s5.com Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how s5.com (operating via the domain s5com.co and any associated sub-domains or mirror sites, collectively the "Platform") collects, uses, discloses, stores, and protects the personal data of individuals who access or use the Platform ("you" or "Data Subject").

s5.com takes its obligations under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations ("IRR") seriously. We process personal data only for lawful, specified, and legitimate purposes, and only to the extent necessary to fulfil those purposes. We implement appropriate technical and organisational security measures to protect data against unauthorised access, disclosure, alteration, and destruction.

This Policy applies to all personal data collected through the Platform — including data submitted during registration, deposited via GCash or bank transfer, gathered during gameplay, provided to customer support, and automatically collected through cookies and analytics tools. This Policy does not apply to third-party websites or services that may be linked from the Platform — those have their own privacy policies.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, the Personal Information Controller (PIC) responsible for your personal data is the operator of the s5.com Platform.

The s5.com Platform has appointed a Data Protection Officer (DPO) who is responsible for overseeing data protection matters and ensuring compliance with RA 10173. The DPO may be contacted at the details set out in Section 14 of this Policy.

3. Personal Data We Collect

Depending on how you interact with the s5.com Platform, we may collect the following categories of personal data:

3.1 Account Registration Data

• Full legal name (as it appears on your Philippine government-issued ID)
• Date of birth (to verify you meet the 21+ minimum age requirement)
• Philippine mobile number (used as primary account identifier and for OTP verification)
• Email address
• Username and password (stored in encrypted form)
• Preferred language and communications preferences

3.2 KYC and Identity Verification Data

• Government-issued Philippine ID number and ID type (PhilSys, UMID, Driver's License, Passport, SSS/GSIS ID, Voter's ID)
• Photographs of the front and back of the presented ID document
• Selfie photograph holding the presented ID document
• Proof of payment method ownership (where requested)

3.3 Financial Transaction Data

• Deposit and withdrawal amounts, dates, and times
• GCash wallet reference numbers
• Bank account numbers and bank name (for bank transfer transactions)
• Transaction identifiers and payment gateway reference numbers

3.4 Gaming Activity Data

• Game sessions played, stakes placed, outcomes, and win/loss records
• Bonus activations, wagering progress, and promotional participation history
• Sports betting markets accessed, odds presented, and bet settlement records
• Session duration and in-session behavioural data used for responsible gaming monitoring

3.5 Technical and Device Data

• IP address and approximate geolocation (country and region level)
• Device type, operating system, browser type and version
• Mobile network provider (e.g., Globe, Smart)
• Session logs, login timestamps, and authentication event records

3.6 Communications Data

• Content of support interactions via Live Chat, email, Viber, or Facebook Messenger
• Complaint and dispute records
• Survey responses and feedback submissions

4. How We Collect Personal Data

s5.com collects personal data through the following channels:

• Directly from you — when you register an Account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotions.
• Automatically — through cookies, web beacons, and server logs when you browse or interact with the Platform. See Section 10 for full details of our cookies practices.
• From payment processors — GCash, PayMaya (Maya), BPI, BDO, and Metrobank provide transaction reference data and, where applicable, basic account holder confirmation data necessary for payment processing and fraud prevention.
• From identity verification services — where s5.com uses third-party KYC technology partners to assist with document and biometric verification, those partners provide verification results and associated data to s5.com.
• From regulatory bodies — PAGCOR and the Anti-Money Laundering Council (AMLC) may provide information relevant to regulatory compliance obligations.

5. Purpose of Processing

s5.com processes personal data only for the following specific, legitimate purposes:

• Account management: Creating, maintaining, and securing your s5.com Account; verifying your identity and age; processing login authentication.
• KYC and age verification: Confirming you meet the PAGCOR-mandated 21+ minimum age requirement before processing withdrawals.
• Payment processing: Processing deposits, crediting winnings, and processing withdrawals via GCash, PayMaya, and Philippine bank channels.
• Game delivery: Operating and delivering casino games, live dealer tables, bingo, and sports betting markets; maintaining accurate game and bet records.
• Regulatory compliance: Fulfilling obligations under PAGCOR regulations, the Philippine Anti-Money Laundering Act (RA 9160 as amended), the Data Privacy Act (RA 10173), and other applicable Philippine law.
• Responsible gaming: Monitoring gaming behaviour to identify at-risk players, enforcing deposit limits and self-exclusion instructions, and complying with PAGCOR responsible gaming requirements.
• Fraud prevention and security: Detecting and preventing fraud, money laundering, account takeover, bonus abuse, and other prohibited conduct.
• Customer support: Responding to enquiries, resolving disputes, and providing assistance with account issues.
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates to players who have consented to receive such communications. You may opt out at any time via Account Settings or by contacting support.
• Platform improvement: Analysing aggregated, anonymised usage data to improve Platform performance, user experience, and game selection.

6. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, s5.com processes personal data on the following legal bases:

• Contractual necessity: Processing required to perform the agreement between s5.com and you — including Account creation, game delivery, payment processing, and KYC verification.
• Legal obligation: Processing required to comply with applicable Philippine law — including PAGCOR regulations, AML obligations, and data retention requirements.
• Legitimate interests: Processing for fraud detection, platform security, and responsible gaming monitoring — where such interests are not overridden by your rights and interests.
• Consent: Processing for direct marketing communications and non-essential analytics cookies — where you have given clear, informed, and freely revocable consent.

7. Data Sharing and Disclosure

s5.com does not sell your personal data to third parties. We may share your personal data only in the following circumstances:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and any other payment service provider necessary to process your transactions.
• KYC and identity verification partners: Third-party identity verification service providers who assist with document verification and biometric comparison, subject to data processing agreements compliant with RA 10173.
• Game software providers: Game studios (such as JILI, PG Soft, Pragmatic Play) may receive technical session data necessary to deliver games. These providers do not receive your full personal profile.
• Regulatory authorities: PAGCOR, the AMLC, the National Privacy Commission (NPC), and other Philippine government bodies — where required by law, court order, or regulatory direction.
• Professional advisors: Legal counsel, auditors, and compliance consultants — where necessary and subject to appropriate confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of the s5.com business, personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

8. Data Retention

s5.com retains personal data for as long as necessary to fulfil the purposes described in this Policy, subject to the following minimum retention periods:

• Account and KYC data: Retained for a minimum of five (5) years from the date of Account closure or last activity, as required by PAGCOR regulations and Philippine AML law.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with the Anti-Money Laundering Act.
• Gaming activity records: Retained for a minimum of three (3) years from the date of each session or bet.
• Customer support communications: Retained for a minimum of two (2) years from the date of the interaction, or longer where relevant to an ongoing dispute.
• Marketing consent records: Retained for as long as the consent is active and for one (1) year after withdrawal of consent.

Upon expiry of the applicable retention period, personal data will be securely deleted or irreversibly anonymised, unless further retention is required by law or for the establishment, exercise, or defence of legal claims.

9. Security Measures

s5.com implements a multi-layered approach to data security, including the following technical and organisational measures:

• 256-bit SSL/TLS encryption on all data transmitted between your device and the s5.com servers — the same standard used by Philippine banks and government portals.
• Password hashing — your Account password is stored as a one-way cryptographic hash. s5.com never stores passwords in plain text and cannot retrieve your password; only a reset is possible.
• Two-factor authentication (2FA) — logins from unrecognised devices require OTP verification via your registered Philippine mobile number.
• Access controls — personal data is accessible only to s5.com personnel who have a specific, documented need to access it for their role. Access is logged and audited.
• Data breach response — s5.com maintains an incident response plan and will notify the National Privacy Commission (NPC) and affected data subjects of any personal data breach within 72 hours of discovery, as required by RA 10173.
• Regular security assessments — the Platform undergoes periodic security reviews and vulnerability assessments.

While s5.com takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your Account credentials and for notifying s5.com promptly if you suspect any unauthorised access to your Account.

10. Cookies and Tracking Technologies

s5.com 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 — including session management, authentication tokens, and security features. These cookies cannot be disabled without impairing Platform functionality.
• Performance and analytics cookies: Used to collect anonymised data about how users interact with the Platform — including pages visited, session duration, and error events. This data helps us improve Platform performance. These cookies are activated only with your consent.
• Functional cookies: Used to remember your preferences — such as language settings, display preferences, and responsible gaming limit configurations.
• Marketing cookies: Used to deliver relevant promotional content and measure the effectiveness of marketing campaigns. These cookies are activated only with your consent and may be withdrawn at any time via your browser settings or the s5.com cookie preference centre.

You can control cookie preferences through your browser settings. Note that disabling strictly necessary cookies will affect your ability to use the Platform.

11. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by s5.com:

s5.com will respond to data subject requests within 30 calendar days of receipt. Where a request is complex or numerous, this period may be extended by a further 30 days, and we will notify you of the extension and the reason within the initial 30-day period.

12. Minors and Age Restriction

The s5.com Platform is strictly intended for individuals who are 21 years of age or older, in compliance with PAGCOR regulations governing online gambling in the Philippines. s5.com does not knowingly collect personal data from individuals under 21 years of age.

If s5.com becomes aware that personal data has been collected from an individual under 21 years of age, that data will be deleted promptly and the associated Account will be suspended. If you are a parent or guardian and believe your minor child has registered an Account on s5.com, please contact us immediately at [email protected] so we can take appropriate action.

13. Changes to This Privacy Policy

s5.com may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or platform features. Material changes will be communicated to registered players via email to the address on file, or via a prominent notice on the s5.com Platform, at least 7 days before the changes take effect.

The "Effective Date" at the top of this Policy will be updated each time the Policy is revised. Continued use of the Platform after the effective date of any revision constitutes acceptance of the updated Policy. We encourage you to review this Policy periodically.

14. Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or s5.com's data processing practices, you may contact the s5.com Data Protection Officer through the following channels:

• Email (DPO): [email protected] — please include "Privacy / DPO Request" in the subject line for prioritised handling.
• