swcv1 Privacy Policy

1 Introduction

swcv1 is an online gaming platform serving Filipino players across the Philippines, from Metro Manila and Makati to Cebu, Davao, and Quezon City. We take the privacy of our players seriously and are committed to handling your personal information with transparency, care, and full respect for your rights under Philippine law.

This Privacy Policy ("Policy") describes how swcv1 ("we", "us", "our", "the Platform") collects, uses, stores, shares, and protects the personal data of individuals ("you", "Player", "User") who access or use the swcv1 platform. It also explains the rights you hold over your personal data and how to exercise them.

This Policy should be read alongside the swcv1 Terms & Conditions and Responsible Gaming Policy, both of which form part of your overall agreement with swcv1.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, swcv1 is the Personal Information Controller responsible for the personal data collected through the swcv1 platform.

As Personal Information Controller, swcv1 determines the purposes and means by which your personal data is processed. Where swcv1 engages third-party service providers to process data on its behalf — such as payment processors, game content providers, and KYC verification services — those parties act as Personal Information Processors and are bound by data processing agreements that restrict their use of your data to the purposes specified by swcv1.

You may contact our Data Protection Officer at any time using the details provided in Section 14 of this Policy.

3 Data We Collect

swcv1 collects personal data across several categories, depending on how you interact with the platform. The table below summarises the main categories and examples:

swcv1 does not intentionally collect sensitive personal information (as defined under R.A. 10173) beyond what is strictly required for identity verification and regulatory compliance purposes. Where sensitive personal information is collected — for example, a government-issued ID bearing your photograph — it is handled with the heightened protections required by Philippine law.

4 How We Use Your Data

swcv1 uses the personal data it collects for the following purposes:

• Account management: Creating and maintaining your swcv1 player account, verifying your identity, and managing your login credentials;
• KYC and regulatory compliance: Meeting our Know Your Customer obligations, verifying your age (21+), and complying with Philippine Anti-Money Laundering Act (AMLA) requirements;
• Payment processing: Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and InstaPay, and maintaining accurate financial records;
• Platform operation and improvement: Delivering games and services, diagnosing technical issues, improving platform performance, and developing new features;
• Responsible gaming: Monitoring gameplay patterns to detect signs of problem gambling, enforcing self-exclusion requests, and applying deposit or loss limits;
• Fraud prevention and security: Detecting and preventing fraudulent activity, money laundering, bonus abuse, and unauthorized account access;
• Customer support: Responding to your inquiries, resolving disputes, and maintaining records of communications;
• Marketing and promotions: Sending you information about swcv1 bonuses, new games, and special offers — where you have provided your consent or where we have a legitimate interest to do so;
• Legal compliance: Meeting our obligations under applicable Philippine laws and regulations and responding to lawful requests from regulatory or law enforcement authorities.

5 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012 and its implementing rules, swcv1 processes your personal data on one or more of the following legal bases:

• Contractual necessity: Processing is necessary for the performance of our contract with you — i.e., operating your swcv1 player account, processing payments, and delivering gaming services;
• Legal obligation: Processing is required for compliance with a legal obligation, including KYC verification, AMLA reporting obligations, and PAGCOR regulatory requirements;
• Legitimate interests: Processing is necessary for the legitimate interests of swcv1, including fraud detection, platform security, and improving our services, where those interests are not overridden by your rights and freedoms;
• Consent: For processing activities not covered by the bases above — in particular, direct marketing communications — we rely on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 Data Sharing & Disclosure

swcv1 does not sell, rent, or trade your personal data to any third party. We may share your personal information with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment service providers: GCash, PayMaya, BPI, BDO, Metrobank, and InstaPay — for the purpose of processing deposits and withdrawals;
• KYC and identity verification providers: Third-party services that assist in verifying the identity and age of swcv1 players as required by law;
• Game content providers: Licensed software and live dealer providers whose games are hosted on the swcv1 platform — who may receive technical session data as part of game operation;
• IT infrastructure and security providers: Cloud hosting, cybersecurity, and platform monitoring partners who process data solely on our instructions;
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies where disclosure is required by law, court order, or regulatory directive;
• Professional advisers: Lawyers, accountants, and auditors, where disclosure is necessary and subject to professional confidentiality obligations.

All third-party processors engaged by swcv1 are required to implement appropriate technical and organizational security measures and to process personal data only in accordance with swcv1's documented instructions.

7 Data Retention

swcv1 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, unless a longer retention period is required or permitted by law.

