Privacy Policy — SWB77

SWB77 (referred to in this document as "swb77", "we", "us", or "our") is committed to protecting and respecting the privacy of all individuals who interact with our online gaming platform accessible at swb77.cam (the "Platform"). This Privacy Policy has been prepared in accordance with internationally recognised data protection principles and sets out our practices regarding the collection, use, storage, disclosure, and protection of personal data belonging to our users ("you", "your", or "the Member").

By registering an Account on swb77, depositing funds, placing bets, using our customer support services, or otherwise accessing the Platform, you acknowledge that you have read and understood this Privacy Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you should not use the Platform.

This Policy should be read together with our Terms & Conditions and Responsible Gambling Policy, both of which are incorporated by reference.

For the purposes of this Privacy Policy, the following terms carry the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, identification number, location data, email address, payment details, and any online identifier that can be linked to a specific individual.
• "Processing" means any operation or set of operations performed on personal data, including collection, recording, storage, use, disclosure, transmission, restriction, erasure, or destruction.
• "Data Controller" means swb77, as the entity that determines the purposes and means of processing personal data collected through the Platform.
• "Data Processor" means any third party that processes personal data on behalf of swb77 under a data processing agreement, such as payment service providers, KYC verification services, and IT infrastructure providers.
• "Consent" means a freely given, specific, informed, and unambiguous indication of the data subject's wishes, signifying agreement to the processing of their personal data for one or more specific purposes.
• "KYC" (Know Your Customer) means the regulatory and platform-mandated process of verifying a Member's identity and confirming their eligibility to use the Platform.

swb77 collects personal data from you through multiple channels during the course of our relationship. The categories of data we collect, and the context in which they arise, are as follows:

• Registration data: Full legal name, date of birth, email address, residential address (including city and postcode), and preferred currency (MYR).
• Identity verification (KYC) documents: Government-issued identification (Malaysian IC / MyKad, passport, driving licence), proof of address (utility bill, bank statement), and proof of payment method ownership.
• Financial data: Bank account details, e-wallet identifiers (e.g., Touch 'n Go eWallet, Boost, GrabPay, DuitNow), and transaction history including deposits and withdrawals in MYR.
• Communications data: Content of messages sent to swb77 via live chat, email, or any support channel.
• Responsible gambling data: Voluntary disclosures made when setting deposit limits, requesting self-exclusion, or engaging with responsible gambling tools.

• Technical data: IP address, browser type and version, operating system, device type, screen resolution, and time zone.
• Usage data: Pages visited, games played, bet history, session duration, click-stream data, and in-game behaviour patterns.
• Cookie and tracking data: Information collected through cookies and similar technologies as described in Section 7 of this Policy.
• Log data: Server access logs, error logs, and security event logs generated during your use of the Platform.

• Identity verification data returned by KYC service providers following document checks.
• Fraud and risk scoring data from anti-fraud service providers used to identify suspicious account activity.
• Payment confirmation data from payment processors including FPX, Maybank, CIMB, Public Bank, and Hong Leong confirming transaction status.

The following table summarises the primary data categories and their collection method:

swb77 processes your personal data only for lawful, specified, and explicit purposes. The purposes for which we use your data include:

• Account Management: Creating, maintaining, and administering your player account, including processing deposits and withdrawals in MYR and managing your game wallet balance.
• Identity Verification: Verifying your identity and age (21+) in compliance with our KYC obligations, and confirming your eligibility to use the Platform.
• Transaction Processing: Processing deposits via your chosen Malaysian payment method (Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank, CIMB, Public Bank, Hong Leong) and processing withdrawal requests to your verified account.
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent transactions, money laundering, collusion, and other prohibited activities. We are legally obligated to report certain suspicious transactions to relevant authorities.
• Responsible Gambling: Monitoring gaming behaviour to identify potential problem gambling indicators, applying deposit limits or self-exclusion measures where requested or required, and maintaining records related to responsible gambling interventions.
• Customer Support: Responding to your enquiries, resolving complaints, and providing technical assistance.
• Legal Compliance: Fulfilling our obligations under applicable international gaming licensing conditions, anti-money laundering requirements, and data protection frameworks.
• Service Improvement: Analysing aggregated usage data (in anonymised or pseudonymised form) to improve Platform performance, game selection, and user experience.
• Promotional Communications: Where you have provided consent, sending you updates about promotions, bonuses, and swb77 news. You may withdraw consent for marketing communications at any time by contacting support.

swb77 relies on one or more of the following legal bases when processing your personal data:

• Contractual Necessity: Processing is necessary to perform the contract between you and swb77 (i.e., the Terms & Conditions). This covers account creation, transaction processing, and dispute resolution.
• Legal Obligation: Processing is necessary for compliance with legal obligations applicable to swb77 under our international gaming licence, including KYC/AML requirements and responsible gambling obligations.
• Legitimate Interests: Processing is necessary for swb77's legitimate business interests, provided those interests are not overridden by your rights and freedoms. This includes fraud detection, Platform security, and service analytics.
• Consent: Where we rely on consent (e.g., for sending marketing communications), you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

swb77 does not sell or share your personal data with third parties for their own commercial purposes. We may, however, share data with carefully selected third parties acting as Data Processors on our behalf, or where required by law:

• KYC & Identity Verification Providers: Specialist third-party services used to verify identity documents and conduct age checks.
• Payment Processors: Malaysian payment gateway and e-wallet operators required to execute your financial transactions (including FPX network participants such as Maybank, CIMB, Public Bank, and Hong Leong).
• Anti-Fraud & Risk Analytics Providers: Services used to score transactions and account activity for fraud and money laundering risk.
• IT Infrastructure & Hosting Providers: Cloud infrastructure and server hosting providers that process data on our behalf under data processing agreements that bind them to equivalent data protection standards.
• Customer Support Tools: Live chat and ticketing platforms used to manage Member communications.

swb77 may disclose personal data to law enforcement agencies, regulatory bodies, gaming licensing authorities, or courts when required to do so by law, by court order, or where such disclosure is necessary to protect the rights, property, or safety of swb77, its Members, or the public.

