Our Commitment: swip9 is committed to protecting the privacy of every user. We process personal data lawfully, fairly, and transparently in accordance with internationally recognised data protection principles. This Policy applies to all users of the swip9 platform, including visitors who have not yet registered an account.

1. Definitions

For the purposes of this Privacy Policy, the following definitions apply:

  • "Personal Data" — any information that identifies or could reasonably identify a living individual, including name, email address, date of birth, device identifiers, and IP addresses.
  • "Processing" — any operation performed on Personal Data, including collection, storage, retrieval, use, disclosure, and deletion.
  • "Data Subject" — the identified or identifiable natural person to whom Personal Data relates; in most cases, this means you, the User.
  • "Data Controller" — the entity that determines the purposes and means of processing Personal Data. For users of swip9, the Data Controller is the swip9 operating entity.
  • "Data Processor" — any third party that processes Personal Data on behalf of and under the instruction of the Data Controller.
  • "Sensitive Data" — a subset of Personal Data that carries heightened risk, including financial account details, identity document numbers, and biometric data used for identity verification.
  • "Cookie" — a small text file placed on your device by a website to store information about your preferences or activity.
  • "Platform" — the swip9 website at https://swip9.cam and all associated mobile-optimised pages and services.

2. Data Controller

The Data Controller responsible for your Personal Data in connection with the swip9 Platform is the internationally incorporated legal entity operating swip9 under its gaming licence. All data protection inquiries, subject access requests, and complaints should be directed to our Data Protection contact using the details in Section 15 of this Policy.

Where swip9 engages third-party service providers to process Personal Data on its behalf — for example, payment processors, KYC verification providers, and customer support platforms — those providers act as Data Processors. swip9 ensures that each Data Processor operates under a written data processing agreement that requires them to maintain confidentiality, implement appropriate security measures, and process data only on swip9's documented instructions.

3. Personal Data We Collect

The table below sets out the categories of Personal Data swip9 collects, organised by the stage at which the data is typically gathered.

Category Specific Data Points When Collected
Registration Data Full legal name, date of birth, email address, mobile phone number, username, password (hashed) Account registration
Identity Verification (KYC) Government-issued ID number (KTP, SIM, Passport), ID document images, selfie photograph, date of birth confirmation Before first withdrawal; random spot checks
Financial Data Bank account name and number (BCA, BRI, BNI, Mandiri, etc.), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja), transaction amounts, transaction timestamps Deposit and withdrawal requests
Gaming Activity Bet history, game session logs, wager amounts, win/loss records, bonus usage, responsible gaming limit settings Ongoing platform usage
Technical Data IP address, device type, operating system, browser type and version, screen resolution, time zone setting Each platform visit
Usage Data Pages visited, features used, click-through paths, session duration, referral source URL Each platform visit
Communications Data Support chat transcripts, email correspondence, call recordings (where applicable), complaint records When you contact support
Marketing Preferences Opt-in or opt-out status for promotional emails, SMS, and WhatsApp notifications Registration and account settings updates
Note on Sensitive Data: Identity document numbers, financial account details, and KYC photographs are classified as Sensitive Data. They are stored with additional encryption layers and access controls, and are accessible only to authorised compliance and fraud-prevention personnel.

4. How We Collect Personal Data

4.1 Directly from You

The majority of Personal Data swip9 holds about you is provided directly by you during account registration, KYC submission, deposit and withdrawal requests, and communications with our support team. You are under no legal obligation to provide this data; however, certain data (registration details, KYC documents, payment information) is necessary for us to provide the Platform's core services, and we cannot deliver those services without it.

4.2 Automatically

When you visit or interact with the Platform, we automatically collect Technical Data and Usage Data through server logs, cookies, web beacons, and similar tracking technologies. This data collection is necessary to operate the Platform securely, detect fraud, and improve user experience. Please see Section 7 for detailed information on cookies and how to manage them.

4.3 From Third Parties

swip9 may receive Personal Data about you from the following third-party sources:

  • Payment Processors: Transaction confirmation data, payment instrument validation results, and fraud-scoring signals from BCA, BRI, BNI, Mandiri, and e-wallet providers.
  • KYC Verification Providers: Identity document authentication results, liveness check results, and sanctions/politically exposed person (PEP) screening outcomes from our third-party identity verification partners.
  • Analytics Providers: Aggregated behavioural analytics from platform analytics tools to help us understand how users interact with the site.
  • Affiliate Partners: Referral tracking identifiers indicating which marketing channel introduced you to swip9, but no additional personal data beyond a pseudonymous referral code.

