Privacy Policy – swete99

1. Introduction

1.1 This Privacy Policy applies to all personal data collected by swete99 through the swete99.org website, mobile-optimized platform, customer support channels, and any other services we provide (collectively, the "Service").

1.2 swete99 is committed to complying 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). Where applicable, we also observe internationally recognized data protection principles.

1.3 This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, which together form the complete agreement governing your use of swete99.

1.4 If you have any questions about this Privacy Policy or how swete99 handles your personal data, please contact our Data Protection Officer (DPO) using the details provided in Section 14.

2. Personal Data We Collect

2.1 swete99 collects the following categories of personal data from users:

Identity & Contact Data:

• Full legal name, date of birth, and gender;
• Philippine mobile number and email address;
• Government-issued identification documents (e.g., Philippine passport, PhilSys ID, SSS ID, driver's license) submitted during KYC verification;
• Proof of address (e.g., utility bill, bank statement).

Financial Data:

• GCash or Maya account number (mobile number) used for transactions;
• Bank account details (account name, account number, bank name) for bank transfer transactions;
• Debit card details (card number, expiry date) where applicable;
• Transaction history, deposit amounts, withdrawal amounts, and account balances.

Technical & Usage Data:

• IP address, device type, operating system, and browser type;
• Login timestamps, session duration, and pages visited;
• Game history, wagering activity, and bonus usage;
• Cookies and similar tracking technologies (see Section 7).

Communications Data:

• Records of your communications with swete99 customer support, including live chat transcripts and email correspondence;
• Feedback, survey responses, and promotional opt-in preferences.

2.2 swete99 does not intentionally collect sensitive personal information (as defined under RA 10173) beyond what is strictly necessary for identity verification and regulatory compliance purposes.

3. How We Collect Your Data

3.1 swete99 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 and usage data collected automatically through cookies, web beacons, server logs, and similar technologies when you access and use the swete99 platform;
• Third-party sources: Identity verification data from KYC service providers; transaction data from payment processors (GCash, Maya, banks); fraud prevention data from third-party risk management services.

3.2 Where swete99 collects personal data from third-party sources, we ensure that such collection is lawful and that the third party has the appropriate authority to share the data with us.

4. How We Use Your Personal Data

4.1 swete99 uses your personal data for the following purposes:

• To create and manage your swete99 player account;
• To verify your identity and age (21+) in compliance with PAGCOR regulations and RA 10173;
• To process deposits and withdrawals via GCash, Maya, bank transfer, and debit card;
• To provide, maintain, and improve the swete99 gaming platform and services;
• To detect, investigate, and prevent fraud, money laundering, and other illegal activities;
• To enforce our Terms & Conditions and Responsible Gaming policies;
• To send you transactional communications (e.g., deposit confirmations, withdrawal notifications, account alerts);
• To send you promotional communications about swete99 offers and bonuses, where you have opted in to receive such communications;
• To comply with applicable laws, regulations, and regulatory requests, including PAGCOR reporting obligations;
• To analyze platform usage and improve user experience through aggregated, anonymized analytics.

4.2 swete99 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

5. Legal Basis for Processing

5.1 swete99 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you (i.e., to provide the swete99 gaming service, process transactions, and manage your account);
• Legal obligation: Processing required to comply with applicable laws and regulations, including PAGCOR licensing requirements, anti-money laundering (AML) obligations under the AMLA, and tax reporting requirements;
• Legitimate interests: Processing necessary for swete99's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and interests;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, such as for marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Data Sharing & Disclosure

6.1 swete99 may share your personal data with the following categories of recipients:

• Payment processors: GCash (Mynt – Globe Fintech Innovations, Inc.), Maya (PayMaya Philippines, Inc.), and Philippine banks (BPI, BDO, Metrobank, UnionBank, etc.) for the purpose of processing your deposits and withdrawals;
• KYC and identity verification providers: Third-party services engaged to verify your identity and age in compliance with regulatory requirements;
• Fraud prevention and risk management services: Third-party providers that assist swete99 in detecting and preventing fraudulent activity;
• Game content providers: Third-party game studios and providers whose games are available on the swete99 platform, to the extent necessary to deliver the gaming service;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where required by law or regulatory obligation;
• Professional advisers: Lawyers, auditors, and other professional advisers engaged by swete99 in connection with the operation of its business, subject to confidentiality obligations.

6.2 swete99 does not sell, rent, or otherwise transfer your personal data to third parties for their own marketing purposes.

