5ph1 Privacy Policy — How We Handle Your Personal Data

1 Introduction

5ph1 ("5ph1", "we", "us", "our") operates an online casino and sports betting platform accessible at 5ph1.cam, serving Filipino players under PAGCOR's regulatory framework. In doing so, 5ph1 necessarily processes certain personal data about its registered players and website visitors.

This Privacy Policy is issued pursuant to and in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), and all issuances of the National Privacy Commission ("NPC") of the Philippines. It describes how 5ph1 collects, uses, stores, shares, protects, and disposes of personal data, and what rights you have as a data subject.

5ph1 also processes certain data to comply with the Anti-Money Laundering Act of the Philippines (RA 9160, as amended) and PAGCOR's Know Your Customer requirements. Where these obligations require data processing that may differ from ordinary commercial practices, this policy explains those specific requirements.

2 Data Controller & Data Protection Officer

For the purposes of the Data Privacy Act of 2012, 5ph1 is the personal information controller in respect of all personal data collected through the 5ph1.cam platform.

5ph1 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this policy and the DPA. The DPO also serves as the primary point of contact for data subjects exercising their rights and for the National Privacy Commission in matters of regulatory correspondence.

To contact 5ph1's Data Protection Officer, please write to: [email protected] with the subject line "Data Protection Officer – [Your Request]".

3 Personal Data We Collect

5ph1 collects the following categories of personal data, depending on the nature of your interaction with the platform:

3.1 Registration & Identity Data

• Full legal name (first name, middle name, last name)
• Date of birth (used to verify the 21+ age requirement)
• Gender
• Philippine mobile number (used as primary account identifier and for SMS OTP)
• Email address
• Residential address in the Philippines

3.2 Identity Verification (KYC) Data

• Government-issued Philippine identification documents (e.g., PhilSys National ID, UMID, Passport, Driver's License, SSS ID, GSIS ID, Voter's ID, PRC ID)
• Selfie or live photo for identity matching where required
• Proof of address documents (e.g., utility bills, bank statements issued in the Philippines)

3.3 Financial & Transaction Data

• GCash mobile number or linked PayMaya account reference
• BPI, BDO, or Metrobank account details (partial, as provided for withdrawal processing)
• Deposit and withdrawal transaction records including amounts, timestamps, and method
• Gaming transaction history including wagers placed, game outcomes, and account balance movements

3.4 Technical & Usage Data

• IP address and approximate geolocation (city/region level)
• Device type, operating system, and browser information
• Session logs, login timestamps, and account activity records
• Pages visited on 5ph1.cam and navigation patterns
• Game session data including duration, frequency, and stake levels

3.5 Communications Data

• Records of live chat, email, and other support interactions with the 5ph1 team
• Feedback, complaints, or dispute records
• Marketing preference settings and promotional response data

4 How We Collect Personal Data

5ph1 collects personal data through the following channels:

• Directly from you — when you register a 5ph1 account, complete KYC verification, make a deposit, request a withdrawal, contact support, or participate in promotions.
• Automatically through your use of the platform — through cookies, server logs, and analytics tools that record technical and usage data as you navigate and interact with 5ph1.cam.
• From payment processors — GCash, PayMaya, and Philippine banking partners may share transaction confirmation data with 5ph1 to verify deposits and facilitate withdrawals.
• From identity verification services — third-party KYC providers may process and return verification results to 5ph1 in connection with account opening and ongoing compliance checks.
• From fraud prevention and security systems — technical data may be analyzed by automated systems to detect suspicious activity, multiple account attempts, or unusual access patterns.

5 Purposes of Personal Data Processing

6 Legal Bases for Processing

5ph1 processes personal data on the following legal bases as recognized under the Data Privacy Act of 2012:

• Contractual necessity — processing required to fulfil our obligations to you under the 5ph1 Terms & Conditions, including account management, game provision, and payment processing.
• Legal obligation — processing required to comply with PAGCOR licensing conditions, the Anti-Money Laundering Act, the Data Privacy Act itself, and other applicable Philippine laws.
• Legitimate interests — processing for fraud prevention, platform security, responsible gaming monitoring, and internal analytics, where these interests are not overridden by your fundamental rights and freedoms.
• Consent — processing for optional purposes such as direct marketing communications and non-essential cookies, where you have provided explicit, informed, and freely given consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Sharing of Personal Data

5ph1 does not sell, rent, or trade your personal data to third parties for commercial purposes. Data is shared only in the following circumstances and with the following categories of recipients:

• Payment processors — GCash (Mynt-Globe Fintech Innovation Inc.), PayMaya, BPI, BDO, and Metrobank, for the purpose of processing deposits and withdrawals.
• KYC and identity verification providers — third-party compliance technology partners that verify identity documents and perform liveness checks as required by PAGCOR KYC standards.
• Game technology providers — software providers (such as JILI Gaming and Pragmatic Play) may receive limited session data necessary to deliver game functionality and certify RNG outcomes. They do not receive financial or identity data beyond what is technically required.
• Regulatory and law enforcement authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and Philippine law enforcement agencies, where disclosure is required by law or court order.
• Professional advisers — legal counsel, auditors, and cybersecurity consultants engaged by 5ph1, who are bound by confidentiality obligations.
• Platform infrastructure providers — cloud hosting and CDN providers operating under contractual data processing agreements that prohibit independent use of 5ph1 player data.

8 Cookies & Tracking Technologies

5ph1.cam uses cookies and similar tracking technologies to operate the platform, maintain your login session, remember your preferences, and analyze how users interact with the site. The following categories of cookies are used:

• Strictly necessary cookies — required for core platform functionality including session management, login authentication, and security checks. These cannot be disabled without rendering the platform inoperable.
• Functional cookies — remember your language preferences, display settings, and other account-level customizations to improve your experience.
• Analytics cookies — collect anonymized data about how users navigate 5ph1.cam, which pages are visited most frequently, and where technical issues occur. This data is used exclusively for internal platform improvement.
• Security cookies — used to detect and prevent fraudulent activity, multiple account registrations, and other security threats.

You may manage non-essential cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of your 5ph1 account. 5ph1 does not use cookies to serve third-party advertising or share browsing data with advertising networks.

9 Data Security

5ph1 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• Encryption: AES-256 encryption for data at rest; TLS 1.3 for all data in transit between your device and 5ph1's servers.
• Access controls: Role-based access control (RBAC) ensuring that only authorized 5ph1 personnel with a legitimate business need can access specific categories of player data.
• Two-factor authentication: SMS OTP required for account access and sensitive account changes, available as an option for all 5ph1 players.
• Security monitoring: 24/7 automated monitoring for unauthorized access attempts, unusual login patterns, and data exfiltration signals.
• Regular audits: Periodic internal and third-party security assessments of 5ph1's infrastructure, access logs, and data handling practices.
• Staff training: All 5ph1 personnel handling personal data receive regular training on data protection obligations and security protocols.

In the event of a personal data breach that poses a real risk to the rights and freedoms of affected players, 5ph1 will notify the National Privacy Commission and affected data subjects within the timeframes required by the Data Privacy Act and NPC Circular 16-03.

10 Data Retention Periods

5ph1 retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable Philippine law. The following general retention standards apply:

• Account data and KYC records: Retained for a minimum of five (5) years following account closure, as required by PAGCOR licensing conditions and AMLA record-keeping obligations.
• Financial transaction records: Retained for five (5) years from the date of each transaction, in compliance with AMLA requirements.
• Game play and session logs: Retained for up to three (3) years from the date of each session for dispute resolution and responsible gaming monitoring purposes.
• Customer support communications: Retained for up to two (2) years from the date of the most recent interaction.
• Marketing data: Retained until you withdraw consent or request deletion, whichever is earlier.
• Technical and usage data: Anonymized after twelve (12) months and retained indefinitely in anonymized, aggregated form for analytics.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized using methods consistent with NPC guidelines.

11 Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by 5ph1. These rights may be exercised by contacting 5ph1's Data Protection Officer at [email protected].

5ph1 will respond to all valid data subject requests within thirty (30) calendar days of receipt, as required by NPC regulations. Complex requests may require an additional thirty (30) day extension, which will be communicated to you with reasons. If you are not satisfied with 5ph1's response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

12 Children's Privacy

5ph1's services are strictly intended for adults aged 21 years and above. 5ph1 does not knowingly collect personal data from individuals under the age of 21. The 21+ age requirement is enforced through mandatory KYC identity verification for all registered accounts.

13 Changes to This Privacy Policy

5ph1 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or NPC guidance. Material changes will be communicated to registered players by email to the address on file and/or by a prominent notice on 5ph1.cam, at least fourteen (14) days before the effective date of the revised policy.

The effective date at the top of this policy will be updated with each revision. We encourage you to review this policy periodically. Your continued use of 5ph1 after the effective date of a revised policy constitutes your acknowledgment of the updated terms. If you object to any change, you may request account closure at any time.

14 Contact & Data Protection Officer

For all privacy-related inquiries, data subject rights requests, or complaints regarding 5ph1's data processing practices, please contact our Data Protection Officer:

If you are not satisfied with how 5ph1 has handled your personal data or a data subject rights request, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines through their official channels.