Contents
- 01Introduction & Scope
- 02Data Controller
- 03Data We Collect
- 04How We Collect Data
- 05Purposes & Legal Basis
- 06Data Sharing & Disclosure
- 07Cookies & Tracking
- 08Data Retention
- 09Data Security
- 10Your Rights as a Data Subject
- 11Children & Minors
- 12Cross-Border Transfers
- 13Changes to This Policy
- 14Contact & Complaints
Your Privacy Matters: This Privacy Policy is issued by swere99 and applies to all personal data processed in connection with the swere99 online casino and sports betting platform at swere99.net. By registering an account or using any swere99 service, you acknowledge that you have read and understood this Privacy Policy. If you do not agree to its terms, you must not use the swere99 platform.
Introduction & Scope
swere99 ("swere99," "we," "us," or "our") is committed to safeguarding the privacy and personal data of all individuals who interact with our platform, including registered players, visitors who browse the swere99 website without registering, and individuals who contact our customer support team.
This Privacy Policy applies to all personal data collected, stored, used, or otherwise processed by swere99 in connection with:
- The swere99 website accessible at swere99.net and any related sub-domains or mobile-optimized interfaces.
- The registration and maintenance of a swere99 player account.
- The use of any swere99 services, including the sportsbook, live casino, JILI slots, bingo, virtual casino, and sabong.
- Deposits and withdrawals processed via GCash, PayMaya, BPI, BDO, Metrobank, or Visa/Mastercard.
- Communications between you and swere99, including live chat, email support, and promotional communications.
This Policy is to be read together with the swere99 Terms and Conditions. In the event of any conflict between this Privacy Policy and the Terms and Conditions on a privacy-related matter, this Privacy Policy shall prevail.
Data Controller
2.1 Identity of the Data Controller. For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, swere99 acts as the Data Controller with respect to the personal data of its Players and website visitors. As Data Controller, swere99 determines the purposes for which and the means by which your personal data is processed.
2.2 Data Protection Officer. swere99 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. You may contact the swere99 DPO at any time by emailing [email protected] with the subject line "Data Protection Officer — Privacy Enquiry." All privacy-related correspondence will be handled by the DPO or their designated team within the response timeframes set out in Section 14.
2.3 Registration with the NPC. swere99 complies with applicable registration and notification obligations under the National Privacy Commission (NPC) of the Philippines, as required by the Data Privacy Act and NPC Circular No. 16-01.
Data We Collect
3.1 Registration Data. When you create a swere99 account, we collect the following personal data that you provide directly:
- Full legal name (first name, middle name, last name)
- Date of birth (used to verify the 21+ age requirement)
- Gender
- Residential address (street, city/municipality, province, ZIP code)
- Email address
- Mobile phone number
- Username and password (password is stored in hashed form only — never in plain text)
- Referral source (how you heard about swere99), if voluntarily provided
3.2 Identity Verification (KYC) Data. To comply with PAGCOR regulations and Philippine anti-money laundering requirements, swere99 requires all Players to complete Know Your Customer (KYC) verification. KYC data collected includes:
- Government-issued photo identification (e.g., Philippine National ID, passport, driver's license, SSS/GSIS/PhilHealth ID, or PRC ID)
- Proof of address documentation (e.g., utility bill, bank statement, or barangay certificate issued within the last three months)
- Selfie photograph taken at the time of KYC submission for liveness verification
- Documentary evidence of the source of funds, where required for enhanced due diligence
3.3 Financial Transaction Data. We collect records of all financial transactions conducted through your swere99 Wallet, including deposit amounts, withdrawal amounts, payment method identifiers (e.g., GCash mobile number, last four digits of a linked card), transaction dates and times, and transaction reference numbers. We do not store full card numbers or complete bank account credentials on our servers.
3.4 Gaming Activity Data. swere99 maintains records of all gaming activity conducted through your account, including bets placed, games played, outcomes, win/loss history, session durations, and responsible gaming tool usage (e.g., deposit limit settings, self-exclusion requests).