5. Purposes & Legal Bases for Processing

swip9 processes your Personal Data only where we have a lawful basis to do so. The table below sets out the primary purposes for which we process your data and the corresponding legal basis under internationally recognised data protection principles.

Purpose Data Categories Used Legal Basis
Creating and managing your account Registration Data Performance of contract
Processing deposits and withdrawals Financial Data, KYC Data Performance of contract
Identity verification and fraud prevention KYC Data, Technical Data Legitimate interest; legal obligation
Anti-money laundering (AML) compliance Financial Data, KYC Data, Gaming Activity Legal obligation
Responsible gaming monitoring Gaming Activity, Registration Data Legitimate interest; legal obligation
Customer support and complaint handling Communications Data, Registration Data Performance of contract; legitimate interest
Sending promotional communications Registration Data, Marketing Preferences Consent
Platform security and abuse prevention Technical Data, Usage Data, Gaming Activity Legitimate interest
Platform improvement and analytics Usage Data, Technical Data Legitimate interest
Complying with legal and regulatory obligations All categories as required Legal obligation
Withdrawing Consent: Where processing is based on your consent — principally for marketing communications — you may withdraw that consent at any time by updating your notification preferences in your Account settings or by contacting support at [email protected]. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

6. Sharing Your Personal Data

6.1 When We Share

swip9 does not sell, rent, or trade your Personal Data to third parties for their own marketing purposes. We share Personal Data only in the circumstances set out below, and only to the extent necessary for the stated purpose.

6.2 Service Providers and Data Processors

We engage carefully selected third-party service providers to assist in operating the Platform. These providers act as Data Processors and are contractually bound to process your data only on our instructions and to maintain appropriate security standards. Categories of service providers include:

  • Payment processors — BCA, BRI, BNI, Mandiri, CIMB Niaga, and e-wallet gateways (OVO, DANA, GoPay, ShopeePay, LinkAja) to facilitate deposits and withdrawals.
  • Identity verification providers — third-party KYC platforms that authenticate government-issued documents and conduct liveness checks.
  • Game content providers — studios such as Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, and Spribe receive pseudonymised session tokens necessary to deliver their games; they do not receive your full identity data.
  • Cloud infrastructure providers — hosting, database, and content delivery network (CDN) services that store and transmit Platform data.
  • Customer support platforms — live chat and ticketing systems used by our 24/7 support team.
  • Analytics and fraud-prevention tools — platforms that analyse usage patterns and flag potentially fraudulent activity.

6.3 Legal and Regulatory Disclosures

swip9 may disclose your Personal Data to competent authorities, regulators, or law enforcement agencies where required to do so by applicable law, court order, or the rules of our gaming licence. This includes disclosures required under anti-money laundering (AML) regulations, counter-terrorism financing obligations, and sanctions compliance requirements. We will notify you of such a disclosure where we are legally permitted to do so.

6.4 Business Transfers

In the event that swip9 undergoes a merger, acquisition, restructuring, or sale of all or substantially all of its assets, your Personal Data may be transferred to the acquiring entity as part of that transaction. We will notify registered users by email prior to any such transfer and ensure the receiving entity is bound by data protection obligations at least equivalent to those in this Policy.

6.5 No Sale of Data

swip9 will never sell your Personal Data to data brokers, advertising networks, or any third party for commercial exploitation. This commitment is unconditional and applies regardless of any change in ownership or corporate structure.

7. Cookies & Tracking Technologies

7.1 What We Use

swip9 uses cookies and similar tracking technologies — including web beacons, pixel tags, and local storage objects — to operate the Platform effectively, personalise your experience, and measure the performance of our services.

7.2 Types of Cookies

Cookie Type Purpose Can Be Disabled?
Strictly Necessary Session management, authentication, security (CSRF protection), load balancing No — essential to platform operation
Functional Remembering your language preferences, responsible gaming settings, last visited game category Yes — disabling may reduce personalisation
Analytics Measuring page views, session duration, and navigation paths to improve the platform Yes — opt out via browser settings
Marketing / Affiliate Tracking Recording referral source for affiliate commission attribution; retargeting (if applicable) Yes — opt out via browser settings

7.3 Managing Cookies

You can control and delete cookies through your browser settings. Most modern browsers allow you to refuse all or certain categories of cookies, delete existing cookies, and receive alerts when new cookies are set. Please note that disabling strictly necessary cookies will prevent you from logging in and using the Platform. For guidance on managing cookies in your specific browser, refer to the browser's official help documentation.

