sw418 Privacy Policy

1. Introduction and Data Controller

1.1 sw418 is the personal information controller (as defined under the DPA) responsible for your personal data collected through the sw418.app Platform, its subdomains, and any related services.

1.2 sw418 is committed to processing your personal data lawfully, fairly, and transparently. We collect only the data we genuinely need to provide you with a safe, secure, and enjoyable online gaming experience on the sw418 Platform.

1.3 This Policy applies to all personal data collected from sw418 account holders, players, visitors to sw418.app, and individuals who contact sw418 through any channel including live chat and email support.

2. Personal Data We Collect

sw418 may collect and process the following categories of personal data:

2.1 Registration and Account Data:

• Full legal name as it appears on a Philippine government-issued ID;
• Date of birth (to verify the 21+ age requirement);
• Philippine mobile number and email address;
• Username and encrypted password;
• Residential address in the Philippines.

2.2 Identity Verification (KYC) Data:

• Copies of government-issued identification documents (e.g., Philippine National ID, passport, driver's license, UMID, SSS/GSIS card, voter's ID);
• Proof of address documents where required;
• Selfie or facial biometric data where required by our KYC partner for identity matching.

2.3 Financial and Transaction Data:

• GCash account number or PayMaya account details linked to your sw418 account;
• Bank account details (BPI, BDO, Metrobank) for bank transfer deposits and withdrawals;
• Transaction history including deposits, withdrawals, wagers, and winnings on the sw418 Platform;
• Source of funds information as required under Philippine AML regulations.

2.4 Technical and Usage Data:

• IP address and approximate geographic location;
• Device type, operating system, browser type, and screen resolution;
• Pages visited on sw418.app, session duration, click patterns, and game play data;
• Login timestamps and session identifiers.

2.5 Communications Data:

• Records of live chat conversations and support email exchanges with sw418 customer support;
• Any personal data you voluntarily provide when contacting sw418 for assistance.

3. How We Collect Your Data

3.1 Directly from you — when you register a sw418 account, complete KYC verification, make a deposit or withdrawal, contact sw418 support, or participate in a promotion.

3.2 Automatically — through cookies, web beacons, and server logs when you access or interact with sw418.app. See Section 6 for full details on cookies.

3.3 From third parties — sw418 may receive identity verification data from KYC service providers; payment data from GCash, PayMaya, and banking partners in connection with processing your transactions; and fraud prevention data from third-party risk management services.

4. Why We Use Your Personal Data

sw418 processes your personal data for the following purposes and on the following legal bases:

• Account creation and management — to create, operate, and maintain your sw418 account (contract performance);
• Identity verification — to verify your identity and age (21+) as required by Philippine gaming regulations and AML law (legal obligation);
• Payment processing — to process deposits, withdrawals, and winnings via GCash, PayMaya, and Philippine bank transfers (contract performance);
• Anti-money laundering (AML) compliance — to detect, investigate, and report suspicious financial activity as required by the Philippine Anti-Money Laundering Act (AMLA) and related regulations (legal obligation);
• Responsible gaming — to monitor gaming patterns, enforce self-exclusion requests, and implement deposit or loss limits you have set (legal obligation and legitimate interest);
• Customer support — to respond to your queries, resolve disputes, and improve the quality of sw418 support services (legitimate interest);
• Platform security and fraud prevention — to detect and prevent fraudulent activity, account misuse, and cheating on the sw418 Platform (legitimate interest);
• Service improvement — to analyse usage patterns and improve the sw418 Platform's performance, game offering, and user experience (legitimate interest);
• Marketing communications — to send you promotional offers and sw418 bonus notifications where you have consented to receive such communications (consent — you may withdraw at any time).

5. Sharing Your Personal Data

5.1 sw418 does not sell, rent, or trade your personal data. We may share your data with the following categories of third parties strictly for the purposes described in Section 4:

• Payment processors — GCash (G-Xchange Inc.), PayMaya Philippines Inc., BPI, BDO, and Metrobank, to facilitate deposits and withdrawals;
• Identity verification providers — certified KYC and AML compliance partners to verify your identity and satisfy Philippine regulatory requirements;
• Game providers — JILI Games and other game software providers receive anonymised session data necessary to operate games on the sw418 Platform;
• Regulatory authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and any other Philippine government authority where sw418 is legally required to disclose data;
• IT and security service providers — cloud hosting, cybersecurity, and fraud detection partners operating under confidentiality obligations and data processing agreements;
• Professional advisers — lawyers, auditors, and accountants under strict confidentiality obligations, where necessary for sw418's legal and compliance functions.

5.2 All third parties who process personal data on sw418's behalf are contractually bound to process such data only for the specified purpose, maintain appropriate security standards, and comply with applicable Philippine privacy law.