3.5 Technical and Device Data. When you access the swere99 platform, we automatically collect certain technical information about your device and connection, including IP address, device type and model, operating system and version, browser type and version, unique device identifiers, and approximate geographic location derived from IP address.
3.6 Communications Data. We retain records of communications between you and swere99, including live chat transcripts, email correspondence, support ticket history, and any feedback or survey responses you submit.
3.7 Marketing Preference Data. Where you have consented to receive marketing communications, we record your consent, the date and method of consent, and your marketing channel preferences (SMS, email).
How We Collect Data
swere99 collects your personal data through the following means:
4.1 Directly from You. The majority of personal data swere99 holds about you is provided directly by you during the account registration process, KYC submission, deposit and withdrawal transactions, live chat and email support interactions, and when you participate in promotions or surveys.
4.2 Automatically Through Technology. When you visit the swere99 website or use the platform, we automatically collect technical and device data through cookies, web beacons, server logs, and similar tracking technologies. Please refer to Section 7 (Cookies & Tracking) for a full description of the tracking technologies we use.
4.3 From Third-Party Payment Processors. When you make a deposit or request a withdrawal via GCash, PayMaya, BPI, BDO, Metrobank, or Visa/Mastercard, swere99 receives transaction confirmation data from the relevant payment processor, including transaction status, reference numbers, and the payment method identifier you used.
4.4 From Identity Verification Service Providers. swere99 works with third-party KYC and identity verification technology providers to assist with the automated verification of government-issued identification documents. These providers process your KYC documents on swere99's behalf as Data Processors under binding data processing agreements.
4.5 From PAGCOR and Philippine Regulatory Bodies. swere99 may receive information about Players from PAGCOR or other Philippine regulatory or law enforcement bodies where required by law, including information relating to self-exclusion orders, AMLA compliance, or ongoing investigations.
Purposes & Legal Basis
The table below sets out the primary purposes for which swere99 processes your personal data, together with the applicable legal basis under the Data Privacy Act of 2012:
| Purpose of Processing | Categories of Data Used | Legal Basis |
|---|---|---|
| Account registration and management | Registration data, KYC data | Contractual necessity |
| Age verification (21+ compliance) | Date of birth, KYC documents | Legal obligation (PAGCOR regulations) |
| Processing deposits and withdrawals | Financial transaction data, KYC data | Contractual necessity |
| Anti-money laundering (AMLA) compliance | KYC data, financial transaction data, source of funds documentation | Legal obligation (RA No. 9160) |
| Providing gaming services and sportsbook | Gaming activity data, account data | Contractual necessity |
| Customer support and dispute resolution | Communications data, gaming activity data, transaction data | Contractual necessity / Legitimate interest |
| Responsible gaming monitoring | Gaming activity data, responsible gaming tool usage | Legal obligation / Legitimate interest |
| Fraud detection and platform security | Technical data, gaming activity data, transaction data | Legitimate interest |
| Marketing communications | Contact details, marketing preference data | Consent |
| Platform analytics and improvement | Technical and device data, gaming activity data (aggregated/anonymized) | Legitimate interest |
| Compliance with court orders and regulatory requests | Any relevant personal data | Legal obligation |
swere99 will not process your personal data for any purpose that is incompatible with the purposes listed above without first notifying you and, where required, obtaining your consent.
Data Sharing & Disclosure
6.1 General Principle. swere99 does not sell, rent, or trade your personal data to any third party for their own marketing or commercial purposes. We share your personal data only in the circumstances described in this Section, and only to the extent necessary for the stated purpose.
6.2 Payment Processors. swere99 shares transaction-relevant personal data with GCash (Mynt — Globe Fintech Innovations, Inc.), PayMaya (Voyager Innovations, Inc.), BPI, BDO, Metrobank, and Visa/Mastercard payment networks solely for the purpose of processing your deposits and withdrawals. Each payment processor operates under its own privacy policy and is independently responsible for data it holds in its own systems.
6.3 Identity Verification Providers. swere99 shares KYC documentation with third-party identity verification service providers acting as Data Processors on our behalf. These providers are bound by data processing agreements that require them to process your data only on swere99's documented instructions and in compliance with the Data Privacy Act.
