privacy and personal data of all players, visitors, and users of the Platform ("you" or "Data Subject").

This Privacy Policy describes how swertes99 collects, uses, stores, shares, and protects your personal information in connection with your use of the Platform. It is prepared in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC).

By registering on or using the swertes99 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the Platform immediately.

2. Personal Data We Collect

swertes99 collects the following categories of personal data from players and users of the Platform:

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification numbers (e.g., Philippine passport number, SSS/UMID number, driver's license number).
• Contact Data: Email address, Philippine mobile number, and residential address (including city, province, and postal code).
• Financial Data: GCash account details, PayMaya account details, bank account information (BPI, BDO, Metrobank), transaction history, deposit and withdrawal records, and account balance information.
• Account Data: Username, encrypted password, account registration date, login history, session data, and account preferences.
• Gaming Data: Game history, betting records, wagering activity, bonus usage, and responsible gaming tool settings.
• Technical Data: IP address, device type, browser type and version, operating system, and platform access logs.
• KYC Documentation: Copies of government-issued photo identification and proof of address documents submitted during identity verification.
• Communications Data: Records of your communications with swertes99 support, including live chat transcripts and email correspondence.

swertes99 does not collect sensitive personal information (as defined under the Data Privacy Act) unless strictly required for regulatory compliance purposes, in which case your explicit consent will be obtained.

3. How We Collect Your Data

swertes99 collects personal data through the following means:

• Direct Collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated Collection: Technical data collected automatically when you access the Platform, including through cookies, web beacons, and server logs. See Section 9 for details on our cookie practices.
• Third-Party Sources: Identity verification data from licensed KYC service providers; fraud prevention data from anti-money laundering screening services; payment data from licensed payment processors (GCash, PayMaya, BPI, BDO, Metrobank).
• Regulatory Sources: Data received from PAGCOR or other regulatory authorities in connection with compliance obligations, including self-exclusion registry checks.

4. How We Use Your Personal Data

swertes99 uses your personal data for the following purposes:

• To create, manage, and maintain your swertes99 player account.
• To verify your identity and age (21+) in compliance with PAGCOR regulations and Philippine law.
• To process deposits, withdrawals, and other financial transactions in Philippine Peso (PHP).
• To detect, investigate, and prevent fraud, money laundering, and other illegal activities in compliance with the Anti-Money Laundering Act (AMLA).
• To provide customer support and respond to your inquiries via live chat and email.
• To administer bonuses, promotions, and loyalty programs you have opted into.
• To enforce our Terms and Conditions and other platform policies.
• To send you transactional communications (account notifications, deposit confirmations, withdrawal updates) and, where you have consented, promotional communications.
• To improve the Platform's functionality, user experience, and game offerings through aggregated analytics.
• To comply with applicable Philippine laws, PAGCOR regulatory requirements, and NPC obligations.

swertes99 does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review.

5. Legal Basis for Processing

swertes99 processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to perform our obligations under the Terms and Conditions you have agreed to, including account management, payment processing, and game provision.
• Legal Obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulations, the AMLA, and the Data Privacy Act itself.
• Legitimate Interests: Processing necessary for swertes99's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

swertes99 does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients only where necessary and lawful:

• Payment Processors: Licensed payment service providers (GCash, PayMaya, BPI, BDO, Metrobank, InstaPay) to process your financial transactions.
• KYC and AML Service Providers: Licensed identity verification and anti-money laundering screening providers engaged to fulfill our regulatory compliance obligations.
• Game Content Providers: Third-party game studios and software providers whose games are available on the Platform, to the extent necessary for game operation and dispute resolution.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government authorities where required by law or regulatory mandate.
• Legal and Professional Advisors: Lawyers, auditors, and other professional advisors engaged by swertes99 under obligations of confidentiality.
• Law Enforcement: Philippine law enforcement agencies where required by a valid court order, subpoena, or other lawful legal process.

All third-party service providers engaged by swertes99 are contractually required to process your data only for the specified purpose and to maintain appropriate security standards consistent with the Data Privacy Act.

7. Data Retention

swertes99 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations.

