Swerte Max Privacy Policy — How We Protect Your Personal Data

1Who We Are — The Data Controller

Swerte Max is the online betting and gaming platform operated at swertemax.asia. For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act 10173), Swerte Max acts as the Personal Information Controller (PIC) for all personal data collected through the platform.

Swerte Max operates under a license issued by the Philippine Amusement and Gaming Corporation (PAGCOR) and is registered with the National Privacy Commission (NPC) of the Philippines. Our Data Protection Officer (DPO) oversees all data privacy matters and can be contacted directly — details are provided in Section 15 of this policy.

This Privacy Policy applies to all personal data collected through the Swerte Max website at swertemax.asia, including through any account registration, deposit or withdrawal transaction, customer support interaction, or participation in any promotional activity offered by Swerte Max.

2What Personal Data We Collect

Swerte Max collects the following categories of personal data, depending on how you interact with the platform:

2.1 Registration and Identity Data

• Full legal name as it appears on your government-issued ID
• Date of birth (to verify the 21+ age requirement)
• Philippine mobile phone number
• Email address
• Current residential address in the Philippines
• Government-issued ID type and number (submitted during KYC verification)

2.2 Financial and Transaction Data

• Deposit and withdrawal amounts and transaction history
• Payment method details — GCash or Maya account name and registered number, bank name and account name for bank transfers, or the first six and last four digits of a Visa/Mastercard used for deposits
• Swerte Max account balance at each transaction point

2.3 Gaming and Betting Activity Data

• Bet history, including game type, stake, odds, and outcome
• Session duration and frequency of play
• Responsible gaming preferences and limit settings you apply to your account

2.4 Technical and Device Data

• IP address at login and during play
• Device type (mobile, tablet, desktop), operating system, and browser type
• Cookies and similar tracking data (see Section 7 for full cookie details)
• Approximate geographic location derived from IP address (not GPS)

2.5 Communications Data

• Customer support chat transcripts and emails sent to or from Swerte Max
• Survey responses and feedback submitted through the platform
• Marketing communication preferences

3Why We Collect Your Data

Swerte Max collects personal data for the following specific, declared purposes — and no others:

4Legal Basis for Processing

Under the Philippine Data Privacy Act (RA 10173), Swerte Max must have a lawful basis for processing your personal data. We rely on the following legal bases:

• Contractual necessity — processing required to provide you with the Swerte Max service you have registered for, including account management, betting, and payments
• Legal obligation — processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act, and NPC registration requirements
• Legitimate interest — processing for fraud prevention, platform security, and responsible gaming monitoring, where our interest does not override your privacy rights
• Consent — processing for marketing communications and non-essential cookies, where you have provided explicit opt-in consent. You may withdraw consent at any time.

5How We Use Your Personal Data

In addition to the purposes listed in Section 3, here is more detail on specific ways your data is used in your day-to-day experience with Swerte Max:

Account and security: Your registration data and device information are used to authenticate your identity when you log in, detect suspicious login attempts, and maintain the security of your account. If an unusual login is detected from an unfamiliar device or location, Swerte Max may require additional verification before granting access.

Personalisation: Swerte Max may use your betting history and game preferences to personalise the game lobby — for example, surfacing PBA odds prominently if you regularly bet on basketball, or showing Color Game promotions if that is your most-played game. This personalisation is based on your own activity on the platform and does not involve external data sources.

Responsible gaming: Your betting frequency, session duration, and stake sizes are monitored by Swerte Max's responsible gaming system. If patterns that may indicate problem gambling are detected, Swerte Max may reach out proactively to offer support tools. This monitoring is conducted in your interest and is required under our PAGCOR license.

Communications: Swerte Max will send you transactional communications — such as deposit confirmations, withdrawal notifications, and security alerts — as a necessary part of operating your account. These are not marketing communications and cannot be opted out of while your account remains active. If you have opted in to marketing, you may also receive promotions, bonus offers, and platform news. You can opt out of marketing communications at any time through your account settings or by emailing our DPO.

6Sharing Your Personal Data

Swerte Max does not sell, rent, or trade your personal data. We share personal data only in the following limited circumstances:

• Payment processors: GCash, Maya, GrabPay, and our bank transfer partners receive the minimum data required to process your deposits and withdrawals — typically your registered name and transaction amount. These partners are bound by their own privacy policies and Philippine financial regulations.
• KYC and identity verification providers: Swerte Max uses a third-party KYC service to verify government IDs and proof of address during account verification. This provider processes your identity data strictly for verification purposes and is bound by a data processing agreement with Swerte Max.
• PAGCOR and regulatory authorities: As required by our gaming license, Swerte Max provides player transaction summaries and activity reports to PAGCOR. We also comply with lawful requests from the Anti-Money Laundering Council (AMLC) and other Philippine government agencies where legally required.
• Technology infrastructure providers: Swerte Max's platform runs on third-party cloud and hosting infrastructure. These providers access server data only as necessary to provide infrastructure services and are bound by confidentiality agreements and applicable Philippine data protection requirements.
• Legal proceedings: Swerte Max may disclose personal data if required by a valid Philippine court order, warrant, or other lawful legal process. We will notify you of such a disclosure where legally permitted to do so.

7Cookies and Tracking Technologies

Swerte Max uses cookies and similar technologies to make the platform work correctly, improve your experience, and comply with security requirements. Here is how each category works:

You can manage your cookie preferences through your browser settings at any time. Note that disabling essential cookies will prevent the Swerte Max platform from functioning correctly.

