5ph9 Privacy Policy

1 Introduction

5ph9 ("we," "us," "our," or "the Company") operates the online gaming platform accessible at 5ph9.net (the "Platform"). As a personal information controller under the Data Privacy Act of 2012, 5ph9 is responsible for the collection, use, storage, and protection of personal data provided by users of the Platform.

This Privacy Policy applies to all personal data collected from individuals who visit, register on, or otherwise interact with the 5ph9 Platform, including players based in Manila, Cebu, Davao, Quezon City, Makati, and across the Philippines. It covers data collected through the website, any mobile-optimised interface, live chat support, and any other channel through which you communicate with 5ph9.

We encourage you to read this Privacy Policy carefully and in full. If you have any questions about how 5ph9 handles your personal data, please contact our Data Protection Officer using the details provided in Section 14 of this document.

2 Personal Data We Collect

5ph9 collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include, but are not limited to, the following:

We do not collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. Where we are required to collect sensitive data — such as a copy of a government-issued ID — it is handled with the highest level of security and access controls.

3 How We Collect Your Data

5ph9 collects personal data through the following means:

• Direct interactions: Data you provide when registering your 5ph9 account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, pixel tags, and server logs. See Section 7 for more detail on cookies.
• Payment processors: Transaction confirmation data received from GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers when you make deposits or request withdrawals.
• Identity verification providers: Data received from third-party KYC and AML screening services used to verify your identity and comply with PAGCOR and AMLC requirements.
• Fraud prevention services: Risk signals and device fingerprinting data from third-party fraud detection partners used to protect the integrity of the Platform.

4 How We Use Your Personal Data

5ph9 uses the personal data we collect for the following purposes:

• Account management: To create, maintain, and administer your 5ph9 player account, including processing your registration, verifying your identity, and managing your account settings.
• Service delivery: To provide you with access to all games and features on the 5ph9 Platform, including slots, live casino, bingo, and rummy.
• Financial transactions: To process deposits and withdrawals via your chosen payment method, maintain accurate transaction records, and comply with financial reporting obligations.
• Regulatory compliance: To fulfil our obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, and other applicable Philippine laws. This includes conducting KYC checks, monitoring for suspicious transactions, and reporting to the AMLC where required.
• Responsible gaming: To monitor gaming activity for signs of problem gambling, enforce self-exclusion requests, apply deposit limits, and provide responsible gaming interventions where appropriate.
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance through live chat and other support channels.
• Security and fraud prevention: To detect, investigate, and prevent fraudulent activity, unauthorised account access, money laundering, and other prohibited conduct on the Platform.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates where you have provided consent or where we have a legitimate interest in doing so. You may opt out of marketing communications at any time.
• Platform improvement: To analyse usage patterns, conduct A/B testing, and improve the overall user experience on the 5ph9 Platform.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012, 5ph9 processes your personal data on the following legal bases:

• Contractual necessity: Processing that is necessary to perform our contract with you — i.e., to provide the 5ph9 gaming services you have registered for, including account management, game access, and financial transactions.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, AMLA reporting obligations, and tax requirements.
• Legitimate interests: Processing carried out for the legitimate interests of 5ph9 or third parties, including fraud prevention, platform security, and service improvement, where such 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 your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Sharing Your Personal Data

5ph9 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:

• Payment service providers: GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors, solely for the purpose of processing your deposits and withdrawals.
• KYC and AML service providers: Third-party identity verification and anti-money laundering screening providers engaged to assist 5ph9 in meeting its regulatory obligations.
• Game content providers: Licensed third-party game studios and live casino operators whose games are available on the 5ph9 Platform. These providers may receive limited technical data necessary to deliver their games.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where disclosure is required by law or court order.
• IT and security service providers: Cloud hosting, cybersecurity, and fraud detection vendors engaged to support the operation and security of the 5ph9 Platform.
• Professional advisers: Lawyers, auditors, and accountants engaged by 5ph9 in connection with legal, compliance, or financial matters, subject to professional confidentiality obligations.

7 Cookies & Tracking Technologies

5ph9 uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyse usage patterns, and support our security and fraud prevention measures. A cookie is a small text file placed on your device when you visit the Platform.

We use the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in to your 5ph9 account. These cookies cannot be disabled without affecting your ability to use the Platform.
• Functional cookies: Used to remember your preferences, such as your preferred language, display settings, and responsible gaming tool configurations.
• Analytics cookies: Used to collect aggregated, anonymised data about how players use the Platform, helping us identify areas for improvement. This data does not identify you personally.
• Security cookies: Used to detect and prevent fraudulent activity, including bot detection and device fingerprinting for account security purposes.

You may control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the 5ph9 Platform. For full details on the cookies we use, please refer to our Cookie Notice, which is available within your account settings.

8 Data Retention

5ph9 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account data: Retained for the duration of your active account relationship with 5ph9, plus a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and the AMLA.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by the AMLA and applicable tax regulations.
• KYC documents: Retained for a minimum of five (5) years following the end of the business relationship, or longer if required by a regulatory investigation or court order.
• Support communications: Retained for up to three (3) years from the date of the last interaction, for quality assurance and dispute resolution purposes.
• Marketing data: Retained until you withdraw your consent or opt out of marketing communications, after which it will be deleted or anonymised within thirty (30) days.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with 5ph9's data disposal procedures.

9 Data Security

5ph9 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the 5ph9 Platform.
• Encryption of sensitive data at rest, including financial data and identity documents.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing of the Platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with the National Privacy Commission's breach notification requirements.

While 5ph9 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your 5ph9 account credentials and for notifying us immediately if you suspect any unauthorised access to your account.

10 Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 5ph9. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14.