• Active account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in line with AMLA and PAGCOR record-keeping requirements;
• KYC and identity documents: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later;
• Financial transaction records: Retained for a minimum of five (5) years in accordance with Philippine financial regulations;
• Communications and support records: Retained for up to three (3) years following resolution of the relevant matter;
• Marketing preference data: Retained until you withdraw consent or opt out, plus a reasonable period to record the withdrawal;
• Technical and log data: Generally retained for twelve (12) months unless required for ongoing fraud investigation or legal proceedings.

Once the applicable retention period expires, personal data is securely deleted or anonymised in a manner that prevents re-identification.

8 Data Security

swcv1 implements comprehensive 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 transmitted between your device and the swcv1 platform;
• Encryption of sensitive data fields at rest within our databases;
• Role-based access controls that restrict internal access to personal data to authorized personnel on a strictly need-to-know basis;
• Regular penetration testing and security audits of the swcv1 platform infrastructure;
• Multi-factor authentication options for player accounts;
• Real-time fraud detection and anomaly monitoring systems;
• Staff training on data protection obligations and security best practices.

In the event of a personal data breach that poses a risk to your rights and freedoms, swcv1 will notify the National Privacy Commission (NPC) and affected players in accordance with the timelines and procedures prescribed by R.A. 10173 and NPC Circular No. 16-03.

9 Cookies & Tracking Technologies

swcv1 uses cookies and similar tracking technologies to operate the platform effectively, personalize your experience, and analyze how the site is used. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the platform to function. These include session cookies that maintain your login state and security cookies that protect against cross-site request forgery. These cookies cannot be disabled;
• Functional cookies: Remember your preferences, such as language settings and game view options, to personalize your experience across sessions;
• Analytics cookies: Collect anonymized information about how players navigate the swcv1 platform, which pages are visited most, and how long sessions last. This data helps us improve platform performance;
• Marketing cookies: Track whether you have engaged with swcv1 promotional content. Used only with your prior consent.

You can manage your cookie preferences through your swcv1 account settings or through your browser's built-in cookie controls. Note that disabling certain cookies may affect the functionality of the platform. Strictly necessary cookies cannot be disabled as they are required for the platform to operate securely.

10 Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by swcv1:

To exercise any of the above rights, please contact our Data Protection Officer using the details in Section 14. swcv1 will respond to all valid privacy rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further sixty (60) days, in which case we will notify you of the extension and reason for the delay.

swcv1 will not charge a fee for handling privacy rights requests in ordinary circumstances. Where requests are manifestly unfounded, excessive, or repetitive, a reasonable administrative fee may be applied.

11 Children & Minors

Age verification is conducted as part of the swcv1 KYC process for all new accounts. Where swcv1 becomes aware that personal data has been collected from an individual under the age of 21, that account will be immediately suspended, the personal data will be deleted without undue delay, and any deposits made will be refunded to the original payment method where possible.

If you believe that a minor has registered an account on swcv1, please contact us immediately at [email protected] so that we can investigate and take appropriate action.

12 Cross-Border Data Transfers

swcv1 primarily processes personal data within the Philippines. In certain circumstances, your personal data may be transferred to or accessed from locations outside the Philippines — for example, where swcv1 uses cloud hosting infrastructure or game content providers whose servers are located in other countries.

Where personal data is transferred outside the Philippines, swcv1 ensures that appropriate safeguards are in place, consistent with the requirements of the Philippine Data Privacy Act of 2012 and NPC guidelines. These safeguards may include contractual clauses that impose data protection obligations equivalent to those applicable within the Philippines, or transfers to recipients located in countries recognized by the NPC as providing adequate data protection standards.

By using swcv1, you acknowledge and consent to the transfer of your personal data as described in this section, subject always to the protections described in this Policy.

13 Policy Updates

swcv1 reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory guidance. The "Last Updated" date at the top of this page will always reflect the most recent revision.

Where changes to this Policy are material — meaning they significantly affect your rights or how your personal data is used — swcv1 will notify you via a prominent notice on the platform or by email to the address associated with your account at least fourteen (14) days before the changes take effect.

For minor or administrative updates that do not materially affect your rights, changes may take effect immediately upon publication. Your continued use of swcv1 after an updated Policy has been published constitutes your acceptance of the revised terms.

14 Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or how swcv1 handles your personal data, please contact our Data Protection Officer through the following channels:

• Email (plain text — not a clickable link): [email protected]
• Live Chat: Available 24/7 inside your swcv1 account dashboard
• Response Time: We aim to acknowledge all privacy-related inquiries within 24 hours and resolve them within 30 days

If you are not satisfied with swcv1's 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. Information on how to file a complaint with the NPC is available through Philippine government channels.