6.4 Game Technology Providers. To deliver JILI slots, live casino, and other game content, swere99 shares session and bet data with its licensed game technology providers. These providers receive only the data necessary to deliver the game experience and record outcomes. They do not receive your full identity documents.
6.5 PAGCOR and Philippine Regulatory Authorities. swere99 is required by its operating conditions to report certain data to PAGCOR, including player transaction summaries and responsible gaming events. swere99 will also disclose personal data to the Anti-Money Laundering Council (AMLC), the National Bureau of Investigation (NBI), Philippine National Police (PNP), and other competent authorities where required by Philippine law or a valid court order.
6.6 Professional Advisors. swere99 may share personal data with its lawyers, accountants, auditors, and insurers where strictly necessary for the purpose of obtaining professional advice or managing legal claims.
6.7 Business Transfers. In the event of a merger, acquisition, restructuring, or sale of all or substantially all of swere99's business assets, your personal data may be transferred to the acquiring entity as part of that transaction. swere99 will notify registered Players via email in advance of any such transfer and will ensure that the acquiring entity is bound by terms no less protective than this Privacy Policy.
No Data Selling: swere99 does not and will never sell personal data to data brokers, advertising networks, or any third party for commercial profiling purposes. Your gaming data is yours.
Cookies & Tracking Technologies
7.1 What Are Cookies. Cookies are small text files placed on your device by the swere99 website. They allow our platform to recognize your device across pages and sessions, maintain your login state, remember your preferences, and analyze how the platform is used.
7.2 Types of Cookies Used by swere99. swere99 uses the following categories of cookies on its platform:
- Strictly Necessary Cookies: These cookies are essential for the swere99 platform to function. They maintain your login session, manage your account security, and ensure that transactions are processed correctly. You cannot opt out of strictly necessary cookies while using the platform.
- Functional Cookies: These cookies remember your preferences, such as your preferred language, display settings, and responsible gaming limit configurations, to provide a more personalized experience on return visits.
- Analytics Cookies: swere99 uses first-party analytics cookies to understand how Players navigate the platform — for example, which game categories are most visited and where players drop off during registration. This data is used in aggregated, anonymized form to improve the platform.
- Security Cookies: These cookies assist in fraud detection and account security, including identifying suspicious login patterns and detecting the use of VPNs or proxies to access the platform from Prohibited Jurisdictions.
7.3 Managing Cookies. You may control non-essential cookies through your browser settings. Most browsers allow you to block or delete cookies via their settings menu. Note that blocking strictly necessary cookies will prevent you from logging in to your swere99 account. Blocking analytics or functional cookies will not affect your ability to play, but may reduce the personalization of your experience.
7.4 No Third-Party Advertising Cookies. swere99 does not permit third-party advertising networks to place cookies or tracking pixels on the swere99 platform for the purpose of serving targeted advertising to our Players on other websites.
Data Retention
8.1 Retention Periods. swere99 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following minimum retention periods apply:
- Account and KYC Records: Retained for a minimum of five (5) years from the date of account closure, as required under applicable Philippine financial regulations and PAGCOR operating conditions.
- Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with the Anti-Money Laundering Act of 2001 (RA No. 9160) and its amendments.
- Gaming Activity Records: Retained for a minimum of three (3) years from the date of the relevant gaming session or bet.
- Communications Records: Live chat transcripts and email correspondence are retained for two (2) years from the date of the interaction, unless related to an unresolved dispute, in which case they are retained until the dispute is fully resolved.
- Marketing Consent Records: Retained for the duration of your account and for two (2) years following account closure or consent withdrawal, whichever is later, for audit purposes.
8.2 Secure Deletion. Upon expiry of the applicable retention period, swere99 will securely delete or anonymize your personal data so that it can no longer be associated with your identity. Anonymized and aggregated data may be retained indefinitely for statistical and analytical purposes.
8.3 Legal Hold. Where swere99 is subject to a legal hold, regulatory investigation, court order, or unresolved dispute requiring the preservation of particular records, the relevant data will be retained beyond its standard retention period until the hold is lifted.
