5bnw Privacy Policy

This Privacy Policy ("Policy") describes the practices of 5bnw ("5bnw," "we," "us," "our") regarding the collection, use, storage, and disclosure of personal information obtained from individuals ("you," "Player," "User") who access or use the online gaming platform located at 5bnw.app and any associated services, mobile interfaces, or communications channels operated by 5bnw.

5bnw operates in compliance with applicable Philippine data privacy law, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as the regulatory requirements of the Philippine Amusement and Gaming Corporation (PAGCOR) with respect to the collection and handling of player data in the context of online gaming operations.

This Policy applies to personal data collected from players, visitors to the 5bnw website, and persons who contact 5bnw through support channels. It does not apply to data collected by third-party websites or applications that may be linked from the 5bnw platform.

For the purposes of the Data Privacy Act of 2012 and this Policy, 5bnw is the personal information controller responsible for the personal data collected through 5bnw.app. 5bnw determines the purposes and means by which personal data is processed in connection with the online gaming services offered on the platform.

5bnw has designated a Data Protection Officer (DPO) responsible for overseeing data protection practices and serving as the primary point of contact for data privacy matters. Contact details for the DPO are provided in Section 15 of this Policy.

Where 5bnw engages third-party service providers to process personal data on its behalf — for example, payment processors and identity verification providers — those parties act as personal information processors under instruction from 5bnw, and their processing activities are governed by data processing agreements consistent with applicable Philippine privacy law.

5bnw collects only the personal data necessary to operate the platform, comply with legal obligations, and provide the services that players expect. The following table summarises the categories of personal data collected:

5bnw does not intentionally collect sensitive personal information — such as biometric data, health records, or political opinions — except where identity verification processes require the submission of documents that may incidentally contain such information, in which case only the information relevant to identity verification is processed.

5bnw collects personal data through the following channels and interactions:

• Direct Registration: When you create a 5bnw account, you provide identity and contact information directly through the registration form.
• KYC Submission: When you submit identity documents to fulfil verification requirements, those documents and the data contained within them are processed by 5bnw and any authorised identity verification service provider engaged for that purpose.
• Payment Transactions: When you make a deposit or request a withdrawal, transaction data is shared between 5bnw and the relevant payment provider (GCash, PayMaya, BDO, BPI, Metrobank, or USDT network).
• Platform Usage: Technical data and gaming activity data are collected automatically as you use the 5bnw platform, through server logs, session tracking, and game system records.
• Communications: When you contact the 5bnw support team via live chat or email, the content of those communications is recorded for service and compliance purposes.
• Cookies and Tracking Technologies: Data is collected through cookies and similar tracking technologies as described in Section 8 of this Policy.

5bnw processes personal data on the following legal grounds, as applicable under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform the contract between 5bnw and the player — specifically, to operate the player's account, process transactions, and deliver the gaming services agreed to at registration.
• Legal Obligation: Processing is required to comply with 5bnw's legal obligations, including PAGCOR regulatory requirements, anti-money laundering laws, Know Your Customer obligations, and other applicable Philippine law.
• Legitimate Interests: Processing is carried out in pursuit of 5bnw's legitimate interests, which include fraud prevention, platform security, responsible gaming monitoring, and the prevention of money laundering, where those interests are not overridden by the rights and interests of the player.
• Consent: Where processing is based on consent — specifically for marketing communications — that consent is obtained explicitly and may be withdrawn by the player at any time without affecting their account access.

