Privacy Policy

1. Data Controller

swcv3 ("the Platform", "we", "us", "our") is the data controller responsible for the personal data collected through the website swcv3.net and all associated mobile interfaces, support channels, and promotional communications. As a PAGCOR-registered online gaming platform serving Filipino players across the Philippines, swcv3 is subject to the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

swcv3 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and applicable data protection law. Players may contact the DPO directly through the support channel at [email protected], specifying "Data Privacy" in the subject line. All data privacy enquiries are handled separately from general customer support and are escalated to the DPO team within one (1) business day of receipt.

2. Personal Data We Collect

swcv3 collects personal data through several channels: directly from you when you register or use the platform, automatically through the platform's technical systems, and — where legally required — from third-party verification and payment providers. The categories of data we collect are set out below.

2.1 Registration Data

When you create a swcv3 account, we collect your full legal name, date of birth, residential address, email address, and a username of your choosing. This information is mandatory to establish and operate your account under PAGCOR's registration requirements.

2.2 Identity Verification (KYC) Data

To comply with PAGCOR regulations and Philippine AML/CTF law, swcv3 collects copies of government-issued identity documents (such as a PhilSys ID, passport, or driver's license), proof of address documents, and — where required — proof of source of funds. This data is handled with the highest level of security controls applied within the swcv3 data environment.

2.3 Financial Transaction Data

swcv3 records all deposits and withdrawals processed through your account, including transaction amounts, timestamps, payment method references (e.g., GCash wallet reference numbers, BPI transaction IDs), and transaction outcomes. Full payment card or bank account numbers are never stored by swcv3 — only tokenised or masked references as provided by the payment processor.

2.4 Gaming Activity Data

We record your gaming history on the platform, including games played, wager amounts, outcomes, session durations, and bonus usage. This data is used for account management, responsible gaming monitoring, dispute resolution, and regulatory reporting to PAGCOR where required.

2.5 Technical & Device Data

swcv3 automatically collects technical data when you access the platform, including your IP address, device type, operating system, browser type and version, screen resolution, and session timestamps. This data is used for security monitoring, fraud detection, and platform performance optimisation.

2.6 Communications Data

If you contact swcv3 support via live chat or email, we retain a record of that communication — including its content, timestamps, and resolution outcome — for quality assurance, training, and dispute resolution purposes. Support communications are retained for a period of three (3) years.

3. Purpose & Legal Basis for Processing

swcv3 processes personal data only for specific, declared purposes and only where a lawful basis for processing exists under the Data Privacy Act of 2012. The primary purposes and corresponding legal bases are as follows:

• Account Registration & Management — Processing is necessary for the performance of the contract between you and swcv3 (i.e., the Terms & Conditions you accept upon registration).
• Identity Verification & KYC — Processing is required for compliance with a legal obligation under PAGCOR regulations and the Anti-Money Laundering Act of 2001 as amended.
• Payment Processing — Processing is necessary for the performance of the contract, specifically to facilitate PHP deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank.
• Fraud Detection & AML Monitoring — Processing is required for compliance with legal obligations under Philippine AML/CTF law and is also in swcv3's legitimate interests in protecting the integrity of the platform.
• Responsible Gaming Monitoring — Processing is necessary for compliance with PAGCOR's responsible gaming requirements and is in the legitimate interests of player welfare.
• Customer Support — Processing is necessary for the performance of the contract, enabling swcv3 to resolve player queries and disputes effectively.
• Marketing Communications — Processing is based on your consent, which you may withdraw at any time. See Section 11 for details.
• Platform Analytics & Improvement — Processing is based on swcv3's legitimate interests in improving the performance, security, and user experience of the platform.

4. Data Sharing & Third Parties

swcv3 does not sell, rent, or trade personal data. We share personal data with third parties only in the following limited circumstances, and only to the extent strictly necessary for the stated purpose:

4.1 Service Providers (Data Processors)

swcv3 engages third-party service providers who process personal data on swcv3's behalf, under written data processing agreements that bind them to process the data only as instructed and to maintain security standards equivalent to those applied by swcv3. This includes:

• KYC and identity verification technology providers
• Payment processors and e-wallet partners (GCash, PayMaya, BPI, BDO, Metrobank)
• AML/CTF screening and transaction monitoring providers
• Cloud infrastructure and hosting providers whose data centers serve the Philippine market
• Customer support software providers

4.2 Regulatory Disclosure

swcv3 is legally required to disclose player data to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities when compelled by law, valid regulatory demand, or court order. swcv3 will notify affected players of any such disclosure to the extent permitted by law.

