5ph2 Privacy Policy

This Privacy Policy ("Policy") is published by 5ph2 ("Company", "we", "us", or "our"), the operator of the online gaming platform accessible at https://5ph2.cam (the "Platform"). This Policy explains how 5ph2 collects, uses, discloses, stores, and protects the personal data of all users ("you", "your", "Player") who access or use the Platform, in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Republic of the Philippines.

By accessing the Platform, registering for an account, making a deposit, or otherwise interacting with 5ph2's services, 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 to this Policy, you must not use the Platform.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, both of which form part of your agreement with 5ph2.

1. Identity of the Data Controller

1.1 Data Controller. For the purposes of RA 10173, 5ph2 acts as the personal information controller in respect of all personal data collected through the Platform. 5ph2 determines the purposes for and the means by which personal data is processed.

1.2 Data Protection Officer. 5ph2 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and with RA 10173. Queries, complaints, or data rights requests may be directed to the DPO at: [email protected] with the subject line "Data Privacy – DPO Request".

2. Personal Data We Collect

5ph2 collects the following categories of personal data, which are described in detail below:

2.1 Data You Provide Directly

Category	Specific Data Points	Mandatory?
Registration Data	Full legal name, date of birth, residential address, mobile number, email address, username	Yes
Identity Verification (KYC)	Government-issued photo ID (e.g., PhilSys ID, passport, driver's license), selfie photo, proof of address	Yes (for withdrawals)
Payment Information	GCash/Maya mobile number, bank account details, e-wallet identifiers, cryptocurrency wallet address	Yes (for transactions)
Communications	Support chat logs, email correspondence, feedback submissions	No (voluntary)
Preferences	Marketing opt-in status, notification preferences, responsible gaming limit settings	No (voluntary)

2.2 Data Collected Automatically

When you access the Platform, our systems automatically collect certain technical and behavioral data, including:

• IP address, device type, operating system, and browser type;
• Session timestamps, pages visited, and features used;
• Gaming activity logs (game played, bet amounts, outcomes, session duration);
• Deposit and withdrawal transaction records;
• Cookies and similar tracking technology data (see Section 7);
• Geolocation data (city-level only, derived from IP address).

2.3 Data from Third Parties

5ph2 may receive personal data about you from third parties in the following circumstances:

• Payment processors (e.g., GCash, Maya, BPI, BDO) — transaction confirmation and fraud screening data;
• Identity verification providers — document authenticity and age verification results;
• Fraud prevention services — risk scores, device fingerprints, and flagged account indicators;
• PAGCOR and regulatory authorities — where legally required to share or receive information.

3. How We Use Your Personal Data

5ph2 processes your personal data only for specified, legitimate purposes. The legal basis for each category of processing under RA 10173 is indicated below:

• Account Registration and Management — to create and maintain your 5ph2 account, verify your identity, and provide you access to our gaming services. Legal basis: Performance of contract.
• Payment Processing — to process deposits, withdrawals, and refunds via your chosen payment method (GCash, Maya, bank transfer, USDT TRC20, Coins.ph, etc.). Legal basis: Performance of contract.
• Regulatory Compliance — to fulfill our obligations under PAGCOR licensing conditions, Philippine AML regulations, and RA 10173, including KYC and suspicious transaction reporting. Legal basis: Legal obligation.
• Fraud Prevention and Security — to detect, investigate, and prevent cheating, collusion, money laundering, and other fraudulent or illegal activity on the Platform. Legal basis: Legitimate interests / Legal obligation.
• Responsible Gaming — to monitor gaming behavior for signs of problem gambling, enforce deposit and loss limits you set, and administer self-exclusion requests. Legal basis: Legal obligation / Legitimate interests.
• Customer Support — to respond to your queries, complaints, and account-related requests. Legal basis: Performance of contract.
• Platform Improvement — to analyze usage patterns, identify technical issues, and improve the overall player experience. Data used for this purpose is aggregated and anonymized wherever possible. Legal basis: Legitimate interests.
• Marketing Communications — to send you promotional offers, bonus announcements, and platform updates, but only where you have given your explicit consent. You may opt out at any time. Legal basis: Consent.

4. Data Sharing and Third-Party Disclosure

4.1 General Principle. 5ph2 does not sell, rent, or trade your personal data to any third party for their own marketing purposes. We disclose your data only in the circumstances described in this section.

4.2 Service Providers. We engage trusted third-party service providers who process personal data on our behalf under strict data processing agreements. These providers are permitted to use your data only as instructed by 5ph2 and for no other purpose. Categories include:

• Payment processing providers (GCash, Maya, BancNet-affiliated banks);
• KYC and identity verification vendors;
• Cloud infrastructure and data hosting providers;
• Customer support platform providers;
• Fraud detection and cybersecurity services;
• Game content providers (JILI, PG Soft, and live dealer studios — game session data only).

4.3 Regulatory and Law Enforcement Authorities. 5ph2 is required by Philippine law to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and law enforcement agencies upon lawful demand. Such disclosures will be made without prior notice to you where legally required or where advance notice would compromise an investigation.

4.4 Corporate Transactions. In the event of a merger, acquisition, restructuring, or sale of all or part of 5ph2's business, your personal data may be transferred to the acquiring or successor entity. You will be notified of such a transfer and of any material changes to this Policy that result from it.

