5ph1 Privacy Policy

This Privacy Policy ("Policy") describes how 5ph1 ("5ph1," "we," "us," "our") collects, uses, stores, shares, and protects the personal data of individuals ("you," "your," "Player," "User") who access or use the 5ph1 online gaming platform available at https://5ph1.app and all associated subdomains, mobile interfaces, and applications (collectively, the "Platform").

5ph1 is committed to protecting the privacy and security of your personal data. This Policy is designed to comply with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC") of the Philippines.

By registering an account on 5ph1 or by continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the Platform and contact us to close your account.

5ph1 is the operator of the online gaming platform accessible at https://5ph1.app, serving players in the Philippines. As the operator of the Platform, 5ph1 acts as the Personal Information Controller ("PIC") in respect of the personal data it collects and processes about you, as that term is defined under the Data Privacy Act of 2012.

This means 5ph1 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently in accordance with the DPA and this Policy.

If you have any questions about how 5ph1 handles your personal data, or if you wish to exercise any of your rights under the DPA, please contact our Data Protection Officer ("DPO") using the contact details provided in Section 15 of this Policy.

5ph1 collects personal data from you in the following ways: directly from you when you register or use the Platform, automatically through your use of the Platform, and from third parties such as payment processors and identity verification providers. The categories of personal data we collect include:

3.1 Registration & Identity Data

• Full legal name as it appears on your government-issued Philippine ID
• Date of birth (to verify you are 21 years of age or older)
• Gender
• Nationality and country of residence
• Registered email address
• Philippine mobile number
• Username and encrypted password

3.2 Identity Verification (KYC) Data

• Copies of government-issued Philippine ID (e.g., PhilSys National ID, passport, driver's license, SSS ID, GSIS ID, PRC ID)
• Proof of address documents (e.g., utility bills, bank statements)
• Source of funds documentation where required by anti-money laundering regulations
• Selfie or facial image for biometric identity verification where applicable

3.3 Financial & Transaction Data

• Deposit and withdrawal transaction records
• Payment method details (e.g., GCash mobile number, PayMaya account reference, BPI/BDO/Metrobank account name — we do not store full bank account numbers or card numbers)
• Transaction amounts, dates, and reference numbers
• Bonus and promotional credit history

3.4 Gaming Activity Data

• Game history, wager amounts, and outcomes
• Session duration and frequency of play
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status)
• Bonus usage and wagering progress

3.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser type
• Unique device identifiers
• Log data including access times, pages visited, and error reports

3.6 Communications Data

• Records of your communications with 5ph1 customer support (live chat transcripts, email correspondence)
• Survey responses and feedback you voluntarily provide
• Marketing communication preferences

The following table summarizes the main categories of data collected and their primary purposes:

5ph1 uses the personal data we collect for the following purposes:

4.1 Account Management

To create, maintain, and manage your 5ph1 player account, including verifying your identity, processing your registration, enabling login and authentication, and managing your account settings and preferences.

4.2 Service Delivery

To provide you with access to the games, features, and services available on the 5ph1 Platform, including processing your deposits and withdrawals, crediting bonuses and promotional offers, and maintaining your gaming history.

4.3 Regulatory Compliance

To comply with our legal and regulatory obligations under Philippine law, including KYC and anti-money laundering ("AML") requirements, responsible gaming obligations, and any reporting requirements imposed by PAGCOR or other competent Philippine regulatory authorities.

4.4 Fraud Prevention & Security

To detect, investigate, and prevent fraudulent activity, unauthorized account access, bonus abuse, money laundering, and other prohibited conduct on the Platform. This includes automated monitoring of account activity and transaction patterns.

4.5 Customer Support

To respond to your inquiries, complaints, and support requests, and to maintain records of our communications with you for quality assurance and dispute resolution purposes.

4.6 Responsible Gaming

To monitor your gaming activity for indicators of problem gambling, to enforce responsible gaming limits and self-exclusion requests you have set, and to contact you where we have concerns about your gaming behavior.

4.7 Platform Improvement

To analyze aggregated and anonymized usage data to understand how players use the Platform, identify technical issues, and improve the features, performance, and user experience of 5ph1.

4.8 Marketing Communications

To send you promotional offers, bonus notifications, and news about 5ph1 — but only where you have given your consent to receive such communications. You may opt out of marketing communications at any time by updating your account preferences or contacting our support team.

Under the Data Privacy Act of 2012, 5ph1 processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you — specifically, to operate your 5ph1 account and deliver the gaming services you have requested.
• Legal Obligation: Processing is necessary to comply with our legal and regulatory obligations under Philippine law, including KYC, AML, and responsible gaming requirements.
• Legitimate Interests: Processing is necessary for our legitimate interests in preventing fraud, ensuring platform security, and improving our services, provided these interests are not overridden by your rights and interests.
• Consent: For processing activities that are not covered by the above bases — in particular, marketing communications — we rely on your explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

5ph1 does not sell, rent, or trade your personal data to third parties for their own marketing 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:

6.1 Payment Processors

We share necessary financial data with payment service providers — including GCash, PayMaya, BPI, BDO, and Metrobank — to process your deposits and withdrawals. These providers process your data as independent data controllers subject to their own privacy policies and applicable Philippine financial regulations.

6.2 Identity Verification Providers

We use third-party KYC and identity verification service providers to assist with verifying your identity and age. These providers process your identity documents and biometric data solely for verification purposes and are contractually prohibited from using your data for any other purpose.

6.3 Regulatory Authorities

We may disclose your personal data to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council ("AMLC"), law enforcement agencies, and other competent Philippine government authorities where required by law, court order, or regulatory directive.