Data Security
9.1 Security Measures. swere99 implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:
- Encryption in Transit: All data transmitted between your device and the swere99 platform is encrypted using industry-standard TLS (Transport Layer Security) protocols.
- Encryption at Rest: Sensitive personal data, including KYC documents and financial records, are encrypted at rest using AES-256 encryption or equivalent.
- Password Security: Player passwords are stored as salted cryptographic hashes. swere99 staff cannot view your password in plain text.
- Access Controls: Access to personal data within swere99's systems is restricted to authorized personnel on a strict need-to-know basis, enforced through role-based access controls and multi-factor authentication.
- Vulnerability Management: swere99 conducts regular security assessments and penetration testing of its platform. Critical vulnerabilities are remediated within defined SLA timeframes.
- Incident Response: swere99 maintains a documented data breach incident response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, swere99 will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected Players without undue delay.
9.2 Player Responsibilities. While swere99 takes all reasonable steps to protect your personal data, the security of your account also depends on you maintaining the confidentiality of your login credentials. You must not share your swere99 username, password, or one-time verification codes with any third party. If you suspect unauthorized access to your account, contact swere99 customer support immediately via live chat.
Your Rights as a Data Subject
Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights as a data subject with respect to personal data held by swere99. These rights may be exercised by contacting swere99's Data Protection Officer as described in Section 14.
Your Data Rights at swere99
10.1 Right to Be Informed. You have the right to be informed of the manner by which your personal data is collected, used, stored, and disposed of. This Privacy Policy is the primary means by which swere99 fulfils this obligation.
10.2 Right to Access. You have the right to request a copy of the personal data swere99 holds about you, including information about the purposes for which it is processed and the categories of third parties with whom it has been shared. swere99 will respond to a verified access request within thirty (30) calendar days.
10.3 Right to Rectification. If any personal data swere99 holds about you is inaccurate or incomplete, you have the right to request its correction. You may update certain personal data directly through your Account Settings; for other corrections, please contact the DPO.
10.4 Right to Erasure. Subject to applicable legal retention obligations (see Section 8), you may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent and no other legal basis applies. Note that swere99 cannot delete data it is legally required to retain under Philippine financial and anti-money laundering regulations.
10.5 Right to Object. You have the right to object to the processing of your personal data where swere99 relies on legitimate interest as its legal basis. You also have an absolute right to object to the processing of your personal data for direct marketing purposes at any time, without needing to provide a reason.
10.6 Right to Data Portability. Where processing is based on your consent or on contractual necessity, and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another data controller where technically feasible.
10.7 Right to Lodge a Complaint with the NPC. If you believe swere99 has violated your rights under the Data Privacy Act of 2012, you have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines through the NPC's official channels.
Children & Minors
11.1 Minimum Age Requirement. swere99 strictly prohibits the use of its platform by any person under twenty-one (21) years of age, in compliance with applicable PAGCOR regulations governing online gambling in the Philippines. swere99 does not knowingly collect personal data from individuals under the age of 21.
11.2 Age Verification. All persons who register a swere99 account are required to complete KYC age verification using a government-issued Philippine identification document. Registration attempts by persons who cannot demonstrate that they are 21 years of age or older will be rejected and any associated account will be immediately closed.
11.3 Discovery of Minor's Data. If swere99 discovers or is notified that personal data belonging to a person under the age of 21 has been collected — for example, as a result of a false declaration of age during registration — swere99 will immediately close the associated account, forfeit any remaining balance in accordance with the Terms and Conditions, and permanently delete the minor's personal data from its systems, subject only to any retention obligations required by applicable law.
11.4 Parental Responsibility. Parents and guardians of persons under 21 are encouraged to use device-level parental controls and to ensure that minors in their household do not have access to any device on which a swere99 account is accessible or on which swere99 login credentials are stored.
Cross-Border Data Transfers
12.1 Primary Data Location. swere99 stores the majority of its Player data on servers located within or in compliance with standards applicable to the Republic of the Philippines.
