5n5nph Privacy Policy — How We Handle Your Personal Data

2. Data Controller

For the purposes of the Philippines Data Privacy Act of 2012, 5n5nph is the personal information controller responsible for your data processed in connection with your use of the platform. This means 5n5nph determines the purposes for which your personal data is collected and the means by which it is processed.

Contact details for the 5n5nph Data Protection Officer (DPO) are provided in Section 14 of this policy. You may contact the DPO directly with any data privacy-related queries, complaints, or requests to exercise your rights.

3. Personal Data We Collect

5n5nph collects personal data in several categories depending on how you interact with the platform. The following table summarises what we collect and why.

5n5nph does not collect sensitive personal information as defined under the Data Privacy Act (such as health information, biometric data, or political opinions) except where expressly required by law or regulation and with your explicit consent.

4. How We Collect Your Data

5n5nph collects personal data through the following means:

• Directly from you: Information you provide when registering a 5n5nph account, completing identity verification, making deposits or withdrawal requests, contacting customer support, participating in promotions, or submitting feedback.
• Automatically through your use of the platform: Technical and usage data collected via server logs, cookies, and similar tracking technologies when you visit the 5n5nph website or use the platform. See Section 10 for details on cookies.
• From payment providers: Transaction confirmation and status data received from GCash, Maya, GrabPay, Philippine banks, and other payment processors when you deposit or withdraw funds at 5n5nph.
• From identity verification services: Where you submit identity documents for KYC verification, data may be processed by third-party identity verification providers operating under data processing agreements with 5n5nph.
• From regulatory authorities: In limited circumstances required by Philippine gaming or anti-money-laundering regulations, 5n5nph may receive or share data with PAGCOR or other relevant Philippine regulatory bodies.

5. How 5n5nph Uses Your Personal Data

5n5nph uses the personal data we collect for the following purposes:

• Account management: Creating and managing your 5n5nph account, verifying your identity, processing login credentials, and maintaining account security.
• Service delivery: Accepting and settling bets, processing GCash and other payment transactions, crediting bonuses and promotional rewards, and providing access to all 5n5nph platform features.
• Customer support: Responding to your enquiries, resolving disputes, investigating complaints, and maintaining records of support interactions for quality and compliance purposes.
• Fraud prevention and security: Detecting suspicious activity, preventing unauthorised access, identifying multiple accounts, and protecting the integrity of the 5n5nph platform and all member accounts.
• Regulatory compliance: Fulfilling obligations under Philippine gaming laws, the Anti-Money Laundering Act (Republic Act No. 9160 as amended), and the Data Privacy Act of 2012, including mandatory reporting and record-keeping requirements.
• Responsible gaming: Monitoring account activity to identify patterns that may indicate problem gambling, making self-exclusion and deposit limit tools available, and flagging accounts for responsible gaming review where warranted.
• Platform improvement: Analysing aggregate usage data to improve the 5n5nph platform's features, performance, and user experience — always in anonymised or aggregated form where possible.
• Marketing communications: Sending promotional offers, new feature announcements, and event notifications — but only to members who have opted in to receive such communications. You can opt out at any time.

6. Legal Basis for Processing

Under the Philippines Data Privacy Act of 2012, 5n5nph processes your personal data on the following legal grounds:

• Contract performance: Processing necessary to fulfil our contractual obligations to you under the 5n5nph Terms and Conditions — including account management, bet settlement, and payment processing.
• Legal obligation: Processing required to comply with Philippine gaming regulations, anti-money-laundering laws, tax obligations, and other applicable legal requirements.
• Legitimate interests: Processing necessary for 5n5nph's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring — where those interests do not override your privacy rights.
• Consent: Processing for marketing communications, optional analytics, and any processing not covered by the above — where we rely on your freely given, specific, informed consent that can be withdrawn at any time.

7. Sharing Your Personal Data

5n5nph does not sell, rent, or trade your personal data. We share it only in the following limited circumstances, and only to the extent necessary for the stated purpose:

• Payment processors: GCash, Maya, GrabPay, Philippine banks, and other payment providers receive the minimal data required to process your deposit or withdrawal transaction. These providers operate under their own privacy policies and data security standards.
• Identity verification providers: Third-party KYC service providers process identity document data to verify your age and identity. All such providers operate under data processing agreements with 5n5nph that require them to protect your data to the same standard as 5n5nph.
• Technology service providers: Cloud hosting, cybersecurity, customer support software, and analytics providers who process data on 5n5nph's behalf under strict data processing agreements. These providers do not have permission to use your data for their own purposes.
• Regulatory and law enforcement authorities: Philippine gaming regulators, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and law enforcement agencies — where disclosure is required by law, court order, or regulatory directive.
• Business transfers: In the event of a merger, acquisition, or sale of the 5n5nph platform, personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this policy. Members will be notified of any such transfer.

