Privacy Policy

1. Who We Are

suissewin ("suissewin," "we," "us," or "our") operates the online gaming platform accessible at suissewin.asia. suissewin is the data controller responsible for the personal information collected through our platform, mobile applications, and related services.

suissewin operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR) and is committed to full compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission (NPC) of the Philippines.

For all privacy-related inquiries, you may contact our Data Protection Officer at: [email protected]

2. Personal Data We Collect

suissewin collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

We do not collect sensitive personal information (as defined under the Data Privacy Act) unless strictly required for regulatory compliance, such as government ID details for KYC verification purposes.

3. How We Collect Your Data

suissewin collects personal data through the following means:

3.1 Direct Collection

You provide data directly to suissewin when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, participate in promotions, or respond to surveys.

3.2 Automated Collection

When you access the suissewin platform, we automatically collect technical and usage data through cookies, web beacons, server logs, and similar tracking technologies. This data helps us maintain platform security, analyze usage patterns, and improve your gaming experience.

3.3 Third-Party Sources

We may receive data about you from third-party sources, including payment processors (such as GCash and PayMaya), identity verification service providers, fraud prevention agencies, and analytics partners. All third-party data sharing is conducted under strict data processing agreements that require compliance with the Data Privacy Act of 2012.

4. How We Use Your Personal Data

suissewin uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your suissewin account, including authentication and security;
• Service Delivery: To provide access to games, process deposits and withdrawals, and deliver the core gaming services of the suissewin platform;
• Regulatory Compliance: To fulfill our obligations under PAGCOR regulations, the Data Privacy Act of 2012, and applicable anti-money laundering (AML) and counter-terrorism financing (CTF) laws in the Philippines;
• KYC Verification: To verify your identity and age (21+) as required by PAGCOR and Philippine law;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats;
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance;
• Responsible Gaming: To monitor gaming behavior and provide responsible gaming tools, including deposit limits and self-exclusion, in accordance with PAGCOR guidelines;
• Marketing & Promotions: To send you relevant promotional offers, bonuses, and platform updates, subject to your communication preferences (you may opt out at any time);
• Platform Improvement: To analyze usage data and improve the features, performance, and user experience of the suissewin platform;
• Legal Obligations: To comply with court orders, regulatory requests, or other legal obligations applicable to suissewin.

5. Legal Basis for Processing

suissewin processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform our contract with you (i.e., to provide the suissewin gaming services you have registered for);
• Legal Obligation: Processing is required to comply with applicable Philippine laws and PAGCOR regulatory requirements, including KYC, AML, and responsible gaming obligations;
• Legitimate Interests: Processing is necessary for suissewin's legitimate interests, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights;
• Consent: For marketing communications and non-essential cookies, we rely on your explicit consent, which you may withdraw at any time.

6. Data Sharing & Disclosure

suissewin does not sell your personal data to third parties. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other payment service providers, for the purpose of processing your deposits and withdrawals;
• Identity Verification Providers: Third-party KYC and age verification service providers engaged to verify your identity in compliance with PAGCOR requirements;
• Fraud Prevention & Security Partners: Service providers that assist suissewin in detecting and preventing fraudulent activity and unauthorized access;
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where disclosure is required by law or regulation;
• Technology & Infrastructure Providers: Cloud hosting, data analytics, and platform technology providers engaged to support the operation of the suissewin platform, all of whom are bound by data processing agreements;
• Legal & Professional Advisors: Lawyers, auditors, and other professional advisors engaged by suissewin, subject to professional confidentiality obligations.

All third parties with whom suissewin shares personal data are required to process such data only for the specified purpose and in accordance with applicable data protection laws.

7. Cookies & Tracking Technologies

suissewin uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze how you use our platform.

7.1 Types of Cookies We Use

• Essential Cookies: Required for the platform to function correctly, including session management and security. These cannot be disabled.
• Functional Cookies: Remember your preferences (such as language settings and game preferences) to personalize your experience.
• Analytics Cookies: Help us understand how players use the suissewin platform so we can improve performance and features.
• Marketing Cookies: Used to deliver relevant promotional content. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Note that disabling essential cookies may affect the functionality of the suissewin platform.

8. Data Retention

suissewin retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including compliance with legal, regulatory, and contractual obligations.

• Active Account Data: Retained for the duration of your account's active status plus a minimum of five (5) years following account closure, in compliance with PAGCOR and AML record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• KYC Documents: Retained for a minimum of five (5) years following account closure or the completion of the transaction to which they relate.
• Support Communications: Retained for three (3) years from the date of the communication.
• Marketing Data: Retained until you withdraw your consent or request deletion, whichever is earlier.

Upon expiry of the applicable retention period, suissewin will securely delete or anonymize your personal data in accordance with our internal data disposal procedures.

9. Data Security

suissewin implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and the suissewin platform;
• Encryption of sensitive data at rest, including financial information and government ID details;
• Multi-factor authentication options for player accounts;
• Regular security audits and vulnerability assessments of our platform infrastructure;
• Strict access controls limiting employee access to personal data on a need-to-know basis;
• Staff training on data protection obligations and security best practices;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, suissewin will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012 and NPC Circular No. 16-03.

10. Your Data Privacy Rights

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

• Right to be Informed: You have the right to be informed about how suissewin collects, uses, and processes your personal data, as set out in this Privacy Policy;
• Right of Access: You have the right to request a copy of the personal data suissewin holds about you, along with information about how it is being processed;
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you;
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations;
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to your request within fifteen (15) business days. We may need to verify your identity before processing your request.

11. Children's Privacy

If you are a parent or guardian and believe that your child has registered on the suissewin platform or provided us with personal data, please contact us immediately at [email protected] so that we can take appropriate action.

12. International Data Transfers

suissewin primarily processes and stores personal data within the Philippines. In certain circumstances, your personal data may be transferred to and processed in countries outside the Philippines, for example where suissewin engages technology or service providers with infrastructure located abroad.

Where such international transfers occur, suissewin ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that require the recipient to process your data in accordance with standards equivalent to those required under the Data Privacy Act of 2012. suissewin will not transfer your personal data to a foreign country unless that country has been deemed to provide an adequate level of protection, or appropriate safeguards have been implemented.

13. Changes to This Privacy Policy

suissewin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. The date of the most recent revision will always be indicated at the top of this page.

Where changes are material, suissewin will notify registered players via email or a prominent notice on the platform prior to the changes taking effect. We encourage you to review this Privacy Policy periodically to stay informed about how suissewin protects your personal data. Your continued use of the suissewin platform following any update constitutes your acceptance of the revised Privacy Policy.

14. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the way suissewin handles your personal data, please contact our Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have not been adequately addressed by suissewin. For more information about your rights under the Data Privacy Act of 2012, visit the NPC's official resources.

For responsible gaming concerns, please visit our Responsible Gaming page. For general platform information, visit our About Us page or review our Terms & Conditions.