12.2 Transfers to Third-Party Service Providers. Certain swere99 service providers — including game technology providers and KYC verification partners — may be located outside of the Philippines. Where personal data is transferred to a Data Processor located in a foreign jurisdiction, swere99 takes the following safeguards:
- swere99 executes binding Data Processing Agreements with all foreign Data Processors, contractually requiring them to implement data protection standards no less protective than those required under the Philippine Data Privacy Act.
- swere99 conducts due diligence on the data protection practices of foreign Data Processors prior to engagement and on a periodic basis thereafter.
- Where a foreign jurisdiction is not recognized as providing an adequate level of data protection, swere99 implements additional contractual safeguards, including standard contractual clauses or equivalent measures, as applicable.
12.3 No Unauthorized International Transfers. swere99 does not transfer your personal data to any foreign jurisdiction except where necessary to deliver the swere99 platform services to you, and in all cases only under the safeguards described above.
Changes to This Policy
13.1 Right to Update. swere99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable Philippine law, NPC guidance, PAGCOR requirements, or swere99's data processing practices. All changes will be published on this page with a revised effective date at the top of the document.
13.2 Notification of Material Changes. Where a proposed change to this Privacy Policy is material — meaning it significantly affects how swere99 processes your personal data or your rights as a data subject — swere99 will notify registered Players via their registered email address at least fourteen (14) days before the change takes effect.
13.3 Continued Use as Acceptance. Your continued use of the swere99 platform after the effective date of any updated Privacy Policy constitutes your acceptance of the changes. If you do not agree to the updated Privacy Policy, you must cease using the platform and may request account closure in accordance with the Terms and Conditions.
13.4 Version Archive. Prior versions of the swere99 Privacy Policy are archived and can be made available upon written request to the swere99 Data Protection Officer.
Contact & Complaints
If you have any questions about this Privacy Policy, wish to exercise any of your data subject rights set out in Section 10, or wish to raise a complaint about swere99's data processing practices, please contact the swere99 Data Protection Officer through the following channels. Note that all contact details are displayed as plain text — swere99 does not accept liability for communications sent to any address other than those listed below.
- Data Protection Officer (Email): [email protected] — please use the subject line "Data Protection Officer — [Nature of Enquiry]" to ensure your message is directed to the DPO team.
- Customer Support (Live Chat): Available 24 hours a day, 7 days a week, via the live chat widget on the swere99 platform. Filipino-speaking agents are available on all shifts.
- Response Timeframe: swere99 aims to acknowledge all privacy-related enquiries within two (2) Philippine business days and to provide a substantive response within thirty (30) calendar days of receiving a verified request.
- NPC Complaints: If you are not satisfied with swere99's response to your privacy complaint, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines through the NPC's official complaint channels.
swere99 is committed to resolving all privacy-related concerns promptly and transparently, in a manner consistent with the Data Privacy Act of 2012 and the values of respect and fairness that underpin the swere99 platform.
Your Data. Your Rights.
How swere99 Protects Filipino Players
256-Bit Encryption
All data sent between your device and the swere99 platform is protected by TLS encryption. KYC documents and financial records are encrypted at rest using AES-256, keeping your sensitive Filipino personal data secure at every step.
Full DPA 2012 Compliance
swere99 operates in full compliance with Republic Act No. 10173 — the Philippine Data Privacy Act of 2012 — and is subject to the oversight of the National Privacy Commission (NPC). Your rights as a Filipino data subject are fully respected.
No Data Selling — Ever
swere99 will never sell, rent, or trade your personal data to third-party advertisers or data brokers. Your gaming history, contact details, and financial records exist solely to power your swere99 experience — full stop.
Secure GCash & PayMaya Payments
Deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank are processed through encrypted, tokenized payment channels. swere99 never stores your full GCash PIN, card number, or online banking credentials on our servers.
You Control Your Data
Filipino players have the right to access, correct, and request deletion of their personal data. Submit a request anytime by emailing [email protected] — our dedicated Data Protection Officer will respond within 30 calendar days.
No Third-Party Ad Tracking
swere99 does not allow external advertising networks to place tracking cookies on our platform. The only analytics we run are our own first-party tools, used exclusively to improve the swere99 experience for players across Manila, Cebu, Davao, and beyond.
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