5n5n Privacy Policy

1 Scope of This Policy

This Privacy Policy applies to all personal data collected and processed by 5n5n in connection with your use of the 5n5n platform, including the website at 5n5n.vu, the 5n5n mobile app, and any related communications or support interactions.

This policy is specifically intended for players based in the Philippines. If you access the platform from outside the Philippines, this policy still applies to the data you provide, though access from jurisdictions where online gaming is prohibited is not permitted under our Terms & Conditions.

5n5n acts as the data controller for all personal data described in this policy — meaning we determine the purposes and means of processing that data. Where third-party service providers process data on our behalf, they do so only under our instructions and are bound by appropriate data protection agreements.

2 Data We Collect

We collect personal data through several channels: when you register an account, when you use the platform, when you contact support, and automatically through your device and browser. Here is a breakdown of the main categories:

We do not knowingly collect sensitive personal data beyond what is required for identity verification and anti-money laundering compliance. We do not collect data from players under 21 years of age — age verification is a required step in the registration process.

3 How We Use Your Data

5n5n uses the personal data we collect only for legitimate and specified purposes. The main uses are:

• Account creation and management: To register your account, verify your identity, and maintain your player profile.
• Payment processing: To process deposits and withdrawals in Philippine Peso through local payment channels and verify that payment methods are registered in your name.
• Platform operation: To provide access to games, betting markets, and features; to track game sessions and bet histories; and to resolve technical issues.
• KYC and anti-money laundering (AML) compliance: To verify your identity before withdrawal and to detect and report suspicious financial activity as required.
• Fraud prevention and security: To identify unusual access patterns, flag potential account takeovers, and protect your funds and account data.
• Responsible gaming: To monitor activity for indicators of problem gaming behaviour, apply deposit limits or self-exclusion where requested, and comply with responsible gaming obligations.
• Customer support: To respond to your queries, resolve disputes, and maintain records of support interactions.
• Platform communications: To send you service-related notifications — account updates, transaction confirmations, security alerts, and where you have opted in, promotional communications.
• Legal and regulatory obligations: To comply with applicable laws, respond to lawful requests from authorities, and maintain required records.

We do not use your data for automated profiling that produces legal or similarly significant effects without your explicit consent.

4 Legal Basis for Processing

Every time we process your personal data, we do so on one of the following legal bases:

• Contract performance: Processing your registration data, payment details, and game activity is necessary to deliver the services described in our Terms & Conditions.
• Legal obligation: KYC verification, AML monitoring, and record-keeping are required by applicable law regardless of your consent.
• Legitimate interests: Fraud detection, security monitoring, and platform improvement are carried out where our legitimate business interests do not override your fundamental rights.
• Consent: Where we send you optional promotional communications, we do so only with your explicit consent. You may withdraw this consent at any time by updating your communication preferences in your account settings.

5 Sharing Your Data

5n5n does not sell your personal data to third parties. We share your data only in the following circumstances:

• Payment processors: Your financial data is shared with payment service providers only to the extent necessary to process your deposit or withdrawal. These providers are bound by their own data protection obligations.
• Identity verification providers: KYC document data may be processed by a third-party identity verification service operating under a data processing agreement with 5n5n.
• Technology and hosting providers: Platform infrastructure may involve third-party cloud hosting or software providers who access data only as processors acting on 5n5n's instructions.
• Regulatory and law enforcement authorities: We will disclose data when lawfully required to do so — for example, in response to a court order, regulatory investigation, or anti-money laundering reporting obligation.
• Business transfers: In the event of a merger, acquisition, or sale of assets, player data may be transferred as part of that transaction, subject to equivalent privacy protections.

In all cases, data shared with third parties is limited to what is strictly necessary for the purpose, and we take reasonable steps to confirm that recipients handle it appropriately.

