5bnw Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how 5bnw ("we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "your," or "data subject") who access or use the 5bnw website, mobile interface, and all associated gaming services (collectively, the "Platform").

5bnw is committed to protecting your privacy and handling your personal data with transparency, integrity, and in full compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and all relevant issuances of the National Privacy Commission ("NPC") of the Philippines.

By accessing the 5bnw Platform, creating an account, or otherwise providing us with your personal information, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, please discontinue use of the Platform immediately.

2 Who We Are

5bnw is an online gaming platform operating in the Philippines and serving Filipino players with a range of gaming products including live dealer games, slots, bingo, color game, and other interactive entertainment services.

For the purposes of the Data Privacy Act of 2012, 5bnw acts as the Personal Information Controller (PIC) in respect of the personal data it collects directly from players and visitors to the Platform. Where 5bnw processes personal data on behalf of a third party (such as a game provider or payment processor), it may act as a Personal Information Processor (PIP) in accordance with the terms of the relevant data processing agreement.

Our designated Data Protection Officer (DPO) can be contacted using the details provided in Section 16 of this Policy. The DPO is responsible for overseeing 5bnw's data protection compliance program and serves as the primary point of contact for data subjects and the NPC.

3 Data We Collect

5bnw collects the following categories of personal data, depending on how you interact with the Platform:

3.1 Identity & Contact Data

• Full legal name as it appears on a government-issued ID
• Date of birth and age verification information
• Residential address (barangay, city/municipality, province)
• Email address and Philippine mobile number
• Government-issued ID type and number (e.g., PhilSys National ID, passport, driver's license, SSS/GSIS ID, PRC ID, voter's ID)
• Selfie or live photo for identity verification purposes

3.2 Financial Data

• Deposit and withdrawal transaction records
• Payment method details (e.g., GCash account name, Maya registered number, BPI/BDO/Metrobank account name — we do not store full bank account numbers or card numbers)
• Transaction amounts, dates, and reference numbers
• Source of funds documentation where required by AML compliance

3.3 Gaming Activity Data

• Game history, bet amounts, win/loss records, and session durations
• Bonus and promotion participation records
• Responsible gaming tool usage (deposit limits, self-exclusion requests, session reminders)

3.4 Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Pages visited, features used, and time spent on the Platform
• Login timestamps and session activity logs
• Cookie identifiers and similar tracking data (see Section 8)

3.5 Communications Data

• Records of your interactions with 5bnw customer support (live chat transcripts, email correspondence)
• Feedback, survey responses, and complaints submitted to 5bnw
• Marketing communication preferences

4 How We Collect Data

5bnw collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance partners; payment confirmation data from payment processors such as GCash, Maya, BPI, BDO, and Metrobank.
• Publicly available sources: In limited circumstances, 5bnw may verify information against publicly available records or government databases as permitted by applicable law.

5 How We Use Your Data

5bnw uses the personal data it collects for the following purposes:

5bnw will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

6 Legal Basis for Processing

Under the Data Privacy Act of 2012, 5bnw processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — including account management, payment processing, and delivery of gaming services.
• Legal obligation: Processing required to comply with applicable laws and regulations, including PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), and NPC regulations.
• Legitimate interests: Processing necessary for 5bnw's legitimate business interests, such as fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7 Sharing Your Data

5bnw does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• KYC and identity verification providers: Third-party services that assist with document verification and age confirmation as required by PAGCOR regulations.
• Payment processors: GCash, Maya, BPI, BDO, Metrobank, UnionBank, and other payment service providers necessary to process your deposits and withdrawals.
• Game content providers: Licensed game studios and live dealer platform providers whose games are accessible through 5bnw. These providers may receive limited gaming session data necessary to deliver their services.
• AML and fraud screening services: Compliance technology providers that assist 5bnw in meeting its obligations under the Anti-Money Laundering Act.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where disclosure is required by law or regulatory direction.
• IT and infrastructure providers: Cloud hosting, data storage, and cybersecurity service providers engaged by 5bnw to operate and secure the Platform, subject to binding data processing agreements.
• Professional advisers: Legal counsel, auditors, and other professional advisers where necessary for the conduct of 5bnw's business, subject to professional confidentiality obligations.

8 Cookies & Tracking Technologies

5bnw uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit a website. We use the following types of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication cookies and security tokens. These cookies cannot be disabled without affecting core Platform functionality.
• Functional cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations.
• Analytics cookies: Help us understand how players use the Platform by collecting aggregated, anonymized usage data. This information is used to improve the Platform experience.
• Marketing cookies: Used to deliver relevant promotional content and measure the effectiveness of our marketing campaigns. These cookies are only placed with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. For strictly necessary cookies, no consent is required as they are essential to the operation of the service.

