Privacy Policy — swerte77vip2

01 Introduction

swerte77vip2 ("we," "us," "our," or "the Platform") operates the online gaming platform accessible at swerte77vip2.club. We are committed to protecting the privacy and personal data of every player, visitor, and user ("you" or "Data Subject") who interacts with our platform.

This Privacy Policy describes how swerte77vip2 collects, uses, stores, shares, and protects your personal information in connection with your use of our website, mobile platform, games, and related services (collectively, the "Services"). It also explains the rights available to you under the Republic Act No. 10173 — Data Privacy Act of 2012 of the Philippines and its Implementing Rules and Regulations.

This Privacy Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, which are incorporated herein by reference. By accessing or using the swerte77vip2 platform, you acknowledge that you have read and understood this Privacy Policy.

02 Personal Data We Collect

swerte77vip2 collects only the personal data that is necessary for the purposes described in this Privacy Policy. The categories of personal data we may collect include:

2.1 Identity & Contact Data

• Full legal name as it appears on your government-issued ID
• Date of birth (for 21+ age verification)
• Nationality and country of residence
• Email address and mobile phone number
• Residential address (barangay, city/municipality, province, ZIP code)

2.2 Verification & KYC Data

• Copies of government-issued identification documents (e.g., Philippine passport, PhilSys ID, SSS ID, UMID, driver's license)
• Proof of address documents (e.g., utility bills, bank statements)
• Selfie or liveness verification images where required
• Source of funds declarations where required by AML regulations

2.3 Financial & Transaction Data

• Payment method details (GCash account number, Maya account, bank account details — stored in tokenized form only)
• Deposit and withdrawal transaction history
• Account balance and bonus balance information

2.4 Gaming Activity Data

• Game session history, bet amounts, win/loss records
• Bonus and promotion participation records
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status)

2.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Cookie identifiers and session tokens
• Login timestamps and access logs

2.6 Communications Data

• Records of your communications with swerte77vip2 customer support (live chat transcripts, email correspondence)
• Survey responses and feedback submissions

03 How We Collect Your Data

swerte77vip2 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the swerte77vip2 platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification and fraud prevention data from licensed KYC service providers; payment verification data from payment processors such as GCash and Maya; publicly available information for AML screening purposes.

04 How We Use Your Personal Data

swerte77vip2 uses your personal data for the following purposes:

Purpose	Data Used	Legal Basis
Account registration and management	Identity, contact, verification data	Contractual necessity
Age verification (21+ compliance)	Date of birth, KYC documents	Legal obligation
Processing deposits and withdrawals	Financial and transaction data	Contractual necessity
Anti-money laundering (AML) screening	Identity, financial, transaction data	Legal obligation
Fraud detection and prevention	Technical, device, transaction data	Legitimate interest
Responsible gaming monitoring	Gaming activity, account data	Legal obligation / legitimate interest
Customer support and dispute resolution	Identity, communications data	Contractual necessity
Platform improvement and analytics	Technical, gaming activity data	Legitimate interest
Promotional communications (opt-in only)	Contact, gaming activity data	Consent
Regulatory reporting and compliance	Identity, financial, transaction data	Legal obligation

swerte77vip2 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.

05 Legal Basis for Processing

swerte77vip2 processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual Necessity: Processing is necessary to perform our obligations under the Terms & Conditions you agreed to when registering your swerte77vip2 account, including account management, game provision, and payment processing.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including KYC and AML obligations under the Anti-Money Laundering Act (AMLA), age verification requirements, and regulatory reporting to relevant authorities.
• Legitimate Interest: Processing is necessary for the legitimate interests of swerte77vip2, including fraud prevention, platform security, responsible gaming monitoring, and service improvement, provided such interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities — such as sending you promotional communications or marketing materials — we rely on your freely given, specific, informed, and unambiguous consent. You may withdraw your consent at any time by contacting our support team or updating your account communication preferences.

06 Data Sharing & Disclosure

swerte77vip2 does not sell, rent, or trade your personal data to third-party marketers. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Privacy Policy:

6.1 Service Providers

We engage trusted third-party service providers who process personal data on our behalf under strict data processing agreements, including:

• KYC and identity verification providers
• Payment processors (GCash, Maya, and partner banks)
• Cloud hosting and infrastructure providers
• Customer support platform providers
• Fraud detection and cybersecurity service providers
• Analytics and platform performance providers

All service providers are contractually required to process personal data only on swerte77vip2's documented instructions and to implement appropriate technical and organizational security measures.

6.2 Regulatory & Law Enforcement Authorities

swerte77vip2 may disclose personal data to Philippine government agencies, regulatory bodies, or law enforcement authorities where required by law, court order, or regulatory directive. This includes disclosures to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent authorities.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of swerte77vip2's business assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer in accordance with applicable law.