8. Data Retention

swip9 retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following retention periods apply as a general guide:

  • Account and Registration Data: Retained for the lifetime of your account, plus a minimum of 5 years after account closure, in accordance with AML record-keeping obligations.
  • KYC and Identity Documents: Retained for a minimum of 5 years from the date of verification, or longer if required by our licensing authority or applicable law.
  • Financial Transaction Records: Retained for a minimum of 5 years from the date of each transaction.
  • Gaming Activity Logs: Retained for 3 years from the date of each session, or longer where required for dispute resolution or regulatory audit.
  • Customer Support Communications: Retained for 3 years from the date of the interaction, or until a related dispute is resolved.
  • Marketing Preference Records: Retained for 2 years from the date of your last interaction with a marketing communication, or until you withdraw consent.
  • Technical and Usage Data (server logs): Retained for 12 months from the date of collection.

At the end of the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be linked to you as an individual. Anonymised or aggregated data (which cannot identify you) may be retained indefinitely for statistical and research purposes.

9. Security Measures

swip9 implements a layered security framework to protect your Personal Data against unauthorised access, disclosure, alteration, and destruction. Our security measures include, but are not limited to:

  • 256-bit SSL/TLS Encryption: All data transmitted between your device and the swip9 Platform is encrypted using industry-standard Transport Layer Security (TLS 1.2 or higher).
  • Data Encryption at Rest: Sensitive Data categories — including KYC documents and financial account details — are encrypted at rest using AES-256 encryption.
  • Access Controls: Personal Data is accessible only to swip9 personnel and authorised processors who require it for their specific role. Role-based access control (RBAC) is enforced across all internal systems.
  • Multi-Factor Authentication (MFA): All internal administrative systems require MFA. Users are encouraged to enable two-factor authentication (2FA) on their swip9 accounts.
  • Regular Security Audits: swip9 conducts periodic penetration testing and vulnerability assessments of its Platform infrastructure.
  • Incident Response Plan: swip9 maintains a documented data breach response plan. In the event of a breach that is likely to result in risk to your rights and freedoms, we will notify affected users and relevant authorities within the timeframes required by applicable law.
Your Responsibility: While swip9 takes all reasonable technical and organisational measures to protect your data, no transmission over the internet is entirely risk-free. You are responsible for keeping your account credentials confidential and for logging out of the Platform after each session, particularly when using a shared device.

10. International Data Transfers

swip9 operates on an international basis and engages service providers located in multiple jurisdictions. Your Personal Data may therefore be transferred to and processed in countries outside Indonesia. Some of these countries may not have data protection laws equivalent to those that protect you in Indonesia.

Where such transfers occur, swip9 takes appropriate steps to ensure that your data remains protected to the standard described in this Policy. These steps include entering into standard contractual clauses with Data Processors, conducting transfer impact assessments for high-risk jurisdictions, and requiring contractual data protection obligations from all international service providers.

By using the Platform and agreeing to this Policy, you acknowledge that your Personal Data may be transferred internationally as described in this section.

11. Your Rights

As a Data Subject, you hold the following rights in relation to your Personal Data held by swip9. These rights are not absolute and are subject to applicable exceptions; however, swip9 will always respond to your request within a reasonable timeframe and explain any limitations that apply.

Right of Access Right to Rectification Right to Erasure Right to Restrict Processing Right to Data Portability Right to Object Right to Withdraw Consent

11.1 Right of Access

You have the right to request a copy of the Personal Data swip9 holds about you, along with information about how it is being processed. We will provide this information free of charge within 30 days of receiving a valid request.

11.2 Right to Rectification

If any Personal Data we hold about you is inaccurate or incomplete, you have the right to request that we correct it. You can update many data points directly through your Account settings; for data that cannot be self-amended (such as your registered name or date of birth), contact support with supporting documentation.

11.3 Right to Erasure

You may request that we delete your Personal Data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where you object to processing based on legitimate interest and we have no overriding grounds to continue. Please note that erasure requests may be limited where retention is required by law (e.g., AML record-keeping obligations).

11.4 Right to Data Portability

Where processing is based on your consent or the performance of a contract, and is carried out by automated means, you have the right to receive a copy of your Personal Data in a structured, commonly used, machine-readable format (such as CSV or JSON), and to transmit that data to another service provider.

