5mbw Privacy Policy

1. Introduction

5mbw ("5mbw", "we", "us", "our") operates the online gaming platform accessible at 5mbw.app and its associated mobile applications. We are committed to protecting the privacy and personal data of every individual who interacts with our platform, whether as a registered player, a visitor browsing our website, or a person who contacts our support team.

This Privacy Policy ("Policy") has been prepared in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines, its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). It describes our practices regarding the collection, use, storage, disclosure, and protection of personal data.

By accessing the 5mbw platform, registering an account, or otherwise engaging with our services, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with any part of this Policy, please discontinue use of the platform and contact us to request account closure.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and applicable data protection legislation, 5mbw is the Personal Information Controller (PIC) in respect of the personal data collected through the 5mbw platform.

As the PIC, 5mbw 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. Our designated Data Protection Officer (DPO) oversees compliance with this Policy and applicable data protection laws.

You may contact our DPO at any time using the contact details provided in Section 15 of this Policy.

3. Personal Data We Collect

5mbw collects the following categories of personal data in connection with the operation of the platform and the provision of our services:

3.1 Identity and Contact Data

• Full legal name as it appears on your government-issued ID
• Date of birth and age verification information
• Residential address in the Philippines (barangay, city/municipality, province)
• Email address
• Philippine mobile number
• Government-issued ID type and number (e.g., PhilSys National ID, passport, driver's licence, SSS ID, GSIS ID, PRC ID, voter's ID)

3.2 Financial Data

• Payment method details (GCash account name and number, PayMaya/Maya account details, bank account name and number, debit card details)
• Transaction history including deposits, withdrawals, and bonus credits
• Source of funds information where required by AML regulations

3.3 Gaming and Account Data

• Username and encrypted password
• Game history, wager amounts, wins, and losses
• Bonus and promotion usage history
• Responsible gaming settings (deposit limits, loss limits, self-exclusion status)
• Customer support interaction records

3.4 Technical and Usage Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser information
• Session duration, pages visited, and features used on the platform
• Cookies and similar tracking technology data (see Section 10)
• Login timestamps and access logs

3.5 Communications Data

• Content of emails, live chat messages, and other communications you send to 5mbw
• Records of your marketing preferences and opt-in/opt-out choices

4. How We Collect Your Data

5mbw collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting support, or participating in a promotion.
• Automated collection: Technical and usage data collected automatically when you access the platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance partners; payment confirmation data from payment processors such as GCash, PayMaya/Maya, and partner banks.
• Publicly available sources: Where permitted by law, information from public registries or databases used to verify your identity or comply with regulatory obligations.

5. Legal Basis for Processing

5mbw processes your personal data on the following legal bases as recognised under the Data Privacy Act of 2012:

Where we rely on your consent as the legal basis for processing, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. How We Use Your Personal Data

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

• Account creation and management: To register your 5mbw account, verify your identity, and maintain your player profile.
• Service delivery: To process deposits and withdrawals, credit bonuses, settle bets, and provide access to all games and features on the platform.
• KYC and AML compliance: To verify your age (21+), identity, and source of funds in accordance with PAGCOR licensing requirements and Philippine anti-money laundering regulations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, multi-accounting, bonus abuse, and other prohibited conduct.
• Responsible gaming: To administer deposit limits, loss limits, session reminders, and self-exclusion requests; to identify players who may be exhibiting signs of problem gambling and intervene appropriately.
• Customer support: To respond to your enquiries, resolve disputes, and improve the quality of our support services.
• Marketing and promotions: To send you information about 5mbw promotions, new games, and special offers — but only where you have opted in to receive such communications. You may opt out at any time.
• Platform analytics: To understand how players use the 5mbw platform, identify areas for improvement, and optimise the user experience.
• Legal and regulatory compliance: To comply with applicable Philippine laws, respond to lawful requests from regulatory authorities, and enforce our Terms and Conditions.

