swerte9 Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") is issued by swerte9 ("swerte9," "we," "us," or "our") and applies to all personal information collected through the swerte9 website at https://swerte9.net, its associated mobile interfaces, and all related services (collectively, the "Platform").

swerte9 is committed to protecting the privacy and security of all personal information entrusted to us by our players, visitors, and other individuals whose data we process. We operate in compliance 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) of the Philippines.

By accessing or using the swerte9 Platform, you acknowledge that you have read and understood this Policy and consent to the collection, use, and processing of your personal information as described herein. If you do not agree with this Policy, please discontinue use of the Platform immediately.

This Policy applies to all registered players, prospective players, visitors to the swerte9 website, and any other individuals whose personal information is processed by swerte9 in connection with the Platform.

2. Personal Information We Collect

swerte9 collects the following categories of personal information:

• Identity Information: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (e.g., Philippine National ID, SSS, GSIS, TIN, passport, driver's license).
• Contact Information: Email address, mobile number, and residential address (including barangay, city/municipality, province, and postal code).
• Account Information: Username, encrypted password, account preferences, and communication settings.
• Financial Information: GCash account details, PayMaya/Maya account details, Philippine bank account information (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), debit card details, transaction history, deposit and withdrawal records, and account balance information.
• Gaming Activity Data: Game history, betting patterns, session duration, win/loss records, and bonus usage.
• Device and Technical Information: IP address, device type, operating system, browser type and version, screen resolution, and unique device identifiers.
• Usage Data: Pages visited, features used, time spent on the Platform, click patterns, and navigation paths.
• Communications Data: Records of your communications with swerte9 customer support, including live chat transcripts and email correspondence.
• Verification Documents: Copies of government-issued IDs, proof of address, and proof of payment method ownership submitted for KYC verification purposes.

3. How We Collect Your Information

swerte9 collects personal information 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 and usage data collected automatically through cookies, web beacons, log files, and similar tracking technologies when you access the Platform.
• Third-Party Sources: Information received from payment service providers (such as GCash and PayMaya) in connection with financial transactions, identity verification service providers, and fraud prevention partners.
• Publicly Available Sources: Information that is publicly available and relevant to our compliance obligations, such as information from public records or regulatory databases.

4. How We Use Your Information

swerte9 uses your personal information for the following purposes:

• Account Management: To create, maintain, and manage your swerte9 account, including processing your registration and verifying your identity.
• Service Delivery: To provide you with access to swerte9 games, process your deposits and withdrawals, and deliver the services you have requested.
• KYC and Compliance: To verify your identity and age (21+), comply with anti-money laundering (AML) obligations, and meet other regulatory requirements applicable to online gaming operators in the Philippines.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats to the Platform and its users.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits, loss limits, and self-exclusion.
• Marketing and Promotions: To send you information about swerte9 promotions, bonuses, and new features, where you have consented to receive such communications. You may opt out at any time.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the functionality, performance, and user experience of the swerte9 Platform.
• Legal Obligations: To comply with applicable Philippine laws, regulations, court orders, and regulatory directives.

5. Legal Basis for Processing

swerte9 processes your personal information on the following legal bases under the Philippine Data Privacy Act of 2012:

• Consent: Where you have given your explicit consent to the processing of your personal information for a specific purpose, such as receiving marketing communications.
• Contractual Necessity: Where processing is necessary for the performance of the contract between you and swerte9, including account registration, game access, and financial transactions.
• Legal Obligation: Where processing is required to comply with a legal obligation applicable to swerte9, including AML compliance, KYC requirements, and regulatory reporting.
• Legitimate Interests: Where processing is necessary for the legitimate interests of swerte9, such as fraud prevention, platform security, and service improvement, provided that such interests are not overridden by your rights and freedoms.