4.5 Cross-Border Transfers. Where personal data is transferred to or processed by service providers located outside the Philippines, 5ph2 ensures that adequate safeguards are in place in compliance with NPC guidelines on cross-border data transfers, including the use of standard contractual clauses or equivalent mechanisms.

5. Data Security Measures

5.1 Technical Safeguards. 5ph2 implements industry-standard technical security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. These include:

• 256-bit SSL/TLS encryption for all data transmissions;
• AES-256 encryption at rest for sensitive stored data;
• Multi-factor authentication for all administrative Platform access;
• Continuous intrusion detection and monitoring systems;
• Regular third-party penetration testing and vulnerability assessments;
• Firewalls, network segmentation, and access control policies.

5.2 Organizational Safeguards. Access to personal data within 5ph2 is restricted on a strict need-to-know basis. All staff who handle personal data undergo mandatory privacy training and are bound by confidentiality obligations. Data access logs are maintained and reviewed regularly.

5.3 Your Responsibilities. While 5ph2 takes all reasonable precautions to secure your data, you also play a role in keeping your account safe. You are responsible for maintaining the confidentiality of your password and for securing the device you use to access the Platform. 5ph2 is not liable for security breaches arising from your failure to protect your credentials.

5.4 Breach Response. In the event of a personal data breach that is likely to result in a real risk to the rights and freedoms of data subjects, 5ph2 will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will inform affected users as soon as reasonably practicable, in accordance with Section 20(f) of RA 10173.

6. Cookies and Tracking Technologies

6.1 What Are Cookies. Cookies are small text files placed on your device by the Platform when you visit or log in. They help 5ph2 recognize your browser, maintain your session, and remember your preferences.

6.2 Types of Cookies We Use.

Cookie Type	Purpose	Duration
Strictly Necessary	Session management, login authentication, fraud prevention. Cannot be disabled without breaking the Platform.	Session
Functional	Remembering your language preference, game lobby settings, and notification choices.	Up to 12 months
Analytics	Understanding how players navigate the Platform to improve usability (aggregated, anonymized data).	Up to 24 months
Marketing	Tracking promotional campaign effectiveness (only where you have consented to marketing communications).	Up to 12 months

6.3 Managing Cookies. You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in or using the Platform. You may opt out of marketing cookies at any time by updating your account notification preferences or by contacting support.

7. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 5ph2:

• Right to be Informed — You have the right to know what personal data about you 5ph2 holds, how it is being used, and with whom it is shared. This Policy satisfies that right in general terms; you may request a more specific summary at any time.
• Right of Access — You may request a copy of the personal data 5ph2 holds about you. We will fulfill verified access requests within thirty (30) calendar days, subject to identity verification.
• Right to Rectification — If any personal data we hold about you is inaccurate or incomplete, you have the right to request correction. You may update most information directly through your Account Settings, or by contacting support.
• Right to Erasure — You may request deletion of your personal data. Note that certain data cannot be deleted due to mandatory legal retention obligations (see Section 8). Where deletion is possible, we will process your request within thirty (30) calendar days.
• Right to Data Portability — You may request that we provide your personal data in a structured, commonly used, machine-readable format for transfer to another controller.
• Right to Object — You may object to processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to our overriding legal obligations.
• Right to Lodge a Complaint — If you believe your data rights have been violated, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of these rights, contact our Data Protection Officer at [email protected] with the subject line "Data Privacy – [Right Being Exercised]". We will acknowledge your request within five (5) business days and respond fully within thirty (30) calendar days.

8. Data Retention

8.1 Active Accounts. 5ph2 retains your personal data for as long as your account remains open and active. We review account activity annually and may contact you regarding dormant accounts.

8.2 Closed Accounts. Upon account closure, 5ph2 retains your personal data for a minimum of five (5) years, in compliance with PAGCOR regulatory retention requirements and Philippine AML obligations under the Anti-Money Laundering Act. Certain transaction records may be retained for up to ten (10) years where required by law.

8.3 Anonymization. Where data is no longer required for regulatory retention but retains analytical value for Platform improvement, 5ph2 may anonymize the data such that it can no longer be linked to any individual, in which case this Policy ceases to apply to that anonymized data.

8.4 Secure Disposal. When personal data reaches the end of its retention period, it is securely deleted or destroyed using methods that prevent reconstruction or recovery.

9. Children and Minors

The 5ph2 Platform is strictly restricted to individuals aged 21 years and above, in compliance with PAGCOR regulations on minimum gambling age in the Philippines. 5ph2 does not knowingly collect personal data from persons under 21 years of age. If we become aware that an account has been created by or on behalf of a minor, we will immediately suspend the account, void any transactions, return any deposits, and delete the associated personal data.

If you have reason to believe that a minor has provided personal data to 5ph2, please contact us immediately at [email protected].

10. Changes to This Privacy Policy

5ph2 reserves the right to update or modify this Privacy Policy at any time. When material changes are made, we will update the "Last Updated" date at the top of this page and, where the changes significantly affect your rights or the way we handle your data, we will provide notice via your registered email address or through a prominent notice on the Platform prior to the change taking effect.

Your continued use of the Platform following the effective date of any revised Policy constitutes your acceptance of those changes. We encourage you to review this Policy periodically to stay informed about how 5ph2 protects your data.

11. How to Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 5ph2, please contact our Data Protection Officer: