5bnw Privacy Policy

Introduction

This Privacy Policy ("Policy") is issued by 5bnw ("the Company," "we," "us," or "our") and governs the collection, processing, storage, use, and disclosure of personal data relating to players, prospective players, and visitors to the 5bnw platform available at https://5bnw.org (the "Platform").

5bnw is committed to protecting the privacy and personal data of all individuals who interact with our Platform. This Policy is formulated in accordance with and in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the applicable issuances of the National Privacy Commission of the Philippines (NPC).

This Policy describes in plain and accessible terms exactly what personal data 5bnw collects, the purposes for which it is used, how it is safeguarded, with whom it may be shared, how long it is retained, and what rights you have in relation to your data. We have written this Policy to be understood by Filipino players — not to obscure our practices in complex language.

By accessing the 5bnw Platform, registering an account, or using any 5bnw service, you acknowledge that you have read, understood, and consented to the data practices described in this Policy. This Policy should be read alongside the 5bnw Terms & Conditions, which govern the contractual relationship between you and 5bnw.

Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, 5bnw acts as the personal information controller in respect of all personal data collected through the Platform. As the personal information controller, 5bnw determines the purposes and means of processing your personal data.

5bnw has designated a Data Protection Officer (DPO) responsible for overseeing our data protection practices and serving as the primary point of contact for data privacy inquiries and requests. Contact details for the DPO are set out in Section 14 of this Policy.

Personal Data We Collect

5bnw collects personal data that is necessary and proportionate to the purposes described in this Policy. The categories of personal data we collect are as follows:

3.1 Identity and Registration Data

• Full legal name as it appears on your Philippine government-issued identification.
• Date of birth (collected for age verification — you must be 21 or older to use 5bnw).
• Gender (where voluntarily provided).
• Nationality and country of residence.
• Philippine residential address.
• Copies of government-issued identification documents submitted for KYC verification (e.g., passport, driver's license, SSS card, UMID, PhilSys ID).

3.2 Contact Data

• Philippine mobile phone number (used as a primary account identifier and for SMS OTP delivery).
• Email address.

3.3 Financial Data

• GCash account number or registered mobile number used for GCash transactions.
• PayMaya account details used for PayMaya transactions.
• Bank account name, account number, and branch information for BPI, BDO, or Metrobank transfers.
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment methods used.
• Source of funds documentation where required for anti-money laundering compliance.

3.4 Account and Gaming Activity Data

• Login history, including timestamps and device information.
• Game participation history, bet amounts, game outcomes, and session durations.
• Bonus and promotional offer activity, including claims and wagering progress.
• Account settings, preferences, and responsible gaming tool configurations.
• Customer support interaction records, including chat logs and email correspondence.

3.5 Technical and Device Data

• IP address at the time of access.
• Device type, operating system, and browser information.
• Device identifiers and fingerprinting data used for fraud detection and security purposes.
• Geolocation data (at the city or region level, used for regulatory compliance and fraud prevention — not precise GPS location).
• Session cookies and usage analytics data. See Section 8 for full cookie information.

How We Collect Your Data

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

• Direct provision by you: When you register for a 5bnw account, complete your profile, submit KYC verification documents, deposit funds, request withdrawals, contact support, or participate in promotions, you directly provide personal data to 5bnw.
• Automated Platform interaction: When you use the Platform, 5bnw's systems automatically collect technical and behavioral data, including your IP address, device information, session activity, game history, and transaction data. This collection occurs regardless of whether you are actively inputting data.
• Cookies and tracking technologies: The Platform uses cookies and similar tracking technologies to collect session data, recognize returning users, and analyze Platform usage. See Section 8 for full details on our use of cookies.
• Third-party payment providers: When you make a deposit or withdrawal via GCash, PayMaya, or a Philippine bank, 5bnw receives transaction confirmation data from the relevant payment provider, including the transaction reference, amount, and associated payment account identifier.
• Identity verification services: For KYC verification purposes, 5bnw may use third-party identity verification service providers who process your identification documents on our behalf. These providers act as personal information processors under instruction from 5bnw.
• Fraud detection and security systems: 5bnw employs automated fraud detection tools that analyze behavioral patterns, device fingerprints, and transaction data to identify suspicious activity and protect both the Platform and its players.