5bnw uses the personal data described in Section 3 for the following specific purposes:

• Account Administration: Creating and maintaining your 5bnw account, verifying your identity and age, managing your account settings, and communicating with you about account-related matters.
• Transaction Processing: Processing deposits and withdrawals, reconciling payment records, and maintaining accurate financial records for audit and regulatory purposes.
• Regulatory Compliance: Fulfilling PAGCOR reporting obligations, maintaining records required under anti-money laundering law, responding to lawful requests from Philippine regulatory authorities and law enforcement, and meeting KYC requirements.
• Fraud and Security: Detecting, investigating, and preventing fraudulent transactions, account takeovers, money laundering, bonus abuse, multi-accounting, and other prohibited conduct as described in the 5bnw Terms & Conditions.
• Responsible Gaming: Monitoring gaming activity to identify patterns that may indicate problem gambling behaviour and, where appropriate, triggering responsible gaming interventions in accordance with PAGCOR guidelines.
• Customer Support: Responding to your enquiries, resolving disputes, and maintaining records of support interactions for quality assurance and dispute resolution purposes.
• Platform Improvement: Analysing aggregated and anonymised usage data to improve the platform's features, performance, and user experience for Philippine players.
• Marketing (Consent-Based): Sending promotional offers, bonus notifications, and marketing communications via email or SMS where you have explicitly opted in to receive such communications. Each marketing message includes a clear opt-out mechanism.

5bnw does not sell, rent, or trade personal data to any third party for commercial purposes. Personal data is shared only in the following limited circumstances:

• Payment Processors: Transaction data is shared with licensed payment service providers (including GCash, PayMaya, BDO, BPI, and Metrobank) to the extent necessary to process deposits and withdrawals. These providers are subject to their own privacy policies and applicable Philippine financial regulations.
• Identity Verification Partners: KYC documents and identity data may be shared with regulated identity verification service providers engaged by 5bnw to carry out verification checks. These providers process data solely for verification purposes under contractual data processing agreements.
• PAGCOR and Regulatory Authorities: 5bnw is obligated to share player data with PAGCOR and other Philippine regulatory authorities where required by applicable law, including for regulatory audits, licence compliance reviews, and investigations into suspected violations of gaming regulations.
• Law Enforcement: 5bnw may disclose personal data to Philippine law enforcement agencies where required by a lawful court order, warrant, or other binding legal process.
• Anti-Money Laundering Reporting: Where 5bnw identifies transactions that trigger mandatory reporting obligations under the Anti-Money Laundering Act (AMLA) and its amendments, the relevant transaction data and player information will be reported to the Anti-Money Laundering Council (AMLC) as required.
• Group Companies: Where 5bnw operates within a corporate group, personal data may be shared with affiliated entities within that group for internal administrative purposes, subject to equivalent data protection standards.

5bnw uses cookies and similar tracking technologies (including local storage objects and session tokens) on the platform to support essential functionality, security operations, and — where consented to — analytics and performance monitoring.

The following categories of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for the platform to function and cannot be disabled. They include session cookies that maintain your login state and security tokens that protect your account from cross-site request forgery.
• Functional Cookies: These cookies remember your preferences, such as language settings and display options, to provide a more personalised experience on the 5bnw platform.
• Analytics Cookies: Where you have consented, 5bnw may use analytics cookies to collect aggregated and anonymised data about how the platform is used. This data is used to improve platform performance and the player experience for Filipino users.

You may manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies may affect the functionality of the 5bnw platform. Detailed cookie settings are available in the Cookie Preference Centre accessible from the platform footer.

5bnw retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention periods apply as a general guide:

• Account Data: Retained for the duration of the active account and for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and AMLA obligations.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction in compliance with anti-money laundering regulations.
• KYC Documents: Retained for the period required by applicable KYC and AML regulations, which is generally five years from the date of verification or from the end of the business relationship, whichever is later.
• Support Communications: Retained for up to three (3) years from the date of the communication for dispute resolution and service quality purposes.
• Marketing Data: Retained until you withdraw consent for marketing communications, after which marketing-specific data is suppressed or deleted.
• Technical Logs: Server and access logs are retained for up to twelve (12) months for security monitoring and fraud investigation purposes.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be attributed to an identifiable individual.

