5mbw Privacy Policy

1. Introduction

5mbw ("the Company," "we," "us," or "our") operates the online gaming platform at https://5mbw.vip. We take the privacy and security of your personal information seriously. This Privacy Policy ("Policy") describes how 5mbw collects, uses, stores, discloses, and protects your personal data when you visit, register on, or use the 5mbw Platform.

This Policy applies to all users of the 5mbw website and services, including registered players, visitors, and anyone who contacts our support team. By using the Platform, you acknowledge that you have read and understood this Policy and consent to the data processing activities described herein, to the extent such consent is required by applicable law.

This Policy should be read in conjunction with our Terms and Conditions and our Responsible Gaming Policy.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, 5mbw is the personal information controller in respect of data processed through the Platform.

We have appointed a Data Protection Officer (DPO) responsible for overseeing this Policy and ensuring compliance with applicable data protection laws. The DPO can be contacted at the address provided in Section 15 of this Policy.

3. Data We Collect

5mbw collects the following categories of personal data, depending on how you interact with the Platform:

3.1 Identity & Contact Data

• Full legal name
• Date of birth (for age verification purposes)
• Philippine mobile number
• Email address
• Government-issued ID number (for KYC verification)
• Residential address
• Nationality

3.2 Financial Data

• GCash or PayMaya account number (registered to your name)
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks) used for deposits or withdrawals
• Transaction history: deposit amounts, withdrawal amounts, dates, and payment methods
• Bonus credit balances and wagering activity

3.3 Gaming Activity Data

• Game sessions, including games played, bet amounts, win/loss outcomes, and session duration
• VIP tier status and loyalty point accumulation
• Responsible gaming tool settings (deposit limits, self-exclusion status, etc.)

3.4 Technical & Device Data

• IP address and geolocation data (country/region level)
• Device type, operating system, and browser type
• Session tokens and login timestamps
• Cookie identifiers and similar tracking technologies

3.5 Communications Data

• Records of communications with our support team, including live chat transcripts and email correspondence
• Feedback and survey responses
• Marketing preference settings and consent records

4. How We Collect Your Data

5mbw collects personal data through the following means:

• Direct Submission: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or responding to surveys.
• Automated Technologies: Data collected automatically through cookies, session tokens, log files, and analytics tools when you use the Platform.
• Payment Providers: Transaction confirmation data from GCash, PayMaya, and partner banks to verify deposits and process withdrawals.
• Identity Verification Services: KYC data verified through third-party identity verification providers in compliance with PAGCOR and AML requirements.
• Fraud Prevention Services: Device fingerprinting and behavioral analysis data from fraud detection service providers.

5. How We Use Your Data

5mbw uses your personal data for the following purposes:

6. Legal Basis for Processing

5mbw processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual Necessity: Processing required to fulfill our obligations under the Terms and Conditions, including account management, payment processing, and game provision.
• Legal Obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulatory requirements, anti-money laundering laws, and tax obligations.
• Legitimate Interests: Processing for fraud prevention, security, and platform improvement where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where your explicit consent has been obtained. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Data Sharing & Disclosure

5mbw does not sell, rent, or trade your personal data. We may share your data with the following categories of third parties, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash (GXI Inc.), PayMaya (Voyager Innovations), and partner Philippine banks — for transaction processing purposes only.
• Identity Verification Providers: Third-party KYC service providers for age verification and document authentication.
• Fraud Prevention Services: Providers of fraud detection, device fingerprinting, and AML screening services.
• Game Providers: Licensed game software providers (e.g., JILI, Pragmatic Play, PG Soft) receive session and wagering data necessary to operate their games.
• Regulatory Authorities: PAGCOR and other competent Philippine government authorities, where required by law or regulatory directive.
• IT and Hosting Providers: Infrastructure and cloud service providers who process data on our behalf under strict data processing agreements.

8. Cookies & Tracking Technologies

5mbw uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication tokens, security cookies, and load-balancing cookies. They cannot be disabled without affecting Platform functionality.
• Performance & Analytics Cookies: Used to understand how Players interact with the Platform — which pages are visited most, how long sessions last, and where errors occur. Data is aggregated and anonymized where possible.
• Functionality Cookies: Remember your preferences such as language settings, display preferences, and responsible gaming tool configurations.
• Marketing Cookies (Consent Required): Used to deliver relevant promotional communications based on your gaming preferences, where you have provided explicit consent.

You may manage non-essential cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use the Platform.

9. Data Retention

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

• Account and KYC Data: Retained for the duration of your account relationship with 5mbw, plus a minimum of five (5) years following account closure, in compliance with Philippine AML record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act (AMLA) of the Philippines.
• Gaming Activity Data: Retained for the duration of your account plus three (3) years after closure, for dispute resolution and regulatory purposes.
• Support Communications: Retained for two (2) years from the date of the communication, or longer if related to an open dispute.
• Marketing Consent Records: Retained for as long as your consent remains active, plus one (1) year after withdrawal, to demonstrate compliance.

Upon expiry of applicable retention periods, personal data will be securely deleted or anonymized in accordance with our data destruction procedures.

10. Data Security

5mbw implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, loss, destruction, or alteration, including:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers.
• Encryption of sensitive data at rest, including financial account details and government ID information.
• Role-based access controls limiting staff access to personal data to those with a legitimate business need.
• Regular security audits, vulnerability assessments, and penetration testing of our systems.
• Multi-factor authentication requirements for all staff with access to personal data systems.
• Incident response procedures for rapid detection, containment, and notification of data security breaches.

In the event of a personal data breach that poses a risk to your rights and freedoms, 5mbw will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected individuals without undue delay, as required by the Philippine Data Privacy Act.

11. Your Data Rights

Under the Philippine Data Privacy Act of 2012 and applicable NPC regulations, you have the following rights in respect of your personal data held by 5mbw:

• Right to Be Informed: The right to know what personal data we hold about you, how it is collected, how it is used, and with whom it is shared — which this Policy fulfills.
• Right of Access: The right to request a copy of the personal data 5mbw holds about you.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected.
• Right to Erasure: The right to request deletion of your personal data, subject to legal retention obligations.
• Right to Data Portability: The right to receive your personal data in a structured, machine-readable format.
• Right to Object: The right to object to certain types of processing, including direct marketing.
• Right to Withdraw Consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting prior processing.
• Right to File a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer as described in Section 15. We will respond to all verified requests within thirty (30) days.

12. Children's Privacy

The 5mbw Platform is strictly intended for individuals who are 21 years of age or older, in compliance with Philippine gaming law and PAGCOR regulations. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under the age of 21, we will immediately suspend the associated account, delete the data, and return any deposited funds following verification.

If you believe a minor has registered on the 5mbw Platform, please contact us immediately at [email protected] so we can take prompt action.

13. International Data Transfers

Some of 5mbw's service providers, including cloud infrastructure and game software partners, may be located outside the Philippines. Where personal data is transferred to countries that do not provide an equivalent level of data protection to the Philippines, 5mbw ensures that appropriate safeguards are in place, such as contractual clauses approved by the National Privacy Commission or the equivalent data protection authority of the relevant jurisdiction, to protect your data rights.

5mbw does not transfer your personal data to any country without first assessing the adequacy of that country's data protection framework and implementing appropriate contractual protections.

14. Changes to This Privacy Policy

5mbw may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or regulatory requirements. Material changes will be communicated to registered Players via email notification or by means of a prominent notice on the Platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. We encourage you to review this Policy periodically to stay informed about how 5mbw is protecting your data.

15. Contact & Data Protection Officer

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

You also have the right to lodge a complaint with the Philippine National Privacy Commission (NPC) if you believe your data rights have been violated. Information about the NPC and its complaint procedures is available on the NPC's official website.