9 Data Retention

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

• Account and KYC data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR licensing requirements and AML record-keeping obligations under the AMLA.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the AMLA and its implementing rules.
• Gaming activity records: Retained for a minimum of three (3) years from the date of the gaming session.
• Customer support communications: Retained for three (3) years from the date of the last interaction, or longer if the communication relates to an unresolved dispute or legal matter.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of the consent given.
• Technical and usage logs: Retained for up to twelve (12) months, after which they are deleted or anonymized.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with 5bnw's data disposal procedures. Where data cannot be immediately deleted due to technical constraints, it will be isolated from active processing until deletion is possible.

10 Data Security

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

• Encryption in transit: All data transmitted between your device and the 5bnw Platform is encrypted using 256-bit SSL/TLS protocols.
• Encryption at rest: Sensitive personal data stored on 5bnw's servers is encrypted using industry-standard encryption algorithms.
• Access controls: Access to personal data is restricted to authorized 5bnw personnel and service providers on a strict need-to-know basis. All access is logged and audited.
• Two-factor authentication: 5bnw's internal systems require multi-factor authentication for staff accessing personal data.
• Regular security assessments: 5bnw conducts periodic vulnerability assessments and penetration testing of its Platform and infrastructure.
• Staff training: All 5bnw personnel with access to personal data receive regular data privacy and security training.
• Incident response: 5bnw maintains a documented data breach response plan and will notify the NPC and affected data subjects within 72 hours of becoming aware of a breach that poses a risk to data subjects' rights.

While 5bnw takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is 100% secure. You are also responsible for maintaining the security of your own account credentials. See Section 4 of the Terms & Conditions for your account security obligations.

11 Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 5bnw:

• Right to be informed: The right to be notified of how your personal data is being collected and processed, as set out in this Policy.
• Right of access: The right to request a copy of the personal data 5bnw holds about you, along with information about how it is being processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to 5bnw's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer using the details in Section 16. We will respond to all valid data subject requests within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further thirty (30) days, in which case we will notify you of the extension and the reason for it.

12 Children's Privacy

The 5bnw Platform is strictly intended for adults aged 21 years and above, in accordance with PAGCOR regulations governing online gaming in the Philippines. 5bnw does not knowingly collect personal data from individuals under the age of 21.

If we become 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 associated account. Any winnings accrued on an account found to belong to an underage individual will be forfeited.

If you are a parent or guardian and believe that your child has provided personal data to 5bnw, please contact us immediately using the details in Section 16 so that we can take appropriate action.

13 Cross-Border Data Transfers

In the course of operating the 5bnw Platform, your personal data may be transferred to, stored in, or processed in countries other than the Philippines — for example, where our cloud infrastructure providers or game content partners maintain data centers.

Where such cross-border transfers occur, 5bnw ensures that appropriate safeguards are in place to protect your personal data in accordance with the Data Privacy Act of 2012 and NPC regulations on cross-border data flows. These safeguards may include:

• Binding contractual clauses in data processing agreements with overseas recipients that impose data protection standards equivalent to those required under Philippine law.
• Transfers to countries or organizations that have been assessed as providing an adequate level of data protection.
• Other lawful transfer mechanisms recognized by the NPC.

By using the 5bnw Platform, you acknowledge and consent to the transfer of your personal data outside the Philippines where necessary for the provision of our services, subject to the safeguards described above.

14 Third-Party Links

The 5bnw Platform may contain links to third-party websites or services, such as payment provider portals. This Privacy Policy applies solely to the 5bnw Platform and does not cover the privacy practices of any third-party websites or services that you may access through links on our Platform.

5bnw is not responsible for the privacy practices, content, or security of any third-party websites. We encourage you to review the privacy policies of any third-party services you access before providing them with your personal data.

15 Policy Updates

5bnw reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered players via email or a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is always displayed at the top of this page. We encourage you to review this Policy periodically to stay informed of how 5bnw protects your personal data.

Your continued use of the 5bnw Platform after any amendments have been posted and notified constitutes your acceptance of the revised Privacy Policy. If you do not agree to the amended Policy, you must cease using the Platform and may request account closure in accordance with the Terms & Conditions.

16 Contact & Data Protection Officer

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 (DPO) through the following channels:

• Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 through the 5bnw Platform interface

Our DPO will acknowledge receipt of your request within five (5) business days and will endeavor to resolve your concern within thirty (30) calendar days.

If you are not satisfied with our response, or if you believe that 5bnw has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent government body responsible for administering and enforcing the Data Privacy Act of 2012.