Privacy Policy

The following terms carry the meanings set out below throughout this Privacy Policy.

• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to name, date of birth, national ID number, residential address, email address, mobile number, IP address, device identifiers, and financial account details.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, erasure, or destruction, whether by automated or manual means.
• "Data Controller" — swip5 and its licensed operating entity, which determines the purposes and means of Processing your Personal Data.
• "Data Processor" — a third party that Processes Personal Data on behalf of swip5 under written contractual obligations, including payment processors and certified game providers.
• "Member" / "You" — any individual who has registered an account on the swip5 platform at https://swip5.net or who accesses it in any capacity.
• "Platform" — the swip5 website at https://swip5.net, including all associated pages, features, and services.
• "KYC" — Know Your Customer; the identity, age, and source-of-funds verification process conducted by swip5 prior to approving withdrawals or in response to risk indicators.
• "Consent" — a freely given, specific, informed, and unambiguous indication by which you signify agreement to the Processing of your Personal Data for a stated purpose.

swip5 acts as the Data Controller for all Personal Data collected through the Platform. As Data Controller, swip5 is responsible for determining why your data is collected and how it is used, and for ensuring that all Processing activities comply with applicable data-protection obligations.

If you have any questions or concerns about how swip5 handles your Personal Data, or if you wish to exercise any of the rights described in Section 10, please contact our Data Protection team at the address listed in Section 14 of this Policy. We are committed to responding to all data-related enquiries within 30 calendar days.

swip5 collects Personal Data through three primary channels: information you provide directly, information generated automatically through your use of the Platform, and information received from authorised third parties such as payment processors and identity verification services.

We do not collect sensitive categories of personal data such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data, except where you voluntarily provide such information in a support context and only to the extent necessary to resolve your query.

swip5 uses your Personal Data strictly for the purposes described below. We do not use your data for any purpose that is incompatible with the reason it was originally collected.

• Account Management: Creating, maintaining, and securing your swip5 Account; processing login requests; enforcing the one-account-per-member rule.
• Service Delivery: Enabling access to casino games, live dealer tables, sports betting markets, esports betting markets, slot tournaments, and all other Platform features.
• Payment Processing: Facilitating IDR deposits and withdrawals via Indonesian banks and e-wallets; reconciling transactions; detecting and preventing payment fraud.
• Identity & Age Verification (KYC): Confirming that Members are at least 21 years of age and are who they claim to be, in compliance with our international licensing obligations.
• Fraud Prevention & Security: Monitoring account activity for signs of fraud, money laundering, bonus abuse, multi-accounting, or other Prohibited Conduct as defined in the Terms & Conditions.
• Legal Compliance: Satisfying record-keeping, reporting, and disclosure obligations under applicable law and our international gaming licence conditions.
• Customer Support: Responding to account queries, technical issues, payment disputes, and responsible gaming requests.
• Responsible Gaming: Administering deposit limits, cooling-off periods, and self-exclusion requests; monitoring for behavioural indicators of problem gambling.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve the Platform's performance, design, and game offerings.
• Marketing Communications: Sending promotional offers, bonus notifications, and tournament announcements to Members who have not opted out. You may withdraw marketing consent at any time via your Account settings.

swip5 processes your Personal Data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing required to fulfil our obligations under the Terms & Conditions, including account management, payment processing, and service delivery.
• Legal Obligation: Processing required to comply with applicable law, including KYC obligations mandated by our international gaming licence, anti-money-laundering requirements, and financial record-keeping rules.
• Legitimate Interests: Processing necessary for our legitimate business interests — such as fraud prevention, platform security, and product improvement — where those interests are not overridden by your fundamental rights and freedoms.
• Consent: Where processing is based on your consent — for example, sending marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

swip5 does not sell your Personal Data to third parties. We share your data only in the following circumstances and only to the extent necessary for the stated purpose:

• Payment Processors: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) receive the minimum financial data required to execute your deposit and withdrawal instructions.
• Game Providers: Certified game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft receive your account identifier and session data to deliver game content and record outcomes. These providers operate under their own independently audited data-protection frameworks.
• Identity Verification Services: Third-party KYC and age-verification providers receive identity documents and demographic data solely for the purpose of completing mandatory verification checks.
• Fraud & Risk Management: Specialist fraud-prevention partners may receive Technical Data and Account Data to support real-time risk scoring and anti-money-laundering screening.
• Legal Authorities: swip5 will disclose Personal Data to law enforcement agencies, regulatory bodies, or courts when required to do so by a lawful order or when necessary to protect the rights, property, or safety of swip5, its members, or the public.
• Corporate Transactions: In the event of a merger, acquisition, or sale of substantially all assets, Member Personal Data may be transferred to the successor entity, subject to equivalent privacy protections. Affected members will be notified in advance.

