SWC3 Privacy Policy – How We Protect
Your Personal Data in the Philippines

This Privacy Policy applies to all personal information collected by SWC3 ("the Platform," "we," "us," "our") through the website swc3.app and all related services, games, and features offered to players in the Philippines. It explains how we handle your data from the moment you visit the site through the full lifecycle of your SWC3 account.

1About This Privacy Policy

SWC3 is the data controller responsible for your personal information. This Policy has been drafted to comply with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its implementing rules and regulations, and the relevant circulars and advisories issued by the National Privacy Commission (NPC).

We have appointed a Data Protection Officer (DPO) who oversees our compliance with RA 10173 and serves as the first point of contact for all privacy-related concerns. Contact details for the DPO are provided in Section 14.

This Policy covers all personal data processing activities carried out by SWC3 in connection with the platform. It does not apply to third-party websites or services that may be linked from the SWC3 platform — those parties operate under their own privacy practices.

2Personal Data We Collect

The categories of personal data that SWC3 may collect from you include the following:

SWC3 does not intentionally collect sensitive personal information (as defined under RA 10173) beyond what is strictly necessary for identity verification and legal compliance purposes. We do not collect religious, political, or health data as part of the standard account process.

3How We Collect Your Personal Data

SWC3 collects personal data through the following means:

• Direct collection: Information you voluntarily provide during account registration, identity verification (KYC), deposit and withdrawal requests, and communications with customer support.
• Automated collection: Technical data gathered automatically when you access the SWC3 platform, including IP address, device identifiers, and session behaviour, through server logs and cookies (see Section 7).
• Third-party verification: Identity and age verification data received from licensed third-party KYC providers engaged by SWC3 to validate documents you submit.
• Payment processors: Transaction confirmation data and payment status updates received from e-wallet providers (GCash, Maya, GrabPay) and banking partners used to process your deposits and withdrawals.
• Regulatory sources: Information received from PAGCOR or other Philippine gaming regulatory bodies in connection with licensing and compliance requirements.

4Why We Use Your Personal Data

SWC3 processes your personal data for specific, legitimate purposes. We do not use your data for purposes beyond those listed below without obtaining your additional consent or unless required by law:

• Account Management: Creating, maintaining, and administering your SWC3 account, including authentication and security.
• Identity Verification: Verifying your age, identity, and eligibility to use the platform in compliance with Philippine gaming licensing requirements.
• Transaction Processing: Processing deposits, withdrawals, bonus credits, and wagering transactions accurately and securely.
• Legal and Regulatory Compliance: Meeting our obligations under Philippine gaming law, anti-money laundering regulations, and data privacy law — including reporting obligations to PAGCOR, AMLC, and the NPC as required.
• Responsible Gaming: Monitoring account activity to identify patterns that may indicate problem gambling and enforcing self-exclusion and limit settings requested by players.
• Customer Support: Responding to and resolving queries, complaints, and disputes submitted through SWC3's support channels.
• Platform Improvement: Analysing aggregate, anonymised usage data to improve the performance, security, and features of the SWC3 platform.
• Marketing Communications: Sending promotional offers and platform updates by email or SMS — but only to players who have opted in to receive marketing communications. You can opt out at any time.
• Fraud Prevention and Security: Detecting and preventing fraudulent transactions, account takeovers, bonus abuse, and other security threats to the platform and its players.

5Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, SWC3's processing of your personal data is based on one or more of the following legal bases:

• Consent: You have given clear, specific, and informed consent to the processing of your personal data for one or more specific purposes — most notably marketing communications and optional features.
• Contractual Necessity: Processing is necessary to fulfil our contractual obligations to you as a registered SWC3 player, including account management and payment processing.
• Legal Obligation: Processing is required to comply with applicable Philippine law, including gaming licensing conditions, anti-money laundering requirements, and tax reporting obligations.
• Legitimate Interests: Processing is necessary for SWC3's legitimate business interests — such as fraud prevention, platform security, and service improvement — provided those interests are not overridden by your rights and freedoms under RA 10173.

6How We Share Your Data

SWC3 does not sell or rent your personal data to any third party. We share your information only in the following specific and controlled circumstances:

• Payment Service Providers: Your financial data is shared with the e-wallet and banking partners (GCash, Maya, GrabPay, InstaPay/PESONet, BDO, BPI, UnionBank, Visa/Mastercard) strictly to process your deposits and withdrawals. These providers are bound by their own data protection obligations and are not permitted to use your data for any other purpose.
• Identity Verification Partners: KYC documents you submit may be shared with our licensed identity verification service providers. These providers act under strict data processing agreements that limit their use of your data to verification purposes only.
• Game Technology Providers: Some gaming products on SWC3 are supplied by third-party software providers. Minimal technical data (such as session tokens) may be shared with these providers to enable gameplay — no more than what is operationally necessary.
• Regulatory Authorities: SWC3 is required by Philippine law to share certain data with PAGCOR, the Anti-Money Laundering Council (AMLC), and other government agencies when requested pursuant to valid legal process or our licensing obligations.
• Professional Advisers: Legal counsel, auditors, and compliance consultants engaged by SWC3 may have access to your data to the extent necessary for their professional advisory role. All such parties are bound by confidentiality obligations.
• Corporate Transactions: In the event of a merger, acquisition, or restructuring involving SWC3, your personal data may be disclosed to prospective or actual successors in business, subject to the privacy protections in this Policy.

7Cookies and Tracking Technologies

SWC3 uses cookies and similar tracking technologies to operate the platform effectively, ensure security, and improve your experience. Here is a plain-language explanation of what we use and why:

• Essential Cookies: These are required for the platform to function. They manage your login session, maintain your account security, and enable core gameplay features. You cannot opt out of essential cookies while using SWC3.
• Performance Cookies: These collect anonymised data about how players use the platform — which pages load slowly, where errors occur, and how navigation flows work — to help us improve performance.
• Functionality Cookies: These remember your preferences, such as your preferred language and display settings, so you don't have to re-enter them every session.
• Analytics Cookies: We use anonymised web analytics to understand aggregate traffic patterns. This data is never linked to individual player accounts.

SWC3 does not use third-party advertising cookies or cross-site tracking cookies. You can manage cookie preferences through your browser settings. Note that disabling essential cookies will prevent you from logging into or using the SWC3 platform.

8Data Retention

SWC3 retains your personal data only for as long as necessary to fulfil the purposes described in this Policy and to comply with our legal obligations under Philippine law. The following retention periods apply as a general guide:

• Account and Identity Data: Retained for the duration of your active account plus a minimum of 5 years after account closure, in accordance with Philippine anti-money laundering record-keeping requirements.
• Financial and Transaction Records: Retained for a minimum of 5 years from the date of each transaction as required by AMLC regulations and gaming licensing conditions.
• Gaming Activity Logs: Retained for 3 years after the relevant activity, or longer if required by a regulatory investigation or legal proceeding.
• Customer Support Records: Retained for 2 years after the closure of the relevant support ticket or interaction.
• Marketing Consent Records: Retained for the duration of your consent plus 2 years after you opt out, as evidence of your consent history.
• Technical Logs (Server, Security): Retained for 12 months under standard operating conditions, or longer if a security incident investigation is ongoing.

At the end of the applicable retention period, your personal data is either securely deleted or anonymised so that it can no longer be associated with you as an individual.

9How We Protect Your Data

SWC3 takes data security seriously and has implemented technical and organisational measures appropriate to the sensitivity of the personal data we hold. Key security measures include:

• Encryption: All data transmitted between your device and SWC3 servers is protected by TLS 1.3 encryption. Personal data stored in our systems is encrypted at rest using AES-256.
• Access Controls: Personal data is accessible only to SWC3 staff and contractors who need it to perform their specific role. Access is governed by role-based permissions, and all access is logged and audited.
• Two-Factor Authentication: SWC3 supports and encourages two-factor authentication (2FA) for all player accounts as an additional layer of identity protection.
• Security Monitoring: Our systems are monitored continuously for suspicious activity, unusual access patterns, and potential security threats. Automated alerts trigger investigation protocols when anomalies are detected.
• Penetration Testing: SWC3 engages independent security professionals to conduct regular penetration tests of the platform to identify and remediate vulnerabilities before they can be exploited.
• Staff Training: All SWC3 personnel who handle personal data receive regular training on data privacy obligations and security best practices.

While SWC3 applies industry-standard security measures, no digital platform can guarantee absolute security. You play an important role in your own data security by keeping your SWC3 credentials confidential and enabling 2FA on your account.

10Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights regarding your personal data held by SWC3:

To exercise any of these rights, contact SWC3's Data Protection Officer using the details in Section 14. Please include your full name, registered email address, and a clear description of your request. We may need to verify your identity before processing your request.

11Children's Privacy

SWC3 is strictly for players aged 18 and above. We do not knowingly collect personal data from anyone under the age of 18. The SWC3 registration process includes a mandatory age declaration, and we conduct age verification as part of the KYC process.

If SWC3 becomes aware that personal data has been collected from a minor — whether through a false declaration or any other means — we will immediately suspend the account, delete the data in question, and refund any real-money deposits to the originating payment method.

12Cross-Border Data Transfers

SWC3's primary data storage and processing infrastructure is located within the Philippines or in data centres that meet equivalent data protection standards. Some of our third-party service providers — including certain game software suppliers and technical infrastructure providers — may process data outside the Philippines.

Where personal data is transferred outside the Philippines, SWC3 ensures that adequate safeguards are in place in accordance with NPC guidelines, including:

• Requiring that the recipient country's data protection laws offer a comparable level of protection to Philippine law.
• Entering into data processing agreements that contractually obligate recipients to maintain appropriate data protection standards.
• Conducting due diligence on the data protection practices of all third-party providers who may receive Filipino player data.

You may request information about the specific countries to which your data may be transferred by contacting the SWC3 Data Protection Officer.

13Updates to This Privacy Policy

SWC3 reviews this Privacy Policy regularly to ensure it remains accurate and compliant with Philippine law. We may update this Policy when there are changes to our data practices, when new legal obligations apply, or when we introduce new platform features that involve personal data processing.

When we make material changes — those that significantly affect how we use your data or your rights as a data subject — we will notify you by email to your registered address and post a prominent notice on the SWC3 platform at least 7 days before the changes take effect.

The "Last Updated" date at the top of this page reflects the most recent revision. We encourage you to review this Policy periodically. Your continued use of SWC3 after a Policy update constitutes acceptance of the revised terms.

14Contact Us and Data Protection Officer

SWC3 has appointed a Data Protection Officer responsible for overseeing compliance with the Philippine Data Privacy Act and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data, please contact:

All privacy-related requests and complaints are acknowledged within 3 business days and receive a substantive response within 15 business days. For complaints that cannot be resolved directly with SWC3, you have the right to escalate to the National Privacy Commission of the Philippines.

This Privacy Policy was last reviewed in January 2025 and is effective from that date for all SWC3 accounts — both those registered before and after the revision date.