5mbw will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

7. Sharing Your Personal Data

5mbw does not sell your personal data to third parties. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash, PayMaya/Maya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your deposits and withdrawals.
• KYC and identity verification providers: Third-party service providers that assist us in verifying your identity and age in compliance with PAGCOR and AML requirements.
• Fraud and AML screening providers: Compliance technology partners that help us detect and prevent money laundering, fraud, and other financial crimes.
• Game software providers: Third-party game studios whose games are hosted on the 5mbw platform may receive limited technical data necessary to deliver the game experience.
• IT and cloud service providers: Hosting, infrastructure, and security service providers who process data on our behalf under strict data processing agreements.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies where disclosure is required by law.
• Legal and professional advisers: Lawyers, auditors, and other professional advisers where necessary to protect 5mbw's legal rights or comply with legal obligations.

8. Data Retention

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

• Active account data: Retained for the duration of your account and for a period of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and AML regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act of 2001 (as amended).
• KYC documents: Retained for a minimum of five (5) years following the end of the business relationship.
• Customer support records: Retained for three (3) years from the date of the interaction, unless a longer period is required for dispute resolution.
• Marketing preferences: Retained until you withdraw your consent or request deletion, subject to any overriding legal retention obligations.
• Technical and usage logs: Retained for up to twelve (12) months for security and fraud prevention purposes.

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

9. Data Security

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

• Encryption of data in transit using TLS/SSL protocols
• Encryption of sensitive data at rest using industry-standard encryption algorithms
• Role-based access controls limiting employee access to personal data on a need-to-know basis
• Multi-factor authentication for internal systems that process personal data
• Regular security assessments, penetration testing, and vulnerability scanning
• Staff training on data protection and information security best practices
• Incident response procedures for detecting, reporting, and managing personal data breaches

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 5mbw will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected individuals without undue delay where required by law.

10. Cookies and Tracking Technologies

5mbw uses cookies and similar tracking technologies on the platform to enhance your experience, maintain session security, and gather analytics data. The following types of cookies are used:

• Strictly necessary cookies: Essential for the platform to function correctly. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, responsible gaming limits, and display options to personalise your experience.
• Analytics cookies: Collect anonymised data about how players use the platform — which pages are visited most, how long sessions last, and where users encounter errors. This data helps us improve the platform.
• Marketing cookies: Used only where you have consented to receive personalised promotions. These cookies track your interaction with 5mbw marketing materials to help us deliver relevant offers.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 5mbw platform. Strictly necessary cookies cannot be disabled as they are essential to the operation of the service.

11. Your Data Subject Rights

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in relation to your personal data held by 5mbw:

• Right to be informed: The right to be notified of how your personal data is being collected and processed — which is the purpose of this Policy.
• Right of access: The right to request a copy of the personal data 5mbw holds about you and information about how it is processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data. You may update most account information directly through your account settings panel.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to overriding legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of the above rights, please submit a written request to our Data Protection Officer using the contact details in Section 15. We will respond to your request within fifteen (15) business days of receipt. We may need to verify your identity before processing your request.

12. Minors and Age Restriction

The 5mbw platform is strictly intended for individuals aged 21 years and above. 5mbw does not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory step in the account registration and KYC process.

If 5mbw becomes aware that personal data has been collected from an individual under the age of 21, we will immediately close the associated account, delete the personal data, and return any deposited funds to the payment method used, less any winnings generated, which will be forfeited.

If you are a parent or guardian and believe that a minor has registered an account on the 5mbw platform, please contact us immediately at [email protected] so that we can take appropriate action.

13. Cross-Border Data Transfers

In the course of operating the 5mbw platform, your personal data may be transferred to and processed in countries other than the Philippines — for example, where our cloud infrastructure providers or game software partners are located. 5mbw ensures that any such cross-border transfer of personal data is carried out in compliance with the Data Privacy Act of 2012 and the NPC's rules on cross-border data flows.

Specifically, 5mbw will only transfer personal data to a foreign country or international organisation where:

• The receiving country has been assessed as providing an adequate level of data protection; or
• Appropriate safeguards are in place, such as standard contractual clauses or binding corporate rules approved by the NPC; or
• The transfer is necessary for the performance of a contract between you and 5mbw (e.g., processing a payment through an international payment network).

14. Changes to This Privacy Policy

5mbw 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, we will notify registered players by email to the address on file and/or by displaying a prominent notice on the platform for a period of not less than 14 days prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Policy periodically. Your continued use of the 5mbw platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

15. Contact Our Data Protection Officer

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

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines (NPC) if you believe that 5mbw has not handled your personal data in accordance with applicable law. Information on how to file a complaint with the NPC is available on the NPC's official website.