How We Use Your Personal Data

5bnw uses the personal data it collects only for specific, legitimate, and declared purposes. The following sets out the primary purposes for which your personal data is processed:

• Account creation and management: To register your 5bnw account, verify your identity, manage your account settings, and maintain your account throughout its lifecycle.
• Age and eligibility verification: To confirm that you meet the minimum age requirement of 21 years as mandated by PAGCOR, and that you are not subject to any other eligibility restriction under 5bnw's Terms & Conditions.
• Provision of gaming services: To enable you to participate in games, place bets, receive winnings, and access all features of the 5bnw Platform.
• Payment processing: To facilitate deposits, process withdrawal requests, and maintain accurate financial records of all transactions on your account.
• Regulatory and legal compliance: To comply with applicable Philippine laws and regulations, including anti-money laundering obligations, PAGCOR regulatory requirements, tax reporting obligations, and court or regulatory orders.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other prohibited conduct on the Platform.
• Customer support: To respond to your inquiries, resolve disputes, and provide assistance through 5bnw's live chat and email support channels.
• Responsible gaming: To monitor gaming behavior for indicators of problem gambling, apply self-imposed responsible gaming tools, and comply with responsible gaming obligations under applicable regulations.
• Marketing communications (with consent): To send promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications. You may withdraw this consent at any time.
• Platform improvement and analytics: To analyze usage patterns, improve Platform performance, and develop new features and services. Analytics are conducted on aggregated or anonymized data wherever possible.

Legal Basis for Processing

5bnw processes your personal data on the following legal grounds as recognized under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual necessity: Processing that is necessary to perform the contract between you and 5bnw — including account registration, game access, payment processing, and withdrawal handling — is carried out on this basis.
• Legal obligation: Processing that is required for 5bnw to comply with its legal obligations under Philippine law — including anti-money laundering reporting, PAGCOR compliance, and tax obligations — is carried out on this basis.
• Legitimate interests: Processing carried out for the purposes of fraud prevention, security monitoring, Platform analytics, and responsible gaming monitoring is conducted on the basis of 5bnw's legitimate interests, subject to balancing those interests against your privacy rights.
• Consent: Processing carried out for marketing communications is conducted solely on the basis of your freely given, specific, and informed consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Data Sharing & Disclosure

5bnw does not sell, rent, exchange, or otherwise make your personal data available to third parties for their own marketing or commercial purposes. Personal data is shared with third parties only in the following defined circumstances:

• Payment processors: Sharing of necessary transaction data with GCash, PayMaya, BPI, BDO, and Metrobank to process deposits and withdrawals. These providers receive only the minimum data necessary to complete the relevant transaction.
• Identity verification providers: Sharing of identification documents and personal data with regulated KYC/AML service providers engaged by 5bnw to conduct identity verification on our behalf. These providers act under data processing agreements with 5bnw.
• Game software providers: Limited technical data necessary for game functionality may be shared with 5bnw's licensed game providers. These providers receive only the minimum data required to deliver the game service (e.g., a unique session token — not your personal identity details).
• Regulatory and law enforcement authorities: Disclosure to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, the Bureau of Internal Revenue, or other competent authorities as required by Philippine law or pursuant to a lawful order.
• Fraud prevention networks: Limited sharing with industry fraud prevention databases and security service providers for the purpose of identifying and preventing fraudulent activity.
• Professional advisers: Disclosure to legal counsel, auditors, or other professional advisers engaged by 5bnw in the course of their professional duties, subject to appropriate confidentiality obligations.

All third parties with whom 5bnw shares personal data are required to handle that data in accordance with applicable data protection law and are prohibited from using it for any purpose beyond what is specified in their agreement with 5bnw.

Cookies & Tracking Technologies

The 5bnw Platform uses cookies and similar tracking technologies to operate effectively, improve user experience, and gather analytics. Cookies are small data files placed on your device when you visit a website.

5bnw uses the following categories of cookies:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in during your visit, and security cookies that protect against fraud and cross-site request forgery. These cookies cannot be disabled without impairing Platform functionality.
• Functional cookies: Used to remember your preferences and settings — such as your preferred language, game display settings, and responsible gaming configurations — so you do not need to re-enter them each session.
• Analytics cookies: Used to collect aggregated information about how players use the Platform — which pages are visited most frequently, how long sessions last, and what navigation paths are common. This helps 5bnw improve Platform design and performance. Analytics data is processed in aggregated or anonymized form wherever possible.
• Security and fraud detection cookies: Used to identify device fingerprints, detect suspicious login patterns, and prevent unauthorized account access. These cookies are part of 5bnw's fraud prevention infrastructure.

