Privacy Policy — swerte77vip1

1. Introduction

swerte77vip1 ("we," "us," "our," or "the Company") is committed to protecting the privacy and personal data of every player who uses the swerte77vip1 online gaming platform. This Privacy Policy ("Policy") describes how swerte77vip1 collects, uses, stores, shares, and protects personal information in connection with the services offered at swerte77vip1.club.

This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC"). It applies to all natural persons who access or use the swerte77vip1 platform, including registered players, prospective players, and visitors to the swerte77vip1 website.

By registering for a swerte77vip1 account, accessing the swerte77vip1 platform, or otherwise providing your personal data to swerte77vip1, you consent to the collection, processing, and use of your personal data as described in this Policy. If you do not agree with this Policy, please do not use the swerte77vip1 platform.

This Policy should be read together with swerte77vip1's Terms and Conditions and Responsible Gaming Policy, both of which are incorporated herein by reference.

2. Data Controller

For the purposes of the Philippine Data Privacy Act, swerte77vip1 acts as the Personal Information Controller ("PIC") in respect of the personal data it collects and processes in connection with the swerte77vip1 platform. As PIC, swerte77vip1 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable Philippine data privacy law.

swerte77vip1 has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Policy and with the DPA. Contact details for the DPO are provided in Section 16 of this Policy.

3. Personal Data We Collect

swerte77vip1 collects the following categories of personal data from players and platform users:

3.1 Registration and Identity Data

• Full legal name as it appears on your government-issued ID
• Date of birth (used to verify the 21+ age requirement under Philippine law)
• Nationality and country of residence
• Residential address (barangay, city/municipality, province)
• Email address
• Mobile number registered in the Philippines
• Username and encrypted password

3.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (UMID, SSS ID, PhilHealth ID, driver's license, or Philippine passport)
• Proof of address documents (utility bills, bank statements, or barangay certificates)
• Selfie photographs taken for liveness verification purposes
• Payment method ownership documentation (e.g., GCash account screenshots)

3.3 Financial and Transaction Data

• Deposit and withdrawal transaction records, including amounts, dates, and payment method references
• GCash account name and reference numbers (not full account credentials)
• Bank account name and last four digits where applicable
• Bonus and promotional credit history
• Account balance history

3.4 Gaming Activity Data

• Game session logs, including games played, wager amounts, outcomes, and session duration
• Betting history across all swerte77vip1 game categories
• Responsible gaming tool usage (deposit limits set, self-exclusion activations, cooling-off periods)

3.5 Technical and Device Data

• IP address and approximate geolocation (used to verify Philippine residency)
• Device type, operating system, and browser type
• Session timestamps and login history
• Cookie identifiers and similar tracking data (see Section 8)

3.6 Communications Data

• Records of communications between you and the swerte77vip1 support team, including live chat transcripts, email correspondence, and support ticket history
• Feedback and survey responses submitted voluntarily

4. How We Collect Your Data

swerte77vip1 collects personal data through the following means:

• Directly from you — when you register for a swerte77vip1 account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotions
• Automatically — through cookies, web beacons, and similar tracking technologies when you access the swerte77vip1 platform (see Section 8)
• From third-party service providers — including identity verification providers, payment processors, and fraud detection services that swerte77vip1 engages to support platform operations
• From regulatory bodies — swerte77vip1 may receive information from PAGCOR or other Philippine regulatory authorities in connection with its licensing and compliance obligations

5. How We Use Your Personal Data

swerte77vip1 uses the personal data it collects for the following purposes:

swerte77vip1 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by applicable Philippine law.

6. Legal Basis for Processing

Under the Philippine Data Privacy Act, swerte77vip1 processes your personal data on the following legal bases:

• Contractual necessity — processing is necessary to perform the contract between you and swerte77vip1 (i.e., to provide gaming services, process transactions, and manage your account)
• Legal obligation — processing is required to comply with swerte77vip1's obligations under Philippine law, including PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), and the DPA itself
• Legitimate interests — processing is necessary for swerte77vip1's legitimate interests in fraud prevention, platform security, and responsible gaming monitoring, provided those interests are not overridden by your rights and freedoms
• Consent — for processing activities that are not strictly necessary for the above purposes, such as sending you marketing communications, swerte77vip1 relies on your freely given, specific, informed, and unambiguous consent, which you may withdraw at any time

7. Data Sharing and Disclosure

swerte77vip1 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. swerte77vip1 may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

7.1 Service Providers

swerte77vip1 engages trusted third-party service providers to support platform operations, including identity verification providers, payment processors (GCash, PayMaya, and banking partners), cloud hosting providers, customer support software providers, and fraud detection services. These providers act as Personal Information Processors under the DPA and are contractually bound to process your data only on swerte77vip1's instructions and in compliance with applicable Philippine data privacy law.

7.2 Regulatory and Law Enforcement Authorities

swerte77vip1 may disclose your personal data to PAGCOR, the Anti-Money Laundering Council ("AMLC"), the National Privacy Commission, or other Philippine government authorities where required by law, court order, or regulatory directive. swerte77vip1 will notify you of such disclosures where legally permitted to do so.

7.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of swerte77vip1's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. swerte77vip1 will notify affected players of any such transfer in advance where practicable.

8. Cookies and Tracking Technologies

swerte77vip1 uses cookies and similar tracking technologies (web beacons, pixel tags, local storage) to operate and improve the swerte77vip1 platform. Cookies are small text files stored on your device when you visit swerte77vip1.club.

8.1 Types of Cookies Used

• Strictly necessary cookies — essential for the swerte77vip1 platform to function, including session management, login authentication, and security. These cannot be disabled.
• Functional cookies — remember your preferences such as language settings and responsible gaming limits you have set.
• Analytics cookies — collect anonymized data about how players use the swerte77vip1 platform to help us improve performance and user experience.
• Marketing cookies — used with your consent to deliver relevant promotional content about swerte77vip1 offers. You may opt out at any time.

8.2 Managing Cookies

You can control and manage cookies through your browser settings. Please note that disabling strictly necessary cookies will affect the functionality of the swerte77vip1 platform and may prevent you from accessing certain features, including your account. For instructions on managing cookies in your specific browser, refer to your browser's help documentation.

9. Data Security

swerte77vip1 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the swerte77vip1 platform
• AES-256 encryption for sensitive data stored at rest, including KYC documents and financial records
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis
• Regular security audits and penetration testing of the swerte77vip1 platform infrastructure
• Two-factor authentication options for player accounts
• Automated fraud detection and anomaly monitoring systems

While swerte77vip1 takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your swerte77vip1 account credentials and for notifying swerte77vip1 immediately if you suspect any unauthorized access to your account.

10. Data Retention

swerte77vip1 retains your personal data for as long as your account remains active and for such additional periods as are required by applicable Philippine law and PAGCOR regulations. The following general retention periods apply:

• Account and identity data — retained for the duration of your account and for a minimum of five (5) years after account closure, as required by PAGCOR licensing conditions and the Anti-Money Laundering Act
• KYC documents — retained for a minimum of five (5) years after the end of the business relationship, in accordance with AMLA requirements
• Financial transaction records — retained for a minimum of five (5) years from the date of each transaction
• Gaming activity logs — retained for a minimum of three (3) years for responsible gaming monitoring and dispute resolution purposes
• Customer support communications — retained for three (3) years from the date of the last communication
• Marketing consent records — retained until consent is withdrawn and for one (1) year thereafter as evidence of consent

Upon expiry of the applicable retention period, swerte77vip1 will securely delete or anonymize your personal data in accordance with its data disposal procedures.

11. Your Data Privacy Rights

Under the Philippine Data Privacy Act, you have the following rights in relation to your personal data held by swerte77vip1:

• Right to be informed — you have the right to be informed of how your personal data is being collected and processed, as set out in this Policy
• Right of access — you have the right to request a copy of the personal data swerte77vip1 holds about you
• Right to rectification — you have the right to request correction of any inaccurate or incomplete personal data swerte77vip1 holds about you
• Right to erasure — you have 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 swerte77vip1's legal retention obligations
• Right to object — you have 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 — you have the right to receive your personal data in a structured, commonly used, and machine-readable format
• Right to lodge a complaint — you have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe swerte77vip1 has violated your data privacy rights

To exercise any of these rights, please contact swerte77vip1's Data Protection Officer at [email protected]. swerte77vip1 will respond to all data privacy rights requests within thirty (30) days of receipt, as required by the DPA IRR.

Please note that certain rights may be limited where swerte77vip1 is required to retain or process your data to comply with its legal obligations under PAGCOR regulations or the Anti-Money Laundering Act.

12. Children's Privacy and Age Restriction

The swerte77vip1 platform is strictly intended for persons who are at least twenty-one (21) years of age, as required under Philippine law for participation in casino-style gambling activities. swerte77vip1 does not knowingly collect personal data from persons under 21 years of age.

swerte77vip1 employs age verification measures during the registration process and through KYC verification to prevent underage access. If swerte77vip1 becomes aware that it has inadvertently collected personal data from a person under 21 years of age, it will promptly close the associated account, delete the personal data, and return any deposits made.

If you are a parent or guardian and believe that a minor has registered with swerte77vip1, please contact us immediately at [email protected].

13. Cross-Border Data Transfers

swerte77vip1 primarily processes and stores personal data within the Republic of the Philippines. Where swerte77vip1 engages third-party service providers located outside the Philippines — for example, cloud infrastructure providers or international identity verification services — personal data may be transferred to and processed in other jurisdictions.

swerte77vip1 ensures that any cross-border transfer of personal data is subject to appropriate safeguards, including contractual data processing agreements that require the recipient to provide a level of data protection equivalent to that required under the Philippine Data Privacy Act. swerte77vip1 will not transfer personal data to jurisdictions that do not provide adequate data protection without first obtaining your explicit consent or as otherwise permitted by the NPC.

14. Third-Party Links

The swerte77vip1 platform may contain links to third-party websites or services for informational purposes. swerte77vip1 is not responsible for the privacy practices or content of any third-party websites. This Policy applies solely to personal data collected by swerte77vip1 through the swerte77vip1 platform. We encourage you to review the privacy policies of any third-party websites you visit.

15. Updates to This Privacy Policy

swerte77vip1 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, PAGCOR regulatory requirements, or swerte77vip1's data processing practices. The "Last Updated" date at the top of this page will be revised whenever material changes are made.

Where changes are material, swerte77vip1 will notify registered players via email or a prominent notice on the swerte77vip1 platform prior to the changes taking effect. Your continued use of the swerte77vip1 platform after the effective date of any updated Policy constitutes your acceptance of the revised terms.

swerte77vip1 encourages you to review this Privacy Policy periodically to stay informed about how your personal data is being protected.

16. Contact and Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or to swerte77vip1's handling of your personal data, please contact our Data Protection Officer:

• Data Protection Officer: swerte77vip1 DPO
• Privacy Email: [email protected]
• General Support: [email protected]
• Response Time: Within 30 days of receipt, as required by the DPA IRR
• Languages: English and Filipino-English

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. Information about the NPC and how to file a complaint is available through official Philippine government channels.