Privacy Policy – s5.com Casino

1. Who We Are

s5.com Casino ("s5.com," "we," "us," or "our") is an online casino and sports betting platform operated under the Philippine Amusement and Gaming Corporation (PAGCOR) regulatory framework and accessible at s5com.club. s5.com serves Filipino players across the Philippines, including Metro Manila, Cebu City, Davao, and other regions.

For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, s5.com acts as the Personal Information Controller (PIC) in respect of personal data collected from players and website visitors through the s5.com platform.

Questions or requests concerning this Privacy Policy or the personal data we hold about you may be directed to our Data Protection Officer at [email protected].

2. Personal Data We Collect

s5.com collects the following categories of personal data from players and, where applicable, website visitors:

Category	Examples
Identity Data	Full legal name, date of birth, nationality, government-issued ID number (e.g., PhilSys National ID, passport, driver's license)
Contact Data	Email address, Philippine mobile number, residential address
Financial Data	GCash account number, Maya account number, bank account details (BPI, BDO, Metrobank), transaction history, deposit and withdrawal records in Philippine Peso (₱)
Account Data	Username, encrypted password, account balance, bonus balance, wagering history, game session records
Technical Data	IP address, device type, operating system, browser type and version, session timestamps, geolocation (country/region level)
Usage Data	Pages visited on s5.com, games played, promotional offers viewed and claimed, customer support interaction records
KYC Documentation	Copies of government-issued identification, selfie photographs, proof of address documents

s5.com does not collect sensitive personal information as defined under the Data Privacy Act (e.g., racial or ethnic origin, religious beliefs, political affiliation, health data) unless expressly required by applicable law or regulation and only to the minimum extent necessary to comply with such requirements.

3. How We Collect Your Data

s5.com collects personal data through the following means:

• Direct interactions: Information you provide when registering an account, completing the KYC verification process, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the s5.com platform, including through cookies, server logs, and similar tracking technologies as described in Section 7 below.
• Third-party payment providers: Transaction confirmation data received from GCash, Maya, BPI, BDO, Metrobank, and other payment processors when you initiate a deposit or withdrawal through the s5.com platform.
• Identity verification services: Confirmation data from third-party KYC verification service providers engaged by s5.com to verify the authenticity of identity documents submitted by players.

4. Legal Basis for Processing

s5.com processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to open and maintain your s5.com account, process transactions, and provide the services described in the Terms and Conditions you agreed to upon registration.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, Anti-Money Laundering Act (AMLA) obligations, Bureau of Internal Revenue (BIR) requirements, and other applicable Philippine laws and regulations.
• Legitimate interests: Processing carried out for s5.com's legitimate operational interests, including fraud prevention, platform security, responsible gaming monitoring, and internal analytics — where such interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications, which you may withdraw at any time by updating your communication preferences in your s5.com account settings or by contacting support.

5. How We Use Your Personal Data

s5.com uses the personal data we collect for the following purposes:

• Creating and managing your s5.com player account
• Processing deposits and withdrawals through GCash, Maya, and supported Philippine banking channels
• Verifying your identity and age (21+) in compliance with PAGCOR requirements and the Data Privacy Act
• Detecting, investigating, and preventing fraud, money laundering, and other unlawful activities
• Administering bonus offers and promotional campaigns in accordance with their applicable terms
• Providing 24/7 customer support services in English
• Sending transactional communications (deposit confirmations, withdrawal notifications, security alerts)
• Sending marketing communications where you have provided consent, including promotional offers relevant to Filipino players
• Monitoring gameplay patterns for responsible gaming purposes, including detecting signs of problem gambling behaviour
• Complying with PAGCOR reporting obligations, AMLA transaction monitoring requirements, and other applicable regulatory requirements
• Improving the s5.com platform through aggregated, anonymised analytics

6. Data Sharing and Disclosure

s5.com does not sell, rent, or trade your personal data to third parties. We may share personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection obligations:

• Payment processors: GCash (Mynt), Maya (PayMaya Philippines), BPI, BDO, Metrobank, and other payment service providers — to process your financial transactions on the s5.com platform.
• KYC and identity verification providers: Third-party service providers engaged to verify the identity and age of players as required by PAGCOR licensing conditions.
• Game content providers: Software licensors whose games are hosted within the s5.com platform — limited to aggregated, anonymised gameplay data required for game integrity monitoring.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), Bureau of Internal Revenue (BIR), and other competent Philippine authorities — where disclosure is required by law or by binding regulatory direction.
• Professional advisers: Legal counsel, auditors, and compliance consultants engaged by s5.com — subject to strict professional confidentiality obligations.

