5bwm Privacy Policy

1 Introduction and Scope

This Privacy Policy ("Policy") is issued by 5bwm ("we," "us," "our"), the operator of the online gaming platform accessible at 5bwm.vip. This Policy governs the collection, use, storage, disclosure, and protection of personal data relating to all persons who visit, register on, or otherwise interact with the 5bwm platform, including prospective players, registered account holders, and former users whose data is retained under legal obligations ("you," "your," "data subject").

5bwm is committed to safeguarding the privacy and personal data of Filipino players and all other users of the platform. We process personal data strictly in accordance with:

• Republic Act No. 10173 — the Data Privacy Act of 2012 ("DPA") and its Implementing Rules and Regulations;
• National Privacy Commission (NPC) circulars, advisories, and guidelines;
• PAGCOR data governance and player protection requirements; and
• Republic Act No. 9160 — the Anti-Money Laundering Act of 2001 as amended ("AMLA") and related AMLC regulations.

This Policy applies to personal data processed through the 5bwm website, mobile browser interface, and all related support and communication channels, including live chat and email correspondence. By accessing or using 5bwm, you acknowledge that you have read and understood this Policy. If you do not agree with how we process your personal data, please discontinue use of the platform and contact us to request Account closure.

2 Data Controller Identity

5bwm is the personal information controller ("PIC") responsible for your personal data processed in connection with the 5bwm platform. As PIC, 5bwm determines the purposes and means of processing personal data and is accountable for ensuring that such processing is conducted lawfully, fairly, and transparently.

5bwm has designated a Data Protection Officer ("DPO") responsible for overseeing compliance with R.A. 10173 and this Policy. The DPO may be contacted at [email protected] with the subject line "Data Protection Officer." All data rights requests and privacy complaints will be handled by or under the direction of the DPO.

3 Categories of Personal Data We Collect

5bwm collects personal data in the following categories. The specific data points collected depend on your level of engagement with the platform (visitor, registered player, verified player):

5bwm does not knowingly collect sensitive personal information as defined under R.A. 10173 (e.g., health data, political affiliations, religious beliefs) unless strictly required for regulatory compliance purposes, in which case explicit consent will be obtained separately.

4 How We Collect Personal Data

5bwm collects personal data through the following methods:

1. Direct provision by you: Information you enter during account registration, identity verification, cashier transactions, support requests, or when updating your account profile.
2. Automated collection: Technical and usage data collected automatically through server logs, session management systems, and anonymized analytics tools when you access the 5bwm platform from any device.
3. Third-party payment providers: Limited financial verification data (e.g., masked payment account references) received from GCash, Maya, BPI, BDO, and other supported Philippine payment providers in connection with processing transactions.
4. Identity verification providers: Data returned by accredited KYC and identity verification service providers used to confirm the authenticity of government-issued identification documents during the account verification process.
5. Regulatory sources: In limited circumstances, data from PAGCOR or AMLC in connection with regulatory compliance obligations, including watchlist screening.

5 Legal Basis and Purposes of Processing

5bwm processes personal data only where a valid legal basis exists under R.A. 10173. The following table identifies the primary purposes of processing and the corresponding legal bases:

Where processing is based on consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. Consent withdrawal may be exercised through Account Settings or by contacting [email protected].

6 Data Sharing and Disclosure

5bwm does not sell personal data to any third party. We share personal data only in the following circumstances and only to the extent necessary for each purpose:

• Payment processors: GCash (GXI/PayMaya Technologies), Maya Philippines, BPI, BDO, and other Philippine payment providers receive transaction data necessary to process deposits and withdrawals. These providers are subject to Bangko Sentral ng Pilipinas (BSP) regulations and their own privacy obligations.
• KYC / Identity verification providers: Accredited third-party providers used to verify government-issued identification receive the minimum data necessary for verification. All such providers operate under data processing agreements with 5bwm.
• Game content providers: Licensed game studios and live dealer providers (e.g., Pragmatic Play, Evolution Gaming) may receive a pseudonymous session token for game-round integrity purposes. No directly identifiable personal data is transmitted to game providers beyond what is required for the game session.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement agencies may receive personal data where 5bwm is under a legal obligation to disclose, or where disclosure is necessary to protect the rights, property, or safety of 5bwm, its players, or the public.
• Professional advisers: Legal counsel, auditors, and accountants engaged by 5bwm may access personal data under strict professional confidentiality obligations where required to provide their services.