6. Sharing and Disclosure of Information

swerte9 does not sell, rent, or trade your personal information to third parties for their own marketing purposes. We may share your personal information with the following categories of recipients, strictly on a need-to-know basis:

• Payment Service Providers: GCash, PayMaya/Maya, and Philippine banking partners, for the purpose of processing your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and AML compliance service providers who assist us in verifying your identity and meeting our regulatory obligations.
• Technology and Infrastructure Partners: Cloud hosting providers, cybersecurity firms, and software vendors who support the operation of the swerte9 Platform, subject to strict data processing agreements.
• Regulatory Authorities: Philippine government agencies, including the National Privacy Commission, relevant gaming regulatory bodies, and law enforcement authorities, where required by law or court order.
• Professional Advisors: Legal counsel, auditors, and other professional advisors, where necessary for the conduct of swerte9's business operations.

All third parties with whom swerte9 shares personal information are required to maintain appropriate technical and organizational security measures and to process personal information only in accordance with swerte9's instructions and applicable Philippine data privacy law.

7. Data Retention

swerte9 retains your personal information for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

Specifically:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with Philippine AML record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction.
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship.
• Customer Support Records: Retained for a minimum of two (2) years from the date of the last interaction.
• Marketing Preferences: Retained until you withdraw your consent or request deletion, subject to any overriding legal retention obligations.

When personal information is no longer required, swerte9 will securely delete or anonymize it in accordance with our data disposal procedures.

8. Data Security

swerte9 implements appropriate technical and organizational security measures to protect your personal information against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the swerte9 Platform.
• Encryption of sensitive data at rest, including financial information and government ID details.
• Multi-factor authentication options for account access.
• Regular security audits, penetration testing, and vulnerability assessments.
• Strict access controls limiting employee access to personal information on a need-to-know basis.
• Staff training on data privacy and security obligations.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, swerte9 will notify the National Privacy Commission and affected individuals in accordance with the requirements of the Philippine Data Privacy Act and NPC Circular No. 16-03.

9. Cookies and Tracking Technologies

swerte9 uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security functions. The types of cookies we use include:

• Essential Cookies: Necessary for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Functional Cookies: Remember your preferences and settings to provide a more personalized experience.
• Analytics Cookies: Help us understand how players use the Platform so we can improve its performance and content.
• Security Cookies: Used to detect and prevent fraudulent activity and unauthorized access.

You may control cookie settings through your browser preferences. Please note that disabling certain cookies may affect the functionality of the swerte9 Platform. By continuing to use the Platform, you consent to our use of cookies as described in this Policy.

10. Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal information held by swerte9:

• Right to Be Informed: The right to be informed of how your personal information is being collected and processed.
• Right to Access: The right to request a copy of the personal information swerte9 holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal information.
• Right to Erasure or Blocking: The right to request deletion or blocking of your personal information where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations.
• Right to Object: The right to object to the processing of your personal information for direct marketing purposes or on grounds relating to your particular situation.
• Right to Data Portability: The right to receive your personal information in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the contact details provided in Section 13 of this Policy. swerte9 will respond to all verified requests within thirty (30) days of receipt.

11. Children's Privacy

The swerte9 Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. swerte9 does not knowingly collect personal information from individuals under the age of 21.

If swerte9 becomes aware that personal information has been collected from a person under the age of 21, we will take immediate steps to delete such information and close the associated account. If you believe that a minor has registered on the swerte9 Platform, please contact us immediately at [email protected].

12. Changes to This Privacy Policy

swerte9 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 date of the most recent revision is indicated at the top of this page.

When material changes are made to this Policy, swerte9 will notify registered players via email or a prominent notice on the Platform. Your continued use of the swerte9 Platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how swerte9 protects your personal information.

13. Contact and Data Protection Officer

swerte9 has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Philippine Data Privacy Act of 2012. If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal information, please contact us through the following channels:

• Data Protection Officer Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 through the swerte9 Platform
• Response Time: swerte9 aims to respond to all data privacy inquiries within thirty (30) days of receipt.

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through their official website and offices in Manila.