6 Data Security

5n5n implements technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 5n5n platform
• OTP-based two-factor authentication for login and sensitive account actions including withdrawals
• Access controls that limit which 5n5n staff can access personal data and under what conditions
• Encrypted storage of sensitive data including identity verification documents and financial records
• Regular security reviews and monitoring for unusual access patterns or potential breaches

No online platform can guarantee absolute security. If you have reason to believe your account has been accessed without your authorisation, contact our support team immediately at [email protected]. You are also responsible for keeping your login credentials confidential and not sharing them with anyone.

7 Data Retention

We retain your personal data for as long as your 5n5n account is active and for a reasonable period thereafter, as required by law and legitimate business needs.

Specific retention periods are determined by the type of data:

• Account and identity data: Retained for the life of your account and for a defined period after account closure, as required for regulatory compliance and dispute resolution.
• Transaction and financial records: Retained for the period required by applicable financial regulations, typically several years from the date of the transaction.
• KYC documents: Retained in accordance with anti-money laundering requirements for the period specified under applicable law.
• Support and communications records: Retained for a reasonable period to support ongoing customer service and dispute handling.
• Technical and device data: Typically retained for a shorter period aligned with security monitoring purposes.

When data is no longer required for any of the purposes outlined above, we securely delete or anonymise it in a way that prevents re-identification.

8 Your Rights

As a user of the 5n5n platform, you have the following rights in relation to your personal data:

• Right of access: You can request a copy of the personal data we hold about you.
• Right to correction: You can ask us to correct inaccurate or incomplete personal data. Some corrections, such as your registered name, may require you to submit updated identity documents.
• Right to erasure: You may request deletion of your personal data in certain circumstances — for example, where data is no longer necessary for the original purpose. This right does not apply where we are required to retain data by law.
• Right to restrict processing: You can ask us to limit the processing of your data while a correction or objection request is being reviewed.
• Right to data portability: Where technically feasible and legally appropriate, you can request that we provide your data in a structured, machine-readable format.
• Right to object: You can object to processing carried out on the basis of legitimate interests. We will assess whether our legitimate interests override your rights in the specific context.
• Right to withdraw consent: Where processing is based on your consent — such as for promotional communications — you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at [email protected]. We will respond within a reasonable timeframe and may need to verify your identity before processing the request.

9 Cookies and Tracking

5n5n uses cookies and similar technologies to make the platform work correctly and to improve your experience. Cookies are small text files stored on your device when you visit the platform.

The types of cookies we use include:

• Essential cookies: Required for the platform to function — maintaining your login session, remembering your language preference, and enabling secure transactions. These cannot be disabled without affecting platform functionality.
• Analytics cookies: Used to understand how players navigate the platform — which pages are most visited, where users experience issues, and how platform performance can be improved. These are aggregated and do not identify individual users.
• Security cookies: Used to detect fraud, protect accounts, and identify suspicious activity patterns.

You can control non-essential cookies through your browser settings. Disabling cookies may affect some platform features. We do not use advertising or third-party tracking cookies for cross-site behavioural profiling.

10 Minors and Age Verification

Age verification is a mandatory step during the 5n5n registration process. If we have reason to believe an account is held by someone under 21, we will suspend that account immediately and delete the associated personal data, with the exception of records required to document the account suspension.

If you are a parent or guardian and believe a minor has registered an account on 5n5n, please contact us at [email protected] so we can investigate and take appropriate action.

11 Changes to This Policy

5n5n may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or platform features. When material changes are made, we will update the "Last updated" date at the top of this page.

Where changes are significant — for example, a new category of data use or a new type of third-party sharing — we will take reasonable steps to notify active account holders by email or in-platform notification before the changes take effect.

Continued use of the 5n5n platform after the effective date of any updated Privacy Policy constitutes your acceptance of the changes. If you do not agree with an update, you may request account closure by contacting our support team.

12 Contact Us

If you have questions about this Privacy Policy, want to exercise your data rights, or need to report a data security concern, you can reach the 5n5n team at:

[email protected]

Please include your registered email address and a clear description of your request so we can respond efficiently. We aim to acknowledge all data-related requests within a reasonable period and will provide a substantive response as promptly as our review allows.

For more information about your account rights and platform rules, see our Terms & Conditions and FAQ.