8. Data Retention

5n5nph retains your personal data only for as long as is necessary for the purposes described in this policy, or as required by applicable Philippine law and regulation. The following general retention periods apply:

• Account data and transaction records: Retained for a minimum of five (5) years from the date of your last transaction or account closure, as required under Philippine anti-money-laundering regulations.
• Identity verification documents: Retained for the duration of your active 5n5nph membership and for five (5) years following account closure, in line with KYC and AML regulatory requirements.
• Customer support communications: Retained for three (3) years from the date of the interaction, for dispute resolution and compliance purposes.
• Marketing preference data: Retained until you withdraw consent or close your account, after which opt-out records are retained for a further twelve (12) months for compliance evidence purposes.
• Technical and usage logs: Retained for up to twelve (12) months for security monitoring and platform performance analysis, after which they are deleted or irreversibly anonymised.

When retention periods expire, 5n5nph securely deletes or anonymises your personal data in accordance with its data disposal procedures.

9. Security Measures

5n5nph takes the security of your personal data seriously and implements a range of technical and organisational measures to protect it against unauthorised access, disclosure, alteration, or destruction:

• Transport Layer Security (TLS): All data transmitted between your device and the 5n5nph platform is encrypted using industry-standard TLS protocols.
• Encrypted storage: Sensitive personal and financial data stored on 5n5nph systems is encrypted at rest. Payment details such as GCash numbers and bank account identifiers are stored in masked or tokenised form.
• Access controls: Internal access to personal data is restricted on a strict need-to-know basis. 5n5nph staff are granted access only to the data required for their specific role, and all access is logged and audited.
• Regular security audits: 5n5nph conducts periodic security assessments and penetration testing of its platform infrastructure to identify and address vulnerabilities proactively.
• Incident response: 5n5nph maintains a documented data breach response procedure. In the event of a personal data breach that is likely to result in harm to members, 5n5nph will notify affected individuals and the National Privacy Commission in accordance with the Data Privacy Act.

While 5n5nph takes all reasonable steps to protect your data, no internet transmission or electronic storage system is 100% secure. You also have a role to play in protecting your account — please keep your 5n5nph login credentials confidential and report any suspected unauthorised access to our support team immediately.

10. Cookies & Tracking Technologies

The 5n5nph website uses cookies and similar tracking technologies to improve your experience, maintain your session, and analyse platform usage. Cookies are small data files stored on your device when you visit the 5n5nph website.

5n5nph uses the following types of cookies:

• Strictly necessary cookies: Required for the 5n5nph platform to function correctly. These include session cookies that keep you logged in while you navigate the platform. These cannot be disabled without affecting platform functionality.
• Functional cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations. These improve your experience without collecting data for advertising purposes.
• Analytics cookies: Collect anonymised data about how members use the 5n5nph platform — which pages are visited, how long members spend on each section, and where errors occur. This data helps us improve the platform. These are set only with your consent.
• Security cookies: Assist in detecting suspicious login attempts, bot activity, and other security threats to the 5n5nph platform. These are strictly necessary for platform security.

5n5nph does not use advertising or third-party tracking cookies that follow your activity across other websites. You can manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will affect your ability to use the 5n5nph platform.

11. Your Rights Under the Philippines Data Privacy Act

Under Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights in relation to your personal data held by 5n5nph. These rights can be exercised by contacting the 5n5nph Data Protection Officer as described in Section 14.

5n5nph will respond to valid data subject requests within thirty (30) days of receipt. Where a request is complex or involves a large volume of data, we may extend this period by a further thirty (30) days and will notify you accordingly. Identity verification may be required before processing sensitive data access or deletion requests.

12. Minors

The 5n5nph platform is strictly for persons aged 21 years and above. 5n5nph does not knowingly collect personal data from individuals under the age of 21. Account registration requires confirmation of age, and 5n5nph conducts identity verification to enforce this requirement.

If 5n5nph becomes aware that personal data has been collected from a person under the age of 21, the account will be closed immediately, all data associated with the underage registration will be deleted as permitted by law, and any funds held in the account will be dealt with in accordance with applicable regulations.

If you believe a person under 21 has registered on the 5n5nph platform, please contact us immediately at the email address provided in Section 14 so that we can investigate and take appropriate action.

13. Changes to This Privacy Policy

5n5nph may update this Privacy Policy from time to time to reflect changes in how we process personal data, updates to applicable Philippine law, or improvements to our privacy practices. When changes are made, the "Last Updated" date at the top of this page will be revised accordingly.

For significant changes that materially affect how your personal data is used, 5n5nph will notify registered members via email or an in-platform notification before the changes take effect. Your continued use of the 5n5nph platform following notification of any change constitutes your acceptance of the updated Privacy Policy.

14. Contact Us & Data Protection Officer

If you have any questions about this Privacy Policy, want to exercise your data subject rights, or have a concern about how 5n5nph handles your personal data, please contact the 5n5nph Data Protection Officer (DPO):

• Email: support@5n5nph.net (please include "Data Privacy" in the subject line)
• Live Chat: Available 24/7 through the 5n5nph platform when logged in to your account
• Response time: Privacy requests are acknowledged within 3 business days and resolved within 30 days

If you are not satisfied with how 5n5nph has handled your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information about how to file a complaint with the NPC is available on the NPC's official website.

For general account questions, betting queries, and platform support, visit the 5n5nph FAQ page or contact the support team through the live chat on the platform. For platform terms and conditions, see the Terms and Conditions page.