Privacy Policy swip9 —
Data Protection Player Privacy

1. Personal Information We Collect

In operating the swip9 platform, we collect various types of personal information from you. This collection occurs directly through account registration and platform use, as well as automatically through technologies such as cookies and server logs. Each category of data we collect has a clear and legitimate purpose.

1.1 Information You Provide Directly

• Identity Information: Full name, identification card number (MyKad), date of birth, gender and profile picture.
• Contact Information: Email address, mobile phone number and residential address.
• Account Information: Username, password (stored in hashed form) and security preferences such as security questions.
• Financial Information: Bank account number, bank name, eWallet details and transaction history within the swip9 platform.
• KYC Documents: Copies of identity cards, bank statements, and other identity verification documents submitted during the account verification process.

1.2 Information Collected Automatically

• Technical Data: IP address, web browser type, operating system, device type and language settings.
• Usage Data: Pages visited, session duration, game preferences, wagering history and interactions within the platform.
• Location Data: General geographic location based on IP address for regulatory compliance and fraud detection purposes.
• Cookie Data: Information collected through cookies and other tracking technologies as described in detail in Section 5.

2. How swip9 Uses Your Data

The personal data we collect is used for legitimate and transparent purposes. swip9 does not use your data for purposes beyond the scope stated below without first obtaining additional consent from you.

3. Legal Basis for Personal Data Processing

Under the Malaysian Personal Data Protection Act 2010 (PDPA), swip9 processes your personal data on the following lawful bases:

• Consent: You have given explicit consent for the processing of your data for specific purposes, such as receiving marketing communications or optional personalisation features.
• Contract Performance: Data processing is necessary to fulfil the agreement between you and swip9, including managing your account, processing transactions and providing the services you request.
• Legal Obligations: swip9 is legally required to collect and retain certain data, including financial records and identity verification (KYC) information, for anti-money laundering regulatory compliance purposes.
• Legitimate Interests: Certain data processing is necessary for the legitimate interests of swip9 or third parties, such as preventing fraud, ensuring platform security and improving our services — provided these interests do not override your fundamental rights and freedoms.

4. Data Sharing with Third Parties

Swip9 does not sell or trade your personal data. However, in the course of normal platform operations, we may share your data with the following categories of third parties, and only to the extent necessary:

4.1 Operational Partners

• Payment Providers: FPX, DuitNow, eWallet providers and other payment gateways that process your financial transactions. They receive only the data necessary to process the relevant transaction.
• Game Providers: Slot game, Live Casino, and Fish Shooting Games developers that provide gaming content on swip9. Data sharing is limited to the game session information required.
• Identity Verification Providers: KYC service providers that assist swip9 in verifying player identities in accordance with legal requirements.
• Cloud Infrastructure: Cloud computing service providers that host the swip9 platform. All such providers are subject to strict data processing agreements.

4.2 Regulatory Authorities

Swip9 may disclose your personal data to government authorities, law enforcement bodies, or courts where required to do so by applicable law, court order, or in response to a valid official investigation. In such situations, swip9 will notify you where permitted by law.

5. Cookies & Tracking Technologies

The swip9 platform uses cookies and similar tracking technologies to enhance user experience, ensure account security, and analyze platform usage in aggregate. The following are the types of cookies we use:

• Necessary Cookies (Required): These cookies are required for the core functions of the swip9 platform, such as login authentication, session management and account security. Without them, the platform cannot function properly. This type of cookie cannot be disabled.
• Performance & Analytics Cookies: Helps us understand how players use the swip9 platform — which pages are visited most frequently, time spent on each section and general navigation patterns. This data is analysed in aggregate and is not linked to individual identities.
• Functional Cookies: Stores your preferences such as preferred language, display settings and game choices so you do not need to reconfigure them each time you log in to swip9.
• Marketing Cookies (with consent): Used to display promotional content more relevant to your interests. You may withdraw consent for this type of cookie at any time.

You can manage your cookie preferences through your web browser settings. Please note that disabling certain cookies may affect the functionality or your experience on the swip9 platform.

6. Data Security Measures

Protecting your personal data is a responsibility we take seriously. swip9 has implemented multiple layers of technical and organisational security measures to ensure your data is protected against unauthorised access, loss, misuse or disclosure.

While we take all reasonable steps to protect your data, no security system can guarantee 100% absolute security. In the event of a data security incident involving your personal information, swip9 will notify you and the relevant authorities within the timeframe prescribed by law.

7. Data Retention Period

Swip9 retains your personal data for as long as necessary to fulfil the purposes stated in this Privacy Policy or as required by law. The following are key data retention period guidelines:

• Active Account Data: Retained for the duration your account is active on swip9 and for a reasonable period after account closure for dispute resolution purposes.
• Financial Transaction Records: Retained for a minimum of 7 years from the transaction date, in accordance with applicable financial laws and regulations in Malaysia.
• KYC Documents: Retained for a minimum of 6 years after account closure, in accordance with the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001.
• Support Communication Logs: Retained for 3 years to allow swip9 to reference interaction history should any enquiry or dispute arise at a later date.
• Marketing Data: Retained until you withdraw your consent or request deletion, subject to any applicable legal retention requirements.

Once the applicable retention period has ended, your personal data will be securely deleted or anonymized so that it can no longer be associated with you.

8. Your Rights as a Data Subject

As a swip9 player and data subject under Malaysia's PDPA, you have the following rights regarding your personal data. swip9 is committed to respecting and facilitating the exercise of these rights:

9. Children's Data Protection

The swip9 platform is strictly restricted to individuals who are of age 18 years and above. swip9 does not intentionally collect, store or process any personal data from individuals under the age of 18.

If swip9 discovers that personal data of an individual under the age of 18 has been collected without our knowledge, we will take immediate steps to delete that data from our systems. If you believe your child has registered an account on swip9, please contact us immediately at [email protected] so we can take the appropriate action.

10. Amendments to This Privacy Policy

Swip9 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or business operations. Any changes will take effect upon publication of the updated version on this page.

• Material Changes: For any material changes that affect how we process your personal data, swip9 will provide at least 14 days' notice before those changes take effect, via in-platform notification or email to your registered address.
• Minor Changes: Typographical corrections, clarifications or other minor changes may be updated without prior notice, but the update date at the top of this page will always reflect the latest version.
• Ongoing Consent: Continued use of the swip9 platform after the Privacy Policy has been updated will be considered your acceptance of those changes. If you do not agree with the amendments made, please discontinue use of the platform and contact us to close your account.

We encourage you to review this Privacy Policy page periodically to ensure you are always up to date on how swip9 protects your personal data.

11. Contact Our Data Protection Officer

If you have any questions, concerns, or complaints regarding this Privacy Policy or how swip9 handles your personal data, do not hesitate to contact us. The swip9 team is ready to assist you promptly and professionally.