swinph Privacy Policy

1Overview & Scope

This Policy applies to all personal information collected by swinph through the swinph.app website, any associated mobile applications, customer support channels, and any other touchpoints through which swinph interacts with players and prospective players.

swinph acts as the Personal Information Controller (PIC) in respect of all personal data collected through the platform. Where swinph engages third-party service providers to process data on its behalf, those providers act as Personal Information Processors (PIPs) and are bound by data processing agreements that require them to handle your data in accordance with this Policy and applicable Philippine law.

This Policy does not apply to third-party websites or services that may be linked from the swinph platform. swinph is not responsible for the privacy practices of any third-party site, and we encourage you to review the privacy policies of any external service you access.

2Personal Data We Collect

swinph collects the following categories of personal data from players and platform users:

3How We Collect Your Data

swinph collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in a promotion.
• Automated collection: Technical data collected automatically when you access the swinph platform, including IP address, device identifiers, browser information, and session activity logs.
• Cookies and tracking technologies: Data collected via cookies, web beacons, and similar technologies as described in Section 9 of this Policy.
• Third-party sources: Identity and fraud-screening data received from licensed KYC verification providers, payment processors, and anti-money laundering screening services, where permitted by applicable law.
• Inferred data: Behavioural and preference data derived from your gaming activity and platform interactions, used to personalise your swinph experience and support responsible gaming monitoring.

4Purpose of Processing

swinph processes your personal data for the following purposes:

• Account management: To create, maintain, and administer your swinph player account, including authentication and security.
• Identity and age verification: To verify that you are at least 21 years of age and to confirm your identity in compliance with Philippine regulatory requirements.
• Payment processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment channels.
• Regulatory compliance: To comply with anti-money laundering (AML), counter-terrorism financing (CTF), and other obligations under Philippine law, including reporting obligations to relevant authorities.
• Customer support: To respond to your queries, complaints, and support requests in a timely and effective manner.
• Responsible gaming: To monitor gaming behaviour, identify potential problem gambling indicators, and administer responsible gaming tools such as deposit limits and self-exclusion.
• Platform improvement: To analyse usage patterns, troubleshoot technical issues, and improve the features and performance of the swinph platform.
• Marketing and promotions: To send you relevant promotional offers, bonus notifications, and platform updates, subject to your communication preferences and applicable consent requirements.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, cheating, collusion, and other prohibited conduct on the swinph platform.

5Legal Basis for Processing

Under the Data Privacy Act of 2012, swinph processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our obligations under the swinph Terms & Conditions, including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including AML/CTF obligations, age verification requirements, and regulatory reporting.
• Legitimate interests: Processing carried out for swinph's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, particularly in relation to marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6Sharing Your Personal Data

swinph does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other licensed payment service providers, for the purpose of processing your deposits and withdrawals.
• KYC and identity verification providers: Licensed third-party providers engaged to verify your identity and age in compliance with Philippine regulatory requirements.
• Game content providers: Software providers whose games are available on the swinph platform, to the extent necessary for game delivery and technical support.
• Regulatory and law enforcement authorities: Philippine government agencies, including the National Privacy Commission, relevant financial intelligence units, and law enforcement bodies, where disclosure is required by law or court order.
• Professional advisers: Legal counsel, auditors, and other professional advisers engaged by swinph, subject to professional confidentiality obligations.
• Business successors: In the event of a merger, acquisition, or sale of all or part of swinph's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

Where swinph transfers personal data to recipients outside the Philippines, we ensure that appropriate safeguards are in place, including contractual data protection clauses consistent with the requirements of the Data Privacy Act of 2012 and NPC issuances.

7Data Retention

swinph retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account data: Retained for the duration of your active account and for a period of five (5) years following account closure, in accordance with AML record-keeping requirements.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• KYC and identity verification documents: Retained for the duration of your account and for five (5) years after account closure.
• Customer support records: Retained for three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Marketing data: Retained until you withdraw consent or opt out of marketing communications, after which it will be deleted or anonymised within a reasonable timeframe.
• Technical and log data: Retained for up to twelve (12) months for security monitoring and platform improvement purposes.

Upon expiry of the applicable retention period, swinph will securely delete or anonymise your personal data in accordance with its data disposal procedures.

8Data Security

swinph implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data transmitted between your device and the swinph platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data at rest, including financial information and identity documents, is encrypted using AES-256 encryption.
• Access controls: Access to personal data is restricted to authorised swinph personnel and service providers on a strict need-to-know basis. All access is logged and subject to regular review.
• Password security: Player passwords are stored using one-way cryptographic hashing. swinph staff cannot view your password in plain text.
• Two-factor authentication: swinph offers two-factor authentication (2FA) for player accounts as an additional layer of security. Players are strongly encouraged to enable 2FA.
• Security monitoring: The swinph platform is subject to continuous security monitoring, regular vulnerability assessments, and periodic penetration testing.
• Incident response: In the event of a personal data breach that poses a risk to your rights and freedoms, swinph will notify the National Privacy Commission and affected players in accordance with the timelines prescribed by the Data Privacy Act of 2012.

9Cookies & Tracking Technologies

swinph uses cookies and similar tracking technologies to enhance your experience on the platform, maintain session security, and gather analytics data. The following types of cookies are used:

• Strictly necessary cookies: Essential for the operation of the swinph platform, including session management, authentication, and security features. These cookies cannot be disabled without affecting platform functionality.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalised experience.
• Analytics cookies: Used to collect aggregated, anonymised data about how players use the swinph platform, helping us identify areas for improvement. No personally identifiable information is shared with analytics providers.
• Marketing cookies: Used to deliver relevant promotional content and measure the effectiveness of swinph marketing campaigns. These cookies are only placed with your consent.

You may manage your cookie preferences through your browser settings or through the cookie consent tool available on the swinph platform. Please note that disabling certain cookies may affect the functionality of the platform.

10Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by swinph. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 13.

11Minors & Age Policy

The swinph platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gambling regulations. swinph does not knowingly collect personal data from individuals under the age of 21.

All players are required to complete age verification as part of the swinph registration process. If swinph discovers that personal data has been collected from a player who is under 21 years of age, we will immediately suspend the relevant account, void any associated transactions, and delete the personal data of the underage individual from our systems as promptly as practicable.

12Changes to This Policy

swinph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or NPC guidance. The effective date of the current version is displayed at the top of this page.

When material changes are made to this Policy, swinph will notify registered players by posting a prominent notice on the platform and, where practicable, by sending a notification to the email address or mobile number registered on your account. We encourage you to review this Policy periodically to stay informed about how swinph protects your personal data.

Your continued use of the swinph platform following the effective date of any amendment constitutes your acknowledgment of the updated Policy. If you do not agree with any changes, you may close your account in accordance with the swinph Terms & Conditions.

13Contact & Data Protection Officer

swinph 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 Policy, please contact our DPO using the details below.

Data Protection Officer — swinph
Email: [email protected]
Platform: swinph.app

You may also submit a data privacy rights request or complaint directly through the swinph customer support channel, available 24 hours a day, 7 days a week, in both English and Filipino.