In the event of a merger, acquisition, restructuring, or sale of all or part of swb77's business, personal data held by swb77 may be transferred to the relevant successor entity, subject to equivalent data protection commitments.

swb77 uses cookies and similar tracking technologies (such as web beacons and local storage objects) to operate the Platform, improve performance, and provide a personalised experience. By using the Platform, you consent to our use of cookies in accordance with this Policy.

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies and security tokens. The Platform cannot operate without these.
• Functional Cookies: Remember your preferences, such as language settings and login state, to provide a more consistent experience across sessions.
• Analytical Cookies: Allow us to understand how Members interact with the Platform — which pages are visited, which games are played, and how long sessions last. Data is processed in aggregated or pseudonymised form.
• Session Integrity Cookies: Used to detect and prevent fraudulent or anomalous login attempts, protecting your Account security.

You may control cookie settings through your browser's privacy settings. Please note that disabling strictly necessary cookies will prevent the Platform from functioning correctly. Disabling functional cookies may result in a degraded user experience.

swb77 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal, licensing, and compliance obligations. The following retention principles apply:

• Active Account Data: Retained for the duration of the Account relationship and for a period of up to five (5) years following Account closure, in compliance with international gaming licence anti-money laundering requirements.
• KYC Documentation: Retained for a minimum of five (5) years following the end of the customer relationship, or such longer period as may be required under applicable licensing conditions.
• Financial Transaction Records: Retained for five (5) years following the transaction date to satisfy audit and compliance requirements.
• Support Communications: Retained for three (3) years following the closure of the support interaction, unless the communication is relevant to an ongoing dispute or compliance matter.
• Analytical Data: Anonymised or aggregated analytical data may be retained indefinitely as it no longer constitutes personal data.

Following the expiry of the applicable retention period, personal data will be securely deleted or anonymised.

swb77 implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, alteration, disclosure, or destruction. Our security measures include, but are not limited to:

• Transport Layer Security: All data transmitted between your device and the swb77 Platform is encrypted using industry-standard 256-bit SSL/TLS protocols.
• Data Encryption at Rest: Sensitive personal data, including KYC documents and financial records, is encrypted when stored on our servers.
• Access Controls: Personal data is accessible only to swb77 personnel and authorised Data Processors who require it to perform their specific functions. Access is governed by the principle of least privilege.
• Security Monitoring: Our infrastructure is subject to continuous monitoring for anomalous activity, intrusion attempts, and data breach indicators.
• Incident Response: swb77 maintains a data breach response procedure. In the event of a breach that is likely to result in risk to your rights, we will notify affected individuals and relevant authorities as required.

While swb77 takes all reasonable steps to protect your data, no internet transmission or electronic storage system can be guaranteed as completely secure. You also play an important role in maintaining Account security by keeping your login credentials confidential.

Subject to applicable law and the conditions set out in this Policy, you have the following rights in respect of your personal data held by swb77. To exercise any of the rights listed below, please contact us at [email protected]. We will endeavour to respond to all verified requests within 30 days.

Please note that certain rights are subject to limitations. For example, the right to erasure does not apply where swb77 is legally required to retain your data under its licensing obligations. We will explain any applicable limitations when responding to your request.

If you are a parent or guardian and believe that a minor in your care has registered on swb77, please contact our support team immediately at [email protected]. We treat all such reports as urgent and will act promptly.

swb77 operates under an international gaming licence and may process or store personal data on servers located outside of Malaysia. Where personal data is transferred to countries that may not have equivalent data protection laws to those in your jurisdiction, swb77 takes steps to ensure that appropriate safeguards are in place, including contractual data processing agreements with our Data Processors that impose obligations consistent with internationally recognised data protection standards.

By registering an Account and using the Platform, you acknowledge and consent to the transfer of your personal data to countries outside Malaysia as described in this Policy.

The swb77 Platform integrates with certain third-party services, including payment gateways, KYC providers, and game studio platforms. While we ensure that our Data Processors are bound by appropriate contractual data protection obligations, swb77 does not control and is not responsible for the privacy practices of third-party services.

swb77 does not include external links to third-party websites on the Platform. However, if you independently navigate to third-party websites, their privacy policies — not this one — govern the collection and use of your data on those platforms.

swb77 reserves the right to update or amend this Privacy Policy at any time. When changes are made, we will update the "Last Updated" date at the top of this document. Where changes are material, we will endeavour to notify registered Members via email or a prominent notice on the Platform prior to the changes taking effect.

Your continued use of the Platform following publication of the revised Privacy Policy constitutes your acceptance of the updated terms. If you disagree with any changes, you should cease using the Platform and request Account closure.

If you have any questions about this Privacy Policy, wish to exercise any of your data subject rights, or have a concern about how swb77 handles your personal data, please contact our Data Protection team using the details below. We will acknowledge all enquiries within 48 hours and aim to resolve substantive matters within 30 days.