07 Cookies & Tracking Technologies

swerte77vip2 uses cookies and similar tracking technologies to operate and improve the platform. A cookie is a small text file stored on your device when you visit our website. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication tokens, security cookies, and load-balancing cookies. These cannot be disabled without affecting platform functionality.
• Functional Cookies: Remember your preferences such as language settings, display preferences, and responsible gaming tool configurations to provide a more personalized experience.
• Analytics Cookies: Help us understand how players interact with the swerte77vip2 platform — which pages are visited most, where users encounter issues, and how we can improve the overall experience. Data collected is aggregated and anonymized where possible.
• Security & Fraud Prevention Cookies: Used to detect and prevent fraudulent activity, unauthorized account access, and bot traffic on the swerte77vip2 platform.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the swerte77vip2 platform. swerte77vip2 does not use third-party advertising or behavioral targeting cookies.

08 Data Security

swerte77vip2 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security measures include:

• Encryption: All data in transit is protected by 256-bit SSL/TLS encryption. Sensitive data at rest — including payment method details and identity documents — is encrypted using AES-256 encryption.
• Access Controls: Personal data is accessible only to authorized swerte77vip2 personnel and service providers who require it to perform their functions. Role-based access controls and multi-factor authentication are enforced for all internal systems.
• Network Security: Our infrastructure is protected by firewalls, intrusion detection systems, and regular penetration testing conducted by independent security specialists.
• Data Pseudonymization: Where feasible, personal data used for analytics and platform improvement is pseudonymized or anonymized to reduce privacy risk.
• Incident Response: swerte77vip2 maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission and affected Data Subjects within the timeframes prescribed by the Data Privacy Act.

09 Data Retention

swerte77vip2 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. Our general retention periods are as follows:

• 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 AML record-keeping requirements under the Anti-Money Laundering Act.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of the transaction, as required by applicable financial regulations.
• Gaming activity logs: Retained for a minimum of three (3) years for responsible gaming monitoring and dispute resolution purposes.
• Customer support communications: Retained for two (2) years from the date of the last interaction, unless a longer period is required for ongoing dispute resolution.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of compliance.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with swerte77vip2's data disposal procedures.

10 Your Data Subject Rights

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by swerte77vip2:

• Right to be Informed: The right to be informed of how your personal data is collected, used, and processed — which this Privacy Policy fulfills.
• Right of Access: The right to request a copy of the personal data swerte77vip2 holds about you, along with information about how it is processed.
• Right to Rectification: The right to request correction of any inaccurate, incomplete, or outdated personal data we hold about you.
• Right to Erasure / Right to be Forgotten: 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 our legal retention obligations.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller where technically feasible.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interest.
• Right to Withdraw Consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer using the contact details in Section 14 of this Policy. swerte77vip2 will respond to all verified data subject requests within fifteen (15) business days, as required by the Data Privacy Act.

11 Children's Privacy & Age Restriction

The swerte77vip2 platform is strictly intended for users who are 21 years of age or older, in accordance with the minimum legal age for casino-style gambling in the Philippines. swerte77vip2 does not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will immediately close the associated account, delete the personal data, and — where applicable — return any deposits made. If you believe a minor has registered on the swerte77vip2 platform, please contact our support team immediately.

12 International Data Transfers

swerte77vip2 primarily stores and processes personal data within the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or KYC verification platforms operating in other jurisdictions.

Where such international transfers occur, swerte77vip2 ensures that appropriate safeguards are in place to protect your personal data, including:

• Contractual clauses requiring the recipient to apply data protection standards equivalent to those required under the Data Privacy Act of 2012.
• Transfers only to countries or organizations that provide an adequate level of data protection as recognized by the National Privacy Commission.
• Implementation of additional technical security measures where required.

13 Changes to This Privacy Policy

swerte77vip2 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. When material changes are made, we will notify registered players via email or prominent in-platform notice at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Privacy Policy indicates when the most recent revision was made. The current version of this Privacy Policy will always be available at swerte77vip2.club/privacy-policy. We encourage you to review this Policy periodically to stay informed about how swerte77vip2 protects your personal data.

Your continued use of the swerte77vip2 platform following the effective date of any amendment constitutes your acknowledgment of the updated Privacy Policy. If you do not agree with the revised Policy, you must discontinue use of the platform and may request account closure.

14 Contact & Data Protection Officer

swerte77vip2 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 regarding your personal data or this Privacy Policy, please contact us:

• Data Protection Officer: swerte77vip2 Privacy Team
• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 via the in-platform chat widget
• Response Time: Within 15 business days for data subject requests; within 48 hours for general privacy inquiries

If you are not satisfied with our response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.