11.5 Submitting a Rights Request

To exercise any of the rights listed above, please contact our Data Protection team at [email protected] with the subject line "Data Rights Request". We will verify your identity before processing the request and will respond within 30 days. Where a request is complex or we have received a high volume of requests, we may extend the response period by a further 60 days, with prior notice to you.

12. Minors

The swip9 Platform is strictly restricted to individuals who are 21 years of age or older. We do not knowingly collect Personal Data from anyone under the age of 21. During account registration, users must confirm their date of birth, and KYC verification is conducted before any withdrawal is processed.

If swip9 becomes aware that Personal Data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the relevant account. If you are a parent or guardian and believe that your child has registered on the Platform, please contact us immediately at [email protected] so that we can investigate and take appropriate action without delay.

13. Third-Party Services

The Platform may integrate third-party game content, payment widgets, and support tools that are operated independently of swip9. These third-party services have their own privacy policies and data practices, for which swip9 is not responsible. We encourage you to review the privacy policies of any third-party service providers whose interfaces you interact with while using the Platform.

In particular, the following categories of third-party services may process elements of your Personal Data under their own privacy frameworks:

  • Game studios (Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, Pocket Games Soft) — game session data processed within their secure game servers.
  • Payment providers (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay) — payment transaction data processed on their own regulated infrastructure.
  • Live chat and helpdesk platforms — conversation logs processed within the support vendor's secure environment.

swip9 carefully vets all third-party integrations and requires contractual data protection commitments from all partners. However, once you interact directly with a third-party interface, you are also subject to that party's own terms and privacy notices.

14. Policy Amendments

swip9 reviews this Privacy Policy periodically — at minimum once per calendar year — and updates it whenever our data processing practices change materially or when applicable laws require it. When we make significant changes, we will notify registered users by email at least 7 days before the updated Policy takes effect, and display a prominent notice on the Platform homepage for at least 14 days.

The "Last Updated" date at the top of this page reflects when the most recent revision was made. Your continued use of the Platform after the effective date of any revision constitutes your acknowledgement of the updated Policy. If you disagree with any amendment, you may exercise your right to close your account and request erasure of your Personal Data as described in Section 11.

15. Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise your data rights, or want to raise a concern about how swip9 handles your Personal Data, please reach out using the details below:

  • Email: [email protected] (plain text — not a clickable link)
  • Subject Line for Privacy Matters: "Privacy Policy Inquiry" or "Data Rights Request"
  • Response Time: Within 5 business days for general inquiries; within 30 days for formal data rights requests
  • Support Hours: 24 hours a day, 7 days a week
  • Languages: English and Bahasa Indonesia supported

If you are not satisfied with our response to a privacy complaint, you have the right to escalate the matter to our licensing authority's supervisory body or to seek independent legal advice. swip9 is committed to resolving all privacy concerns fairly and in accordance with the principles set out in this Policy.

How swip9 Protects Your Privacy

Six concrete practices that demonstrate our commitment to keeping your personal data safe, transparent, and firmly under your control.

End-to-End Encryption

Every byte of data exchanged between your device and swip9's servers is protected by 256-bit SSL/TLS encryption. Sensitive data stored in our systems — including KYC documents and financial account details — is encrypted at rest using AES-256, the gold standard for data security.

Strict Access Controls

Your Personal Data is accessible only to personnel whose role specifically requires it. Role-based access control (RBAC) is enforced across all internal platforms. Administrative access to production systems requires multi-factor authentication and is fully audited.

Full Data Rights

You hold seven distinct rights over your data — access, rectification, erasure, restriction, portability, objection, and consent withdrawal. swip9 responds to all rights requests within 30 days and provides clear explanations where any limitation applies.

Zero Data Selling

swip9 will never sell, rent, or trade your Personal Data to third parties for their commercial use. This commitment is unconditional. Data is shared only with vetted service providers who process it strictly on our instructions to deliver your gaming experience.

Defined Retention Limits

We do not retain your data indefinitely. Clear retention periods — ranging from 12 months for server logs to 5 years for AML-required records — govern every data category. At the end of each retention window, data is securely deleted or irreversibly anonymised.

Transparent Policy Updates

When this Policy changes in a meaningful way, you will receive advance email notice at least 7 days before the update takes effect — not a silent revision buried in fine print. You always have the option to close your account and request data erasure if you disagree with any change.

Have Questions About Your Privacy?

Our support team is available around the clock to address any concerns about how your data is handled. You can also review our full Terms & Conditions or visit our FAQ for quick answers.

Read the FAQ Terms & Conditions Back to Home