6.4 Technology Service Providers

We engage third-party technology providers to support the operation of the Platform, including cloud hosting, data analytics, customer support software, and cybersecurity services. These providers act as data processors on our behalf and are contractually bound to process your data only on our instructions and in accordance with applicable data protection law.

6.5 Game Content Providers

Certain games available on 5ph1 are provided by third-party game studios. These providers may receive limited technical data (such as session tokens and game results) necessary to deliver the game experience. They do not receive your full personal profile.

5ph1 uses cookies and similar tracking technologies on the Platform to enhance your experience, maintain your session, and analyze Platform usage. The following types of cookies are used:

7.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function correctly. They enable core features such as user authentication, session management, and security. These cookies cannot be disabled without significantly impairing your ability to use the Platform.

7.2 Functional Cookies

These cookies remember your preferences and settings — such as your preferred language, display settings, and responsible gaming tool configurations — so you do not have to re-enter them each time you visit.

7.3 Analytics Cookies

These cookies collect anonymized information about how players use the Platform, including which pages are visited most frequently and where errors occur. This data helps us improve the Platform's performance and user experience. Analytics data is aggregated and does not identify individual players.

7.4 Managing Cookies

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. Strictly necessary cookies cannot be disabled through browser settings as they are essential to the Platform's operation.

5ph1 retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The specific retention periods applicable to each category of data are set out in the table in Section 3 of this Policy.

In determining appropriate retention periods, 5ph1 considers the following factors:

• The nature and sensitivity of the personal data
• The purposes for which the data was collected and whether those purposes have been fulfilled
• Legal and regulatory retention obligations, including those imposed by the DPA, AML regulations, and PAGCOR requirements
• The potential risk of harm from unauthorized use or disclosure of the data
• Whether the purposes can be achieved through anonymization rather than deletion

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with 5ph1's data disposal procedures. Where data is anonymized rather than deleted, the anonymized data may be retained indefinitely for analytical purposes as it no longer constitutes personal data.

5ph1 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 5ph1's servers is encrypted using TLS 1.3 protocol.
• Encryption at Rest: Sensitive personal data stored on 5ph1's servers is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized 5ph1 personnel and service providers on a strict need-to-know basis. All access is logged and audited.
• Password Security: Player passwords are stored as salted cryptographic hashes. 5ph1 never stores passwords in plain text.
• Two-Factor Authentication: 5ph1 supports and encourages the use of two-factor authentication (2FA) for player accounts.
• Penetration Testing: 5ph1's systems are subject to regular security assessments and penetration testing by qualified cybersecurity professionals.
• Incident Response: 5ph1 maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission and affected players in accordance with the DPA's breach notification requirements.

As a data subject under the Data Privacy Act of 2012 of the Philippines, you have the following rights in respect of your personal data held by 5ph1:

The 5ph1 Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. 5ph1 does not knowingly collect personal data from individuals under the age of 21.

As part of our registration process, all players are required to confirm that they are 21 years of age or older and to complete KYC verification using a valid government-issued Philippine ID. Where 5ph1 discovers or has reasonable grounds to believe that an account has been registered by a person under 21 years of age, the account will be immediately suspended, all funds will be frozen pending investigation, and the personal data of the underage individual will be deleted in accordance with applicable law.

If you are a parent or guardian and believe that your child has registered an account on 5ph1, please contact us immediately using the details in Section 15 so we can take prompt action.

The 5ph1 Platform may contain links to third-party websites or services — for example, links to payment provider portals or game studio websites. This Privacy Policy applies only to the 5ph1 Platform and does not cover the privacy practices of any third-party websites or services.

5ph1 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 websites you visit before providing them with your personal data. The inclusion of a link to a third-party website on the 5ph1 Platform does not constitute an endorsement of that website or its privacy practices.

5ph1 primarily processes and stores personal data within the Philippines. However, some of our third-party service providers — including cloud hosting providers and technology partners — may process or store data in servers located outside the Philippines.

Where personal data is transferred outside the Philippines, 5ph1 ensures that appropriate safeguards are in place to protect your data in accordance with the requirements of the Data Privacy Act of 2012. These safeguards may include:

• Contractual clauses requiring the recipient to process data to the same standard as required under Philippine law
• Transfers to countries or organizations that have been assessed as providing an adequate level of data protection
• Other legally recognized transfer mechanisms as approved by the National Privacy Commission

You may request further information about the safeguards applicable to international transfers of your personal data by contacting our Data Protection Officer.

5ph1 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 to this Policy, we will notify registered players by email to their registered email address and/or by posting a prominent notice on the Platform at least seven (7) days before the changes take effect, where practicable.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. The current version of this Policy is always available on this page. We encourage you to review this Policy periodically to stay informed about how 5ph1 protects your personal data.

Your continued use of the 5ph1 Platform after the effective date of any amendment to this Policy constitutes your acceptance of the revised Policy. If you do not agree with the amended Policy, you must cease using the Platform and may request account closure in accordance with the 5ph1 Terms & Conditions.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 5ph1, please contact our Data Protection Officer through the following channels:

• Data Protection Officer: 5ph1 Data Protection Office
• Email: [email protected]
• Support Email: [email protected]
• Live Chat: Available 24/7 directly from the 5ph1 Platform
• Response Time: We aim to acknowledge all privacy-related inquiries within 48 hours and to provide a substantive response within 15 business days.

If you are not satisfied with our response to your privacy inquiry or complaint, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. Information about how to contact the NPC is available through official Philippine government channels.

For general information about 5ph1, please visit our About Us page. For information about responsible gaming tools and resources, please visit our Responsible Gaming page.