Where personal data is shared with third-party processors, s5.com ensures that appropriate data processing agreements are in place requiring processors to protect the data to standards equivalent to those required under the Data Privacy Act of 2012.

7. Cookies and Tracking Technologies

s5.com uses cookies and similar tracking technologies on the platform. Cookies are small text files placed on your device that allow the platform to recognise you between sessions, maintain your login state, and personalise your experience.

s5.com uses the following categories of cookies:

• Strictly necessary cookies: Required for core platform functions — session authentication, secure login maintenance, and fraud prevention signals. These cannot be disabled without affecting platform functionality.
• Functional cookies: Store your preferences such as language settings and responsible gaming tool configurations across sessions.
• Analytics cookies: Collect aggregated, anonymised data on how players navigate and use the s5.com platform, used to improve usability and content relevance.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from accessing the core s5.com platform but may affect certain personalisation features.

8. Data Retention

s5.com retains personal data for the following minimum periods, in compliance with applicable Philippine regulatory requirements:

• Account and identity data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLA record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required under the Anti-Money Laundering Act.
• KYC documentation: Retained for a minimum of five (5) years following account closure or the completion of the relevant KYC review.
• Technical and usage data: Retained for up to twelve (12) months for platform performance and fraud monitoring purposes, after which it is anonymised or deleted.
• Marketing consent records: Retained for the duration of your account and for three (3) years following account closure or consent withdrawal, for record-keeping compliance.

9. Security Measures

s5.com implements technical, organisational, and physical security measures designed to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the s5.com platform
• Encryption of stored passwords using industry-standard one-way hashing algorithms
• Two-factor authentication (2FA) available and encouraged for all player accounts
• Access controls limiting s5.com personnel access to personal data on a strict need-to-know basis
• Regular security audits and penetration testing of the platform infrastructure
• Automatic session timeout after periods of inactivity
• Login anomaly detection and new-device notification alerts

No method of transmission over the internet or method of electronic storage is completely secure. While s5.com employs commercially reasonable security measures, we cannot guarantee absolute security of your personal data.

10. Your Data Privacy Rights

Under the Data Privacy Act of 2012 (Republic Act No. 10173), Filipino players and data subjects have the following rights in relation to the personal data s5.com holds about them:

• Right to be informed: The right to know whether s5.com holds personal data about you and the purposes for which it is being used.
• Right of access: The right to obtain a copy of your personal data held by s5.com.
• Right to rectification: The right to have inaccurate or incomplete personal data corrected.
• Right to erasure or blocking: The right to request deletion or blocking of your personal data in circumstances permitted under the Data Privacy Act.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to object: The right to object to processing of your personal data carried out on the basis of legitimate interests, including profiling.
• Right to withdraw consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to file a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, submit a written request to s5.com's Data Protection Officer at [email protected]. s5.com will respond to verified requests within fifteen (15) business days.

11. Children and Minors

21+ The s5.com platform is strictly for individuals aged 21 years and above. s5.com does not knowingly collect personal data from individuals below the age of 21. If we become aware that personal data has been submitted by an individual below the age of 21, we will immediately close the associated account, void any transactions, and delete or anonymise the personal data. If you believe a minor has registered an account on s5.com, please contact us immediately at [email protected].

12. Updates to This Privacy Policy

s5.com reserves the right to update this Privacy Policy at any time to reflect changes in applicable Philippine data privacy law, PAGCOR regulatory requirements, or our data processing practices. Material changes will be communicated to registered players via the email address associated with their account at least fourteen (14) days before the effective date of the change. Continued use of the s5.com platform after the effective date of any updated Privacy Policy constitutes your acknowledgement of the changes.

The version of this Privacy Policy published on the s5.com website at any given time is the current and operative version. Previous versions are available on request from our Data Protection Officer.

13. Contact Our Data Protection Officer

For all data privacy enquiries, access requests, rectification requests, complaints, or other matters relating to your personal data held by s5.com, please contact our Data Protection Officer:

Email: [email protected]
Support is available 24 hours a day, 7 days a week. Response to formal data privacy requests within 15 business days.

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your rights under the Data Privacy Act of 2012 have not been adequately addressed by s5.com.