8How Long We Keep Your Data

Swerte Max retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by Philippine law:

• Account data — retained for the duration of your active account plus 5 years after account closure. This retention period is required by PAGCOR regulations and the Anti-Money Laundering Act.
• Transaction records — retained for 5 years from the date of each transaction, as required by the AMLC and PAGCOR reporting requirements.
• KYC identity documents — retained for 5 years after your last transaction or account closure, whichever is later.
• Customer support records — retained for 2 years from the date of the last interaction, then deleted unless the interaction is related to an active legal or regulatory matter.
• Marketing preferences and opt-in records — retained until you withdraw consent or close your account, plus 1 year to maintain proof of consent.
• Session and technical logs — retained for 12 months for security and fraud investigation purposes, then anonymised or deleted.

When data is no longer required, Swerte Max deletes or anonymises it using secure data destruction methods that prevent reconstruction or recovery.

9How We Secure Your Data

Swerte Max implements the following technical and organisational security measures to protect your personal data against unauthorised access, loss, misuse, or disclosure:

• Transport encryption: All data in transit between your device and the Swerte Max platform is encrypted using TLS 1.3 with 256-bit AES encryption.
• Data at rest: Databases and file storage systems containing personal data are encrypted at the storage level. Encryption keys are managed separately from encrypted data.
• Access control: Swerte Max employees can only access personal data relevant to their specific role. All internal access is logged, reviewed, and subject to least-privilege principles. Access is immediately revoked upon employment termination.
• Two-factor authentication: All Swerte Max administrative systems require two-factor authentication. Players are strongly encouraged to enable 2FA on their own accounts through account settings.
• Regular security audits: Swerte Max undergoes periodic independent security assessments, including penetration testing and vulnerability scanning, to identify and address security weaknesses proactively.
• Staff training: All Swerte Max staff who handle personal data complete mandatory data privacy and security training on joining the company and annually thereafter.

10Your Rights Under RA 10173

The Philippine Data Privacy Act of 2012 gives every Filipino whose personal data is held by an organisation a set of enforceable rights. As a Swerte Max player, you have all of the following rights regarding your personal data:

To exercise any of these rights, contact our Data Protection Officer at privacy@swertemax.asia. We will verify your identity before processing any data rights request and will respond within 15 working days. If you are not satisfied with our response, you have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines.

11Children's Privacy

Swerte Max is strictly an adults-only platform. We do not knowingly collect, store, or process personal data from anyone under the age of 21. Our registration process includes an age declaration and identity verification step specifically designed to prevent underage registration.

If Swerte Max discovers or is informed that personal data has been collected from a person under 21 years of age — whether through a false age declaration or any other means — we will immediately close the associated account, delete all personal data collected in connection with that account, and report the matter to PAGCOR in accordance with our license obligations.

If you believe a person under 21 has registered on the Swerte Max platform, please contact us immediately at support@swertemax.asia or through live chat so we can investigate and act without delay.

12International Data Transfers

Swerte Max primarily processes and stores personal data on infrastructure located in the Philippines or in compliant regional data centres that serve the Philippine market. In limited cases, certain technology providers used by Swerte Max — such as cloud infrastructure or security services — may process data in data centres outside the Philippines.

Where any cross-border transfer of personal data occurs, Swerte Max ensures that the transfer is subject to appropriate safeguards consistent with the requirements of the Philippine Data Privacy Act, including contractual data processing agreements that bind the receiving party to data protection standards equivalent to those required in the Philippines.

Swerte Max will not transfer your personal data to any country that the National Privacy Commission has determined does not provide adequate protection for personal data, unless appropriate safeguards are in place and approved by the NPC.

13Data Breach Response Protocol

In the event of a personal data breach that is likely to result in harm to affected players, Swerte Max will take the following actions:

1. Containment: Immediately contain the breach to prevent further unauthorised access or disclosure.
2. Assessment: Conduct a rapid assessment to determine the nature, scope, and likely impact of the breach.
3. NPC notification: Notify the National Privacy Commission within 72 hours of becoming aware of the breach, as required by NPC Circular 16-03.
4. Player notification: Notify all affected Swerte Max players by email within 72 hours of the NPC notification, where the breach is likely to result in serious harm.
5. Remediation: Implement corrective measures to prevent recurrence and provide affected players with clear guidance on steps they can take to protect themselves.

Your notification will include: a description of what happened, what data was involved, what Swerte Max is doing about it, and what steps you can take to protect yourself (such as changing your password or monitoring your GCash account).

14Updates to This Privacy Policy

Swerte Max may update this Privacy Policy from time to time to reflect changes in the platform, our data practices, or Philippine regulatory requirements. The "Last Updated" date at the top of this document will always reflect the most recent revision.

When we make material changes — meaning changes that significantly affect how we collect, use, or share your personal data — we will notify you by:

• Sending an email to your registered Swerte Max email address
• Displaying a prominent notice on the Swerte Max homepage and this page
• Showing an in-platform notification on your next login after the update

Your continued use of the Swerte Max platform after any update to this Privacy Policy constitutes your acknowledgement of the updated policy. If you do not agree with changes to the policy, you may request account closure by contacting support — your personal data will be handled in accordance with the retention requirements described in Section 8.

15Contact Our Data Protection Officer

Swerte Max has appointed a registered Data Protection Officer (DPO) as required by the NPC. If you have any question, request, or complaint related to your personal data or this Privacy Policy, please contact our DPO directly:

• Email: privacy@swertemax.asia
• General Support Email: support@swertemax.asia
• Live Chat: Available 24/7 at swertemax.asia — ask to be connected to the privacy team
• Response time: Data rights requests are acknowledged within 2 working days and fulfilled within 15 working days

If your concern is not resolved to your satisfaction after contacting our DPO, you have the right to escalate your complaint to the National Privacy Commission of the Philippines. The NPC can be reached through their official website and handles complaints from Philippine data subjects against personal information controllers.