7 Cookies and Tracking Technologies

The 5bwm platform uses cookies and similar tracking technologies to deliver a functional, secure, and optimized experience. The following cookie categories are used:

5bwm does not deploy third-party advertising cookies, cross-site tracking cookies, or social media pixels. You may manage optional cookies through your browser settings; however, disabling essential session cookies will prevent you from logging in to your 5bwm Account.

8 Data Retention

5bwm retains personal data for the minimum period necessary to fulfill the purposes for which it was collected and to comply with applicable legal obligations. The following general retention periods apply:

• Active account data (identity, contact, financial, gameplay): Retained for the duration of the active account relationship plus a minimum of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and AMLA obligations.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required under R.A. 9160.
• KYC / Verification documents: Retained for a minimum of five (5) years following account closure or the last transaction, whichever is later.
• Support communications: Retained for a minimum of two (2) years from the date of the last communication, or longer where the communication relates to an ongoing dispute or investigation.
• Analytics data (anonymized): Retained in aggregated, non-identifiable form for up to three (3) years for platform improvement purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in a manner that prevents reconstruction of the original data. Where deletion is not immediately possible due to backup system schedules, data will be isolated from active processing until deletion is completed.

9 Data Security Measures

5bwm implements a layered security framework to protect personal data against unauthorized access, disclosure, alteration, and destruction. Our technical and organizational security measures include:

• Encryption in transit: 256-bit TLS encryption on all data communications between user devices and 5bwm servers;
• Encryption at rest: Personal data stored on 5bwm infrastructure is encrypted using AES-256 encryption;
• Access controls: Role-based access control (RBAC) limiting personnel access to personal data on a strict need-to-know basis;
• Authentication security: Mandatory two-factor authentication (2FA) for all administrative access to systems holding personal data;
• Security monitoring: 24/7 automated monitoring for unauthorized access attempts, anomalous activity, and potential data breaches;
• Penetration testing: Regular security assessments and vulnerability scanning conducted by qualified information security professionals;
• Staff training: All 5bwm personnel with access to personal data receive mandatory data privacy and information security training.

10 Your Data Subject Rights

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data processed by 5bwm:

To exercise any of the above rights, submit a written request to [email protected] with the subject line "Data Subject Rights Request," including your registered mobile number or username for identification. 5bwm will acknowledge your request within five (5) business days and respond substantively within fifteen (15) business days, extendable by a further fifteen (15) days in complex cases with prior notice to you.

Where 5bwm declines a data subject rights request — for example, where compliance with the request would conflict with a legal obligation — we will provide a written explanation of the reason for the refusal. You have the right to escalate unresolved complaints to the National Privacy Commission (NPC) through their official complaint channels.

11 Children and Minors

If you are a parent or legal guardian and believe that your child under 21 has provided personal data to 5bwm, please contact us immediately at [email protected] with the subject line "Minor Data Concern." We will investigate and take appropriate action within 48 hours of receiving your report.

12 Cross-Border Data Transfers

5bwm is a Philippines-focused platform and processes personal data primarily within the Republic of the Philippines. Where personal data is transferred to service providers located outside the Philippines — for example, internationally hosted cloud infrastructure providers or game studio platforms — such transfers are conducted only where:

1. The receiving jurisdiction provides an adequate level of protection for personal data as assessed under R.A. 10173 and NPC guidelines; or
2. Appropriate safeguards are in place, including data processing agreements containing standard contractual clauses consistent with NPC requirements; and
3. The transfer is limited to the minimum data necessary for the specific processing purpose.

5bwm will not transfer personal data to any jurisdiction or entity that does not provide adequate safeguards for the rights of Filipino data subjects.

13 Amendments to This Privacy Policy

5bwm reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR / NPC regulatory requirements. Material amendments will be communicated to registered Players via email to the registered account address and/or via a prominent notice on the 5bwm platform, with at least seven (7) days' notice before the revised Policy takes effect.

The most current version of this Privacy Policy is always available at 5bwm.vip/privacy-policy. The effective date at the top of this document reflects the most recent revision. Your continued use of the 5bwm platform following the effective date of an amended Privacy Policy constitutes your acceptance of the revised terms.

14 Contact and Complaints

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 5bwm, please contact our Data Protection Officer:

• Email: [email protected] (Subject: "Data Protection Officer")
• Response time: Acknowledgment within 5 business days; substantive response within 15 business days
• Live Chat: Available via the 5bwm platform for general inquiries; data rights requests must be submitted in writing by email

If you are unsatisfied with 5bwm's response to a privacy complaint, you have the right to lodge a formal complaint with the National Privacy Commission (NPC) of the Philippines through their official complaint process. The NPC is the competent supervisory authority for the enforcement of R.A. 10173 in the Philippines.