6. Cookies and Tracking Technologies

6.1 sw418 uses the following types of cookies and similar technologies on sw418.app:

• Strictly Necessary Cookies — required for the Platform to function. These include session cookies that maintain your sw418 login state and security tokens that protect against cross-site request forgery. These cannot be disabled;
• Functional Cookies — remember your preferences such as language settings and game lobby display options. These improve your sw418 experience but are not essential;
• Analytics Cookies — collect anonymised data about how players use sw418.app to help us improve Platform performance and navigation. sw418 does not share analytics data with third-party advertising networks.

6.2 sw418 does not use third-party advertising or retargeting cookies. You will not see sw418 advertisements follow you across the internet based on your sw418.app browsing activity.

6.3 You may configure your browser to refuse or delete cookies. Note that disabling strictly necessary cookies will prevent you from logging in to your sw418 account.

7. Data Security

7.1 sw418 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and sw418 servers;
• Encryption of sensitive data at rest including passwords (salted hashes) and payment credentials;
• Two-factor authentication (2FA) available to all sw418 account holders;
• Role-based access controls limiting sw418 staff access to personal data on a strict need-to-know basis;
• Regular security audits and penetration testing of sw418 systems;
• Real-time fraud detection and anomaly monitoring on all sw418 accounts.

7.2 In the event of a personal data breach that poses a risk to your rights and freedoms, sw418 will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with Section 20(f) of the DPA and NPC Circular 16-03.

8. Data Retention

8.1 sw418 retains your personal data for as long as necessary to fulfil the purposes described in this Policy and to comply with applicable legal obligations. Specific retention periods include:

• Account data — retained for the duration of your sw418 account and for 5 years following account closure, as required by Philippine AML regulations;
• KYC/identity documents — retained for 5 years from the date of last transaction, in compliance with the AMLA and PAGCOR requirements;
• Transaction records — retained for 5 years from the date of each transaction;
• Support communications — retained for 3 years from the date of the communication;
• Technical/usage logs — retained for 12 months from the date of collection.

8.2 Upon expiry of the applicable retention period, sw418 will securely delete or anonymise your personal data.

9. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by sw418:

• Right to be Informed — the right to know that your personal data is being collected and how it is processed (this Policy fulfils this obligation);
• Right of Access — the right to request a copy of the personal data sw418 holds about you;
• Right to Rectification — the right to correct inaccurate or incomplete personal data in your sw418 account;
• Right to Erasure (Right to be Forgotten) — the right to request deletion of your personal data, subject to sw418's legal retention obligations under AML and gaming regulations;
• Right to Object — the right to object to certain processing of your personal data, including processing for direct marketing purposes;
• Right to Data Portability — the right to receive your personal data in a structured, commonly used format;
• Right to Lodge a Complaint — the right to file a complaint with the National Privacy Commission of the Philippines if you believe sw418 has violated your data privacy rights.

To exercise any of these rights, contact sw418's Data Protection Officer at [email protected]. sw418 will respond within 15 business days. Some requests may be subject to identity verification before sw418 can action them.

10. Children's Privacy

10.1 The sw418 Platform is strictly prohibited to persons under 21 years of age. sw418 does not knowingly collect personal data from individuals under the age of 21.

10.2 If sw418 becomes aware that personal data has been collected from a person under 21 without verified parental or guardian consent, that data will be immediately deleted and the associated account permanently suspended.

10.3 If you are a parent or guardian and believe that a minor has provided personal data to sw418, please contact us immediately at [email protected].

11. Cross-Border Data Transfers

11.1 In the course of providing the sw418 Platform, your personal data may be transferred to or processed in countries outside the Philippines — for example, by cloud infrastructure providers or game software partners operating data centres in other jurisdictions.

11.2 Where such transfers occur, sw418 ensures that adequate safeguards are in place to protect your personal data, including contractual obligations that require the recipient to maintain data protection standards equivalent to those required under Philippine law.

11.3 By using the sw418 Platform, you consent to such transfers as described in this Section, subject to the safeguards described above.

12. Updates to This Privacy Policy

12.1 sw418 may update this Privacy Policy periodically to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent update is displayed at the top of this Policy.

12.2 Where changes are material, sw418 will notify registered players via email or through a prominent notice on sw418.app prior to the changes taking effect. Your continued use of the sw418 Platform following such notice constitutes acceptance of the updated Policy.

13. Contact and Data Protection Officer

For any questions about this Privacy Policy, to exercise your data rights, or to report a privacy concern, please contact sw418's designated Data Protection Officer (DPO):

• Email: [email protected] (subject line: "Privacy / DPO Request")
• Live Chat: Available 24/7 on sw418.app in English and Tagalog
• Response Time: Within 15 business days for formal data rights requests; within 4 hours for general privacy enquiries via email

If you are not satisfied with sw418's response to a privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines at [email protected] or through the NPC's official online complaints portal.