swip5 uses cookies and similar tracking technologies to operate the Platform effectively and to improve your experience. The following categories of cookies are in use:

• Strictly Necessary Cookies: Essential for core Platform functionality, including session management, login state persistence, and security token verification. These cannot be disabled without affecting your ability to use the Platform.
• Functional Cookies: Store your preferences such as language, game lobby layout, and responsible gaming settings to provide a consistent experience across sessions.
• Analytics Cookies: Collect aggregated, anonymised data about how Members navigate the Platform. This data is used internally to improve page performance and user experience. No individual behavioural profiles are shared with third-party advertisers.
• Security Cookies: Support fraud detection by recording session fingerprints and flagging anomalous login patterns for review.

You can manage non-essential cookie preferences through your browser settings. Note that disabling certain cookies may impair the functionality of some Platform features. swip5 does not use third-party advertising cookies or cross-site tracking pixels.

swip5 maintains a comprehensive information security programme designed to protect your Personal Data against unauthorised access, disclosure, alteration, or destruction. Our security measures include:

• 256-bit TLS 1.3 encryption for all data in transit between your device and our servers.
• AES-256 encryption for sensitive data at rest, including identity documents, bank account references, and payment records.
• Multi-factor authentication options available to all Members and mandatory for all administrative access to Member data.
• Regular third-party penetration testing and vulnerability assessments conducted by independent cybersecurity firms.
• Role-based access controls ensuring that employee access to Personal Data is limited to what is required for their specific job function.
• Real-time intrusion detection and 24/7 security monitoring of all Platform infrastructure.

In the event of a data breach that is likely to result in a risk to the rights and freedoms of affected Members, swip5 will notify impacted individuals without undue delay and in accordance with applicable notification obligations. Notification will be sent to the email address registered on your Account.

While swip5 takes every reasonable precaution to safeguard your data, no internet-based service can guarantee absolute security. You are responsible for maintaining the confidentiality of your own login credentials and for notifying swip5 promptly if you suspect unauthorised access to your Account.

swip5 retains Personal Data for no longer than is necessary to fulfil the purpose for which it was collected, or to comply with applicable legal and regulatory obligations. The following standard retention periods apply:

Upon the expiry of the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be associated with an identifiable individual. Anonymised data may be retained indefinitely for aggregated analytics purposes.

As a Member of swip5, you hold the following rights with respect to your Personal Data. To exercise any of these rights, contact our Data Protection team at [email protected]. We will respond within 30 calendar days of receiving your verified request.

Where Processing is based on your consent, you may withdraw that consent at any time by contacting [email protected] or adjusting your Account settings. Withdrawal of consent does not affect the lawfulness of Processing carried out prior to withdrawal.

Parents and guardians are encouraged to implement content-filtering software on shared devices to prevent minors from accessing online gambling platforms, including swip5. If you have reason to believe that a minor has registered an account on our platform, please notify us immediately at [email protected].

swip5 primarily processes Member data on servers located in secure data centres operating under internationally recognised security and compliance frameworks. In certain circumstances — for example, when engaging certified game providers or KYC verification services — your Personal Data may be transferred to and processed in countries outside Indonesia.

Where such international transfers occur, swip5 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to the protections described in this Policy. These safeguards include contractual data-processing agreements with all third-party Data Processors that impose binding data-protection obligations consistent with internationally accepted standards.

By using the Platform, you acknowledge and consent to the transfer of your Personal Data as described in this section, subject always to the protections outlined in this Policy.

swip5 may update this Privacy Policy periodically to reflect changes in our data-processing practices, new legal or regulatory requirements, or improvements to our services. The "Last updated" date at the top of this page indicates when the most recent revision was made.

Material changes to this Policy — particularly changes that affect how we use your Personal Data or the rights available to you — will be communicated to registered Members via the email address on file at least seven days before they take effect. Continued use of the Platform after the effective date of an amendment constitutes your acceptance of the updated Policy.

We encourage you to review this Policy periodically. The current version will always be accessible at swip5.net/privacy-policy.

If you have any questions about this Privacy Policy, wish to exercise a data-subject right, or want to raise a concern about how swip5 handles your Personal Data, please reach out to our Data Protection team. Our Indonesian-speaking support agents are available 24 hours a day, seven days a week.