4.3 Business Transfers

In the event that swcv3 undergoes a merger, acquisition, or transfer of its business operations, player personal data may be transferred to the successor entity as part of that transaction. Players will be notified of any such transfer and the privacy terms applicable to their data under the new entity at least 30 days before the transfer takes effect.

5. Data Retention

swcv3 retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable Philippine law. The following retention periods apply as a general guide:

When personal data reaches the end of its retention period, it is securely deleted or anonymised in accordance with swcv3's data destruction procedures. Anonymised data — where no individual can be identified from it — may be retained beyond these periods for aggregate analytics purposes.

6. Security Measures

swcv3 implements a layered security architecture designed to protect player personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security measures include, but are not limited to:

• 256-bit SSL/TLS Encryption: All data in transit between player devices and swcv3 servers is encrypted using industry-standard TLS 1.2 or higher.
• AES-256 Data-at-Rest Encryption: Personal data stored in swcv3's database infrastructure is encrypted at the storage level using AES-256.
• Access Controls: Access to personal data within swcv3's systems is restricted on a strict need-to-know basis. Staff with access to player data undergo background checks and receive mandatory data privacy training.
• Multi-Factor Authentication: Internal system access for swcv3 staff requires multi-factor authentication. Players are strongly encouraged to enable MFA on their own accounts.
• Intrusion Detection & Monitoring: swcv3's infrastructure is monitored 24/7 for suspicious activity, intrusion attempts, and anomalous data access patterns.
• Penetration Testing: swcv3 conducts periodic third-party penetration testing of its platform and infrastructure to identify and remediate vulnerabilities proactively.

7. Cookies & Tracking Technologies

swcv3 uses cookies and similar browser-based technologies to operate the platform, maintain your session security, and understand how players use the site so we can improve it. We do not use third-party advertising or tracking cookies.

7.1 Types of Cookies Used

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies, CSRF protection tokens, and load-balancing cookies. These cannot be disabled without breaking core platform functionality.
• Functional Cookies: Remember your preferences such as language settings, responsible gaming limit preferences, and display options. Stored for the duration of your session or up to 30 days if you choose to save preferences.
• Analytics Cookies: Used to collect aggregated, anonymised data on how pages are used — such as which game categories receive the most visits, and where players encounter errors. No individual player behaviour is tracked at a personally identifiable level through these cookies.

7.2 Cookie Lifespan

Session cookies are deleted automatically when you close your browser. Persistent cookies set by swcv3 have a maximum lifespan of 12 months, after which they expire and are re-issued on your next visit if you continue using the platform.

7.3 Managing Cookies

You may control cookie settings through your browser's privacy preferences. Disabling strictly necessary cookies will prevent you from logging in to your swcv3 account. Disabling analytics cookies will not affect your ability to use the platform but will mean swcv3 receives less data to improve the experience for Filipino players.

8. Your Data Rights Under Philippine Law

Under the Data Privacy Act of 2012, registered swcv3 players have the following rights with respect to their personal data:

• Right to Be Informed: You have the right to know what personal data swcv3 holds about you, the purposes for which it is processed, and who it is shared with. This Privacy Policy fulfils swcv3's primary obligation under this right.
• Right to Access: You may request a copy of the personal data swcv3 holds about you at any time. Requests are processed within 15 business days.
• Right to Rectification: If any personal data swcv3 holds about you is inaccurate or incomplete, you have the right to request correction. Basic account information (name, address, email) can be updated directly from your account settings. KYC-related corrections require submission of updated supporting documents.
• Right to Erasure: You may request deletion of your personal data in certain circumstances — for example, where the data is no longer necessary for the purpose it was collected. This right is subject to swcv3's legal retention obligations under PAGCOR and AML regulations, which may require certain data to be retained for up to five years after account closure regardless of a deletion request.
• Right to Object: You have the right to object to the processing of your personal data for marketing purposes at any time. You may also object to processing based on legitimate interests where you believe your rights override those interests.
• Right to Data Portability: Where technically feasible, you may request that swcv3 provide your personal data in a structured, machine-readable format so it can be transferred to another controller.
• Right to Lodge a Complaint: If you believe swcv3 has handled your personal data in violation of RA 10173, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

To exercise any of the above rights, please contact the swcv3 data privacy team at [email protected]. Please include your full registered name, account username, and a clear description of your request. Identity verification may be required before the request is processed.