5bnw implements a range of technical and organisational security measures designed to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Encryption in Transit: All data exchanged between your device and the 5bnw platform is encrypted using 256-bit SSL/TLS encryption. This applies to all account interactions, payment transactions, and KYC document submissions.
• Encryption at Rest: Sensitive personal data stored on 5bnw systems — including identity documents and payment information — is encrypted at rest using industry-standard encryption protocols.
• Access Controls: Access to personal data held by 5bnw is restricted on a strict need-to-know basis. Staff with access to player data are subject to confidentiality obligations and receive regular data protection training.
• Two-Factor Authentication: 5bnw's internal systems utilise multi-factor authentication for staff accessing data management systems. 5bnw also strongly recommends that players enable 2FA on their own accounts to protect their personal data.
• Security Monitoring: 5bnw maintains continuous monitoring of platform systems to detect and respond to unusual access patterns, potential breaches, and other security events.
• Vulnerability Management: Regular security assessments and penetration tests are conducted to identify and remediate potential vulnerabilities in the platform infrastructure.

Under the Data Privacy Act of 2012 and applicable implementing regulations, you have the following rights with respect to the personal data that 5bnw holds about you:

To exercise any of the above rights, please contact the 5bnw Data Protection Officer using the contact details provided in Section 15. 5bnw will respond to all verified data subject requests within thirty (30) calendar days of receipt. In complex or high-volume periods, an extension of up to a further thirty days may apply, and you will be notified of any extension within the initial thirty-day period.

Please note that certain rights are subject to exceptions. For example, 5bnw cannot delete account or transaction data that it is required to retain under PAGCOR regulations, the AMLA, or other applicable Philippine law. In such cases, 5bnw will inform you of the reason why the request cannot be fully fulfilled.

If 5bnw becomes aware that personal data has been submitted by an individual under 21 years of age, that data will be deleted promptly and the associated account will be terminated. Parents or guardians who believe that a minor has submitted personal data to 5bnw are encouraged to contact the support team immediately so that the matter can be investigated and resolved without delay.

Age verification is conducted as part of the registration and KYC processes to minimise the risk of underage access to the platform.

The 5bnw platform may, from time to time, contain references to or integrations with third-party services — including payment providers such as GCash and PayMaya — whose privacy practices are governed by their own privacy policies and not by this Policy.

5bnw is not responsible for the privacy practices, data handling, or content of third-party services. When your use of the platform involves interaction with a third-party service — for example, when you authenticate a GCash payment within the GCash application — you are subject to that service's own terms and privacy policy from the point of that interaction.

5bnw recommends that players review the privacy policies of any third-party services they interact with in connection with their use of the 5bnw platform.

5bnw reserves the right to update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or regulatory requirements. The updated Policy will be posted on this page with a revised effective date.

For material changes — those that significantly affect how your personal data is processed or that reduce your rights — 5bnw will provide at least fourteen (14) days' advance notice via email to your registered address or via a prominent in-platform notification before the changes take effect.

Your continued use of the 5bnw platform after the effective date of any revision constitutes your acceptance of the updated Policy. If you do not accept the changes, you may close your account by contacting the support team, and any outstanding balance will be returned to your verified payment account.

The most current version of this Policy is always available at 5bnw.app/privacy-policy. 5bnw recommends bookmarking this page and reviewing it periodically.

For all data privacy enquiries, data subject access requests, or complaints related to this Policy or 5bnw's handling of your personal data, please contact the 5bnw Data Protection Officer through the following channels:

• Email (DPO): [email protected] — please include "Data Privacy Request" in the subject line so that your message is directed to the DPO team promptly.
• Live Chat: Available 24 hours a day, 7 days a week, including Philippine public holidays, directly through the 5bnw platform. For privacy requests submitted via live chat, an agent will direct your enquiry to the DPO team and provide a reference number.
• Service Region: 5bnw serves players across Metro Manila, Cebu, Davao, Quezon City, Makati, and all regions of the Philippines.

If you are unsatisfied with 5bnw's response to your data privacy enquiry or believe your rights under the Data Privacy Act of 2012 have been violated, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, the independent regulatory body responsible for enforcing the Data Privacy Act.