You may adjust your browser settings to block or delete cookies. However, disabling strictly necessary cookies will impair your ability to access and use the 5bnw Platform normally, including the ability to log in to your account.

Data Security Measures

5bnw implements appropriate technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 5bnw's servers.
• Encryption of sensitive stored data, including personal identification information and financial records.
• Bcrypt hashing of account passwords — passwords are never stored in recoverable plain text form.
• Role-based access controls restricting internal access to personal data to staff members who require it to perform their functions.
• Multi-factor authentication for administrative systems access.
• Regular security vulnerability assessments and penetration testing of the Platform.
• Intrusion detection and monitoring systems operating continuously to identify and respond to security threats.
• Incident response procedures for managing personal data breaches, including NPC notification obligations.

Data Retention

5bnw retains personal data for no longer than is necessary for the purposes for which it was collected, subject to applicable legal retention obligations. The following general retention principles apply:

• Active account data: Personal data associated with an active 5bnw account is retained for the duration of the account's active status plus the applicable post-closure retention period set out below.
• Financial and transaction records: Transaction history and financial records are retained for a minimum of five (5) years following the date of the relevant transaction, in compliance with Philippine anti-money laundering legislation (Republic Act No. 9160, as amended) and applicable PAGCOR requirements.
• KYC identity documents: Identity verification documents submitted by players are retained for a minimum of five (5) years following account closure, as required by anti-money laundering regulations.
• Communications and support records: Customer support interaction records are retained for three (3) years following the date of the interaction, unless required for longer retention in connection with a legal dispute or investigation.
• Analytics data: Anonymized or aggregated analytics data may be retained indefinitely as it no longer constitutes personal data once the anonymization process is complete.
• Marketing consent records: Records of marketing consent and withdrawal of consent are retained for five (5) years to demonstrate compliance with consent requirements.

At the expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized. Where legal proceedings, regulatory investigations, or compliance obligations require extended retention, data will be retained until those proceedings or obligations are concluded.

Your Data Subject Rights

As a data subject under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 5bnw. These rights may be exercised by submitting a written request to 5bnw's Data Protection Officer as described in Section 14.

Children's Privacy

The 5bnw Platform is strictly restricted to individuals who are at least twenty-one (21) years of age, as required by PAGCOR and applicable Philippine gambling regulations. 5bnw does not knowingly collect, process, or retain personal data relating to individuals under the age of 21.

If 5bnw discovers or has reason to believe that an account has been registered by or on behalf of an individual under the age of 21, that account will be immediately terminated, any associated balance will be handled in accordance with 5bnw's Terms & Conditions, and any personal data associated with the account will be deleted as soon as practicable, subject to any mandatory retention requirements under applicable law.

If you have reason to believe that a person under the age of 21 has registered a 5bnw account, please notify our support team immediately at [email protected].

Updates to This Privacy Policy

5bnw may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or Platform services. When material changes are made, 5bnw will provide notice through one or more of the following channels: a prominent notice on the Platform; an email notification to your registered address; or an announcement in the Platform's notification system.

The date of the most recent update is displayed at the top of this Policy. Your continued use of the Platform following notification of any update constitutes your acceptance of the revised Policy. If you do not accept the revised Policy, you must cease use of the Platform and may request account closure in accordance with 5bnw's Terms & Conditions.

We encourage all 5bnw players to review this Policy periodically to remain informed about how 5bnw protects your personal data. Archived versions of this Policy are available upon request to our Data Protection Officer.

Contact & Privacy Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 5bnw, please contact our Data Protection Officer through any of the following channels. All privacy-related inquiries are handled by our DPO and not general support staff.

If you are not satisfied with 5bnw's response to your privacy complaint or believe that 5bnw is in breach of the Data Privacy Act of 2012 or applicable NPC regulations, you have the right to file a complaint with the National Privacy Commission of the Philippines (NPC). The NPC is the independent regulatory authority responsible for administering and implementing the Data Privacy Act in the Philippines.