Specifically:

• Account Data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements.
• Financial and Transaction Data: Retained for a minimum of five (5) years from the date of the transaction, as required under the Anti-Money Laundering Act and its implementing rules.
• KYC Documentation: Retained for a minimum of five (5) years following the end of the business relationship, or longer if required by a regulatory authority or ongoing legal proceeding.
• Communications Data: Support chat transcripts and email records are retained for up to three (3) years from the date of the communication.
• Technical and Log Data: Server logs and access records are retained for up to twelve (12) months, unless required for longer periods in connection with a security investigation or legal matter.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with swertes99's data disposal procedures. Anonymized or aggregated data that can no longer identify you may be retained indefinitely for analytical purposes.

8. Data Security

swertes99 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption in Transit: All data transmitted between your device and the swertes99 Platform is protected using TLS 1.2 or higher encryption protocols.
• Encryption at Rest: Sensitive personal data stored on swertes99 servers is encrypted using industry-standard AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized swertes99 personnel on a strict need-to-know basis. All access is logged and regularly audited.
• Two-Factor Authentication: swertes99 supports and encourages the use of SMS OTP-based two-factor authentication for all player accounts.
• Regular Security Audits: The Platform undergoes periodic security assessments and penetration testing by qualified security professionals.
• Staff Training: All swertes99 personnel with access to personal data receive regular data privacy and security training.

While swertes99 takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your own account credentials. If you suspect unauthorized access to your account, contact our support team immediately.

9. Cookies and Tracking Technologies

swertes99 uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit the Platform. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function correctly, including maintaining your login session and enabling secure transactions. These cannot be disabled.
• Functional Cookies: Remember your preferences and settings (such as language and display preferences) to provide a more personalized experience.
• Analytics Cookies: Collect aggregated, anonymized data about how players use the Platform to help us improve performance and user experience. No personally identifiable information is shared with analytics providers.
• Security Cookies: Used to detect and prevent fraudulent activity, bot access, and other security threats on the Platform.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. swertes99 does not use cookies to serve third-party advertising or to track your activity across unrelated websites.

10. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by swertes99:

• Right to Be Informed: The right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy.
• Right of Access: The right to request a copy of the personal data swertes99 holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate, incomplete, or outdated personal data we hold about you.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to applicable legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 13. swertes99 will respond to all valid data subject requests within fifteen (15) business days of receipt, or within the timeframe required by applicable law.

Please note that certain rights may be subject to limitations where processing is required for compliance with a legal obligation, the performance of a contract, or the establishment, exercise, or defense of legal claims.

11. Children's Privacy

The swertes99 Platform is strictly intended for adults aged 21 years and above, in accordance with PAGCOR regulations governing online gaming in the Philippines. swertes99 does not knowingly collect personal data from individuals under the age of 21.

If swertes99 becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the Platform, please notify our support team immediately.

Parents and guardians are encouraged to use parental control tools and to monitor the online activities of minors in their care to prevent access to age-restricted gaming platforms.

12. Changes to This Privacy Policy

swertes99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The "Last Updated" date at the top of this page will be revised accordingly.

Where changes are material — meaning they significantly affect your rights or how we process your personal data — swertes99 will notify registered players via email or a prominent notice on the Platform at least fourteen (14) days before the changes take effect.

Your continued use of the swertes99 Platform following the effective date of any revised Privacy Policy constitutes your acknowledgment of the updated terms. We encourage you to review this page periodically to stay informed of how swertes99 protects your data.

13. Contact Us and Data Protection Officer

swertes99 has appointed a Data Protection Officer (DPO) in compliance with the Data Privacy Act of 2012. If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact us through the following channels:

• Data Protection Officer: dpo@swertes99.asia
• General Support: support@swertes99.asia
• Live Chat: Available 24/7 through the swertes99 Platform
• Support Hours: 24 hours a day, 7 days a week, including Philippine public holidays

Our support team includes Filipino-speaking agents available to assist players from Manila, Cebu, Davao, Quezon City, Makati, and all regions across the Philippines. We aim to acknowledge all privacy-related inquiries within two (2) business days.

If you are not satisfied with our response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, the regulatory body responsible for enforcing the Data Privacy Act.