6.3 Where swete99 engages third-party service providers to process personal data on its behalf, we ensure that appropriate data processing agreements are in place and that such providers implement adequate security measures.

7. Cookies & Tracking Technologies

7.1 swete99 uses cookies and similar tracking technologies (collectively, "Cookies") to enhance your experience on the platform. Cookies are small text files stored on your device when you visit swete99.org.

7.2 swete99 uses the following types of Cookies:

• Strictly necessary cookies: Essential for the operation of the swete99 platform, including session management and security. These cannot be disabled.
• Functional cookies: Used to remember your preferences (e.g., language settings, display preferences) to provide a more personalized experience.
• Analytics cookies: Used to collect aggregated, anonymized data about how users interact with swete99, helping us improve the platform. No personally identifiable information is shared with analytics providers.

7.3 You can manage or disable non-essential Cookies through your browser settings. Please note that disabling certain Cookies may affect the functionality of the swete99 platform.

7.4 swete99 does not use Cookies to serve third-party advertising or to track your activity across other websites.

8. Data Retention

8.1 swete99 retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, regulatory, accounting, and reporting requirements.

8.2 In general, swete99 retains player account data for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act (AMLA) retention obligations.

8.3 Financial transaction records are retained for a minimum of five (5) years from the date of the transaction, as required by the AMLA and its implementing rules.

8.4 Where personal data is no longer required for any lawful purpose, swete99 will securely delete or anonymize it in accordance with our data retention schedule.

9. Data Security

9.1 swete99 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit;
• Encryption of sensitive data at rest;
• Role-based access controls limiting data access to authorized personnel only;
• Regular security audits and vulnerability assessments;
• Two-factor authentication ( 2FA) for internal system access;
• Intrusion detection and real-time monitoring systems;
• Staff training on data privacy and security best practices.

9.2 While swete99 takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. swete99 cannot guarantee absolute security but is committed to maintaining industry-standard protections at all times.

9.3 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, swete99 will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected users without undue delay, in accordance with RA 10173 and NPC Circular No. 16-03.

10. Your Rights as a Data Subject

10.1 Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by swete99:

• Right to be informed: You have the right to be informed of how your personal data is being collected and processed, as described in this Privacy Policy;
• Right of access: You have the right to request a copy of the personal data swete99 holds about you, along with information about how it is being used;
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold 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 swete99's legal retention obligations;
• Right to object: You have the right to object to the processing of your personal data on grounds relating to your particular situation, including processing for direct marketing purposes;
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible;
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe swete99 has violated your data privacy rights.

10.2 To exercise any of the rights listed above, please contact our Data Protection Officer using the details in Section 14. swete99 will respond to all valid data subject requests within thirty (30) days of receipt, in accordance with NPC guidelines.

10.3 swete99 may need to verify your identity before processing a data subject request to ensure that personal data is not disclosed to unauthorized parties.

11. Children's Privacy

11.1 swete99 is strictly an adult platform. In accordance with PAGCOR regulations and Philippine law, the minimum age to register and use swete99 is twenty-one (21) years. swete99 does not knowingly collect personal data from individuals under the age of 21.

11.2 If swete99 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. Any winnings or balances associated with an underage account will be forfeited.

11.3 If you believe that a minor has registered on swete99, please contact our support team immediately so that we can investigate and take appropriate action.

12. Third-Party Links

12.1 The swete99 platform may contain links to third-party websites or services for informational purposes. swete99 is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit.

12.2 The inclusion of any third-party link on swete99 does not constitute an endorsement of that third party's website, products, or services.

13. Changes to This Privacy Policy

13.1 swete99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. The "Last Updated" date at the top of this page will be revised accordingly.

13.2 Where changes to this Privacy Policy are material, swete99 will notify registered users via email or in-platform notification at least seven (7) days before the changes take effect.

13.3 Your continued use of the swete99 platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree to the revised Policy, you must cease using the Service and may close your account in accordance with our Terms & Conditions.

13.4 The most current version of this Privacy Policy is always available at swete99.org/privacy-policy.

14. Contact & Data Protection Officer

14.1 swete99 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data or this Privacy Policy, please contact our DPO:

• Data Protection Officer: swete99 DPO
• Email: [email protected]
• General Support Email: [email protected]
• Response Time: We aim to respond to all privacy-related enquiries within 30 days of receipt

14.2 For general account support, live chat is available daily from 8:00 AM to 12:00 MN (PHT) through the swete99 platform.

14.3 For complaints that cannot be resolved directly with swete99, you may contact the National Privacy Commission (NPC) of the Philippines through their official government channels.