swerte88 Privacy Policy Data Protection Your Rights Secure & Safe

01 Introduction

This Privacy Policy ("Policy") describes how swerte88 ("swerte88", "we", "us", "our"), the operator of the online gaming platform at swerte88.asia, collects, uses, stores, and protects the personal information of users ("Player", "you", "your") who access or use the swerte88 Platform, including its website, mobile applications, and associated services (collectively, the "Platform").

swerte88 is committed to protecting the privacy and personal data of all Filipino players in accordance with Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission of the Philippines ("NPC"). This Policy also reflects swerte88's obligations under PAGCOR's data governance requirements for licensed online gaming operators.

By registering on or using the swerte88 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 to this Policy, please discontinue use of the Platform immediately.

02 Personal Data We Collect

swerte88 collects only the personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

Identity & Contact Data

• Full legal name (as it appears on your government-issued ID)
• Date of birth (for age verification — 21+ requirement)
• Nationality and country of residence
• Email address and Philippine mobile number
• Residential address

Identity Verification (KYC) Data

• Government-issued photo ID (e.g., Philippine passport, PhilSys ID, SSS ID, UMID, driver's licence)
• Proof of address documents
• Selfie or liveness verification image (where required)

Financial & Transaction Data

• GCash account reference, PayMaya / Maya account reference, or bank account details (account name and number only — never passwords or PINs)
• Deposit and withdrawal transaction history
• Account balance and gaming activity records

Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session logs, login timestamps, and Platform usage patterns
• Cookie and tracking data (see Section 8)

Communications Data

• Records of your communications with swerte88 customer support
• Feedback, survey responses, and promotional opt-in preferences

03 How We Collect Your Data

swerte88 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer 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 8).
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-money laundering screening services; payment confirmation data from payment processors such as GCash and PayMaya.
• Regulatory sources: Data received from PAGCOR or other Philippine regulatory authorities in connection with licensing compliance, self-exclusion registers, or law enforcement requests.

04 How We Use Your Personal Data

swerte88 processes your personal data only for lawful purposes and on the basis of one or more of the following legal grounds: your consent, the performance of a contract with you, compliance with a legal obligation, or our legitimate interests as a licensed gaming operator. Specifically, we use your data to:

• Create, verify, and manage your swerte88 player account.
• Verify your identity and age (21+) in compliance with PAGCOR KYC requirements.
• Process your deposits, withdrawals, and in-game transactions securely.
• Detect, investigate, and prevent fraud, money laundering, and other illegal activity on the Platform.
• Comply with our obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and other applicable Philippine laws.
• Provide customer support and respond to your enquiries and complaints.
• Send you account-related notifications, security alerts, and service updates.
• Send you marketing communications about swerte88 promotions and offers, where you have consented to receive them.
• Analyse Platform usage patterns to improve our games, features, and overall user experience.
• Enforce our Terms & Conditions and other Platform policies.
• Comply with responsible gaming obligations, including monitoring for signs of problem gambling and administering self-exclusion requests.

05 Sharing Your Personal Data

swerte88 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya / Maya, BPI, BDO, Metrobank, UnionBank, and other approved Philippine payment providers, solely to process your financial transactions.
• KYC and identity verification providers: Third-party services engaged to verify your identity documents and perform age verification in compliance with PAGCOR requirements.
• Anti-fraud and AML screening services: Providers that assist swerte88 in detecting and preventing fraudulent activity and money laundering in accordance with the Anti-Money Laundering Act of the Philippines.
• Game software providers: Licensed game developers and studios whose games are hosted on the swerte88 Platform may receive limited technical data necessary to deliver their games.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where disclosure is required by law or regulatory obligation.
• Professional advisers: Lawyers, auditors, and accountants engaged by swerte88, subject to professional confidentiality obligations.
• Business successors: In the event of a merger, acquisition, or sale of swerte88's business, your data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

All third parties with whom swerte88 shares personal data are required to handle that data in accordance with applicable Philippine data protection laws and swerte88's data processing standards.

06 Data Retention

swerte88 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulations. The following general retention periods apply:

• Account and KYC data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLA record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act.
• Customer support communications: Retained for up to three (3) years from the date of the communication.
• Marketing preferences: Retained until you withdraw your consent or request deletion, whichever is earlier.
• Technical and usage logs: Retained for up to twelve (12) months, unless a longer period is required for security investigations.