9. Minors & Age Policy

swcv3 is strictly prohibited to persons under the age of 21 years, as mandated by PAGCOR regulations governing online gaming in the Philippines. swcv3 does not knowingly collect personal data from individuals under 21 years of age.

Where swcv3 becomes aware — through KYC review, player self-disclosure, or third-party report — that an account has been registered by a person under 21, the account will be immediately suspended. All real-money deposits made by the underage player will be returned to the payment source used, and any gaming activity or winnings generated will be treated as void in accordance with PAGCOR requirements. Personal data associated with the underage account will be retained only as long as required to process the account closure and comply with any related regulatory reporting obligation, then securely deleted.

10. Cross-Border Data Transfers

swcv3 primarily processes and stores personal data within facilities that serve the Philippine market. Where it is necessary to transfer personal data outside the Philippines — for example, to cloud infrastructure providers or technology partners with operations in other jurisdictions — swcv3 ensures that such transfers are protected by appropriate safeguards, including:

• Contractual clauses in data processing agreements that bind recipient organisations to data protection standards equivalent to those under RA 10173.
• Transfer only to jurisdictions or organisations that have been assessed by swcv3's compliance team as providing an adequate level of data protection for the categories of personal data being transferred.
• Limiting the scope of any cross-border transfer to only the data strictly required by the recipient service provider for the specific service they are performing for swcv3.

Players may request details of the cross-border transfer safeguards applicable to their data by contacting the swcv3 data privacy team.

11. Marketing Communications

swcv3 may send you promotional communications — including information about new games, bonus offers, and platform features — by email or in-platform notification, but only where you have opted in to receive such communications. Marketing consent is collected separately during the registration process and is never bundled with mandatory account terms.

You may withdraw your marketing consent at any time by:

• Updating your communication preferences from within your swcv3 account settings under "Notifications & Marketing".
• Clicking the unsubscribe link included at the bottom of every marketing email sent by swcv3.
• Contacting the swcv3 support team at [email protected] and requesting removal from all marketing lists.

Withdrawal of marketing consent takes effect within 5 business days. Please note that withdrawing marketing consent does not affect transactional communications — such as deposit confirmations, withdrawal notifications, KYC status updates, and important account or security alerts — which swcv3 may continue to send as they are necessary for the operation of your account.

12. Complaints & Contact

If you have a concern, question, or complaint regarding how swcv3 has handled your personal data, we encourage you to contact us directly in the first instance so we have an opportunity to address the issue:

• Data Privacy Team: [email protected] — please include "Data Privacy" in the subject line.
• Response Time: swcv3 acknowledges data privacy complaints within 2 business days and provides a substantive response within 15 business days as prescribed by RA 10173.

If you are not satisfied with swcv3's response to your data privacy complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines (NPC). The NPC accepts complaints from data subjects at its offices and through its official online channels. swcv3 fully cooperates with NPC investigations and audit requests.

13. Policy Amendments

swcv3 reviews this Privacy Policy at least annually and updates it whenever there are material changes to our data processing practices, applicable law, or PAGCOR regulatory requirements. The "Last updated" date at the top of this document reflects the date of the most recent revision.

Where a proposed amendment materially affects players' data rights or the way swcv3 uses personal data, we will provide at least 14 days' advance notice by email to all registered players and/or via a prominent notice on the platform before the revised policy takes effect. Continued use of swcv3 following the effective date of a revised Privacy Policy constitutes your acknowledgment of the updated terms.

For historical versions of this Privacy Policy, players may submit a request to the data privacy team at [email protected].