swn99 Privacy Policy

1. Introduction

swn99 ("swn99," "we," "us," or "our") is committed to protecting the privacy and personal data of all players and visitors who use the swn99 online casino and sports betting platform (the "Platform"). We understand that Filipino players trust us with sensitive personal information, and we take that responsibility seriously.

This Privacy Policy ("Policy") describes the types of personal information swn99 collects, the purposes for which we use it, the circumstances under which we may share it, and the rights you have in relation to your personal data. This Policy applies to all personal data collected through the swn99 website, mobile platform, customer support channels, and any other swn99 services.

This Policy should be read together with the swn99 Terms & Conditions, which govern your use of the Platform. Capitalized terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

2. Data Controller

swn99 is the data controller responsible for the personal data collected through the Platform. As data controller, swn99 determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

swn99 has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data privacy laws. If you have any questions or concerns about how swn99 handles your personal data, you may contact our DPO using the contact details provided in Section 15 of this Policy.

3. Data We Collect

swn99 collects the following categories of personal data from players and visitors:

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued identification numbers (e.g., PhilSys ID number, passport number, driver's license number, UMID number).
• Contact Data: Residential address (including barangay, city, and province), email address, and mobile phone number.
• Account Data: Username, encrypted password, account preferences, communication preferences, and responsible gaming settings.
• Financial Data: GCash account details, PayMaya account details, bank account information (BPI, BDO, Metrobank), transaction history, deposit and withdrawal records, and account balance information.
• Gaming Data: Game history, betting records, wagering activity, bonus usage, and session duration data.
• Technical Data: IP address, device type, operating system, browser type and version, time zone, and platform access logs.
• Usage Data: Information about how you navigate and interact with the swn99 Platform, including pages visited, features used, and time spent on the Platform.
• Communications Data: Records of your communications with swn99 customer support, including chat transcripts, emails, and call recordings where applicable.
• Verification Data: Copies of identity documents and selfie photographs submitted for Know Your Customer (KYC) verification purposes.

swn99 does not intentionally collect special categories of sensitive personal data (such as health data, religious beliefs, or political opinions) unless specifically required by law or regulation.

4. How We Collect Your Data

swn99 collects personal data through the following means:

1. Direct Collection: Data you provide directly when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
2. Automated Collection: Data collected automatically when you access the Platform, including through cookies, web beacons, pixel tags, and server logs. See Section 9 for more details on cookies.
3. Third-Party Sources: Data received from payment processors (such as GCash and PayMaya), identity verification service providers, fraud prevention agencies, and regulatory authorities where permitted by law.
4. Publicly Available Sources: In limited circumstances, swn99 may collect data from publicly available sources for fraud prevention and AML compliance purposes.

5. How We Use Your Data

swn99 uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your swn99 player account, including processing your registration and verifying your identity.
• Service Delivery: To provide you with access to swn99's gaming services, process your deposits and withdrawals, and deliver customer support.
• Legal Compliance: To comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations, PAGCOR reporting requirements, and the Data Privacy Act of 2012.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct on the Platform.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits and self-exclusion.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the functionality, performance, and user experience of the swn99 Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and news about swn99 services, where you have opted in to receive such communications.
• Dispute Resolution: To investigate and resolve disputes, complaints, and legal claims involving your swn99 account.

6. Legal Basis for Processing

swn99 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

1. Contractual Necessity: Processing necessary for the performance of the contract between you and swn99, including account registration, service delivery, and payment processing.
2. Legal Obligation: Processing required to comply with applicable Philippine laws and regulations, including AML obligations, PAGCOR requirements, and tax reporting obligations.
3. Legitimate Interests: Processing necessary for swn99's legitimate interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your data protection rights.
4. Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including for marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7. Sharing Your Data

swn99 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. swn99 may share your personal data with the following categories of recipients in the circumstances described below:

1. Service Providers: Third-party vendors and service providers who assist swn99 in operating the Platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, IT infrastructure providers, and customer support platforms. These providers are contractually bound to process your data only on swn99's instructions and in accordance with applicable data privacy laws.
2. Regulatory Authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other Philippine government agencies where disclosure is required by law, regulation, or court order.
3. Law Enforcement: Philippine law enforcement agencies where disclosure is required in connection with the investigation or prosecution of criminal offences.
4. Business Transfers: In the event that swn99 undergoes a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. swn99 will notify you of any such transfer via email or a prominent notice on the Platform.

8. Data Retention

swn99 retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

1. Active Accounts: Personal data associated with active swn99 accounts is retained for the duration of the account relationship.
2. Closed Accounts: Following account closure, swn99 retains personal data for a minimum of five (5) years in accordance with PAGCOR requirements and Philippine AML regulations. Financial transaction records may be retained for longer periods where required by law.
3. KYC Documents: Identity verification documents are retained for a minimum of five (5) years from the date of submission or account closure, whichever is later.
4. Marketing Data: Where you have opted in to marketing communications, swn99 retains your contact details for marketing purposes until you withdraw your consent or unsubscribe.

When personal data is no longer required, swn99 will securely delete or anonymize it in accordance with our data retention and disposal procedures.

9. Cookies & Tracking Technologies

swn99 uses cookies and similar tracking technologies (including web beacons and pixel tags) to enhance your experience on the Platform, remember your preferences, and analyze how the Platform is used.

• Essential Cookies: Required for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Functional Cookies: Used to remember your preferences, such as language settings and responsible gaming limits.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the swn99 Platform, helping us identify areas for improvement.
• Marketing Cookies: Used to deliver relevant promotional content to you based on your interests and activity on the Platform, where you have consented to receive marketing communications.

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the swn99 Platform.

10. Data Security

swn99 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the swn99 Platform;
• Encryption of sensitive data at rest, including financial data and identity documents;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security assessments and penetration testing of the Platform;
• 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, swn99 will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of the Data Privacy Act of 2012 and its Implementing Rules and Regulations.

While swn99 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for keeping your swn99 login credentials confidential and for notifying swn99 immediately if you suspect any unauthorized access to your account.

11. Your Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by swn99:

1. Right to be Informed: The right to be informed of how your personal data is collected, used, and processed by swn99, as set out in this Policy.
2. Right of Access: The right to request a copy of the personal data swn99 holds about you and information about how it is processed.
3. Right to Rectification: The right to request correction of inaccurate or incomplete personal data held by swn99.
4. 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 swn99's legal retention obligations.
5. Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on swn99's legitimate interests.
6. Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
7. Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe swn99 has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of these rights, please contact swn99 using the details in Section 15. swn99 will respond to all data rights requests within thirty (30) days of receipt, in accordance with the Data Privacy Act of 2012.

12. Children & Minors

The swn99 Platform is strictly intended for persons aged 21 years and above, in accordance with Philippine gaming regulations. swn99 does not knowingly collect personal data from individuals under the age of 21.

If swn99 discovers that personal data has been collected from a person under 21 years of age, swn99 will immediately close the relevant account, return any deposits, and delete the personal data in question. If you believe that swn99 may have inadvertently collected data from a minor, please contact us immediately using the details in Section 15.

13. International Data Transfers

swn99 primarily processes and stores personal data within the Philippines. In limited circumstances, personal data may be transferred to or processed by service providers located outside the Philippines, for example in connection with cloud infrastructure or third-party software services.

Where personal data is transferred outside the Philippines, swn99 ensures that appropriate safeguards are in place to protect your data, including contractual clauses that require the recipient to process your data in accordance with standards equivalent to those required by the Philippine Data Privacy Act of 2012.

14. Changes to This Policy

swn99 reserves the right to update or amend this Privacy Policy at any time. Where changes are material, swn99 will provide reasonable notice to registered players via email or a prominent notice on the Platform prior to the changes taking effect. The date of the most recent revision is indicated at the top of this page.

Your continued use of the swn99 Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree to the amended Policy, you must cease using the Platform and may close your account in accordance with the Terms & Conditions.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or swn99's handling of your personal data, please contact our Data Protection Officer:

Email: [email protected]

The email address above is provided as plain text for informational purposes only. swn99 will acknowledge all data privacy inquiries within three (3) business days and will endeavour to resolve all requests within thirty (30) days in accordance with the Data Privacy Act of 2012.

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you are not satisfied with swn99's response to your data privacy concern.