Upon expiry of the applicable retention period, swerte88 will securely delete or anonymise your personal data in accordance with our data disposal procedures.

07 Data Security

swerte88 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the swerte88 Platform.
• Encryption of sensitive data at rest, including KYC documents and financial records, using industry-standard encryption algorithms.
• Role-based access controls ensuring that swerte88 staff can only access personal data on a strict need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing of the Platform infrastructure.
• Multi-factor authentication options for player accounts to reduce the risk of unauthorised access.
• Incident response procedures to detect, contain, and notify affected players and the NPC of any personal data breach within the timeframes required by Philippine law.

08 Cookies & Tracking Technologies

swerte88 uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyse usage patterns, and deliver relevant content. The following types of cookies may be used on the swerte88 Platform:

• Strictly necessary cookies: Essential for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, preferred game categories, and display options to personalise your swerte88 experience.
• Analytics cookies: Help swerte88 understand how players use the Platform — which games are most popular, where players encounter difficulties, and how to improve the overall experience. Data collected is aggregated and anonymised where possible.
• Marketing cookies: Used to deliver relevant promotional content about swerte88 offers. These are only placed with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the swerte88 Platform. For more information on managing cookies in popular Philippine mobile browsers, refer to your browser's help documentation.

09 Your Data Rights

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in respect of your personal data held by swerte88:

• Right to be informed: You have the right to be informed of how your personal data is being collected and processed — which is the purpose of this Privacy Policy.
• Right of access: You may request a copy of the personal data swerte88 holds about you, along with information about how it is being processed.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to swerte88's legal retention obligations under PAGCOR and AMLA regulations.
• Right to object: You may object to the processing of your personal data for direct marketing purposes at any time.
• Right to data portability: You may request that swerte88 provide your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: If you believe swerte88 has violated your data privacy rights, you may lodge a complaint with the National Privacy Commission of the Philippines (NPC).

To exercise any of the above rights, please contact our Data Protection Officer at [email protected]. swerte88 will respond to all verified data rights requests within thirty (30) days, as required by Philippine law.

10 Minors & Age Policy

The swerte88 Platform is strictly intended for individuals who are at least 21 years of age, in accordance with Philippine gaming regulations. swerte88 does not knowingly collect personal data from individuals under the age of 21.

If swerte88 discovers or has reason to believe that a player is under 21 years of age, the relevant account will be immediately suspended, all funds will be frozen pending investigation, and the matter will be reported to PAGCOR as required. Any personal data collected from an underage individual will be securely deleted upon confirmation of the player's age.

Parents and guardians who believe their child may have registered on the swerte88 Platform are encouraged to contact our support team immediately at [email protected].

11 Cross-Border Data Transfers

In the course of operating the swerte88 Platform, your personal data may be transferred to, stored in, or processed in countries outside the Philippines — for example, where our game software providers or cloud infrastructure partners are located. swerte88 ensures that any such cross-border transfer of personal data is carried out in compliance with Section 21 of the Data Privacy Act of 2012 and the NPC's rules on cross-border data flows.

Specifically, swerte88 will only transfer personal data outside the Philippines where:

• The recipient country provides an adequate level of data protection as recognised by the NPC; or
• Appropriate safeguards are in place, such as data processing agreements incorporating the NPC's standard contractual clauses; or
• The transfer is necessary for the performance of a contract with you (e.g., processing a payment through an international payment gateway).

12 Policy Amendments

swerte88 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or PAGCOR regulatory requirements. When material changes are made, swerte88 will notify registered players by email or by posting a prominent notice on the Platform prior to the changes taking effect.

The "Effective Date" at the top of this Policy indicates when it was last updated. We encourage you to review this Policy periodically to stay informed about how swerte88 protects your personal data. Your continued use of the Platform after the effective date of any revised Policy constitutes your acceptance of the updated terms.

13 Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or swerte88's handling of your personal data, please contact our Data Protection Officer (DPO) through the following channels:

• Email: [email protected]
• Live Chat: Available 24/7 via the swerte88 Platform
• Response Time: swerte88 aims to acknowledge all data privacy enquiries within 72 hours and to resolve them within 30 days.

If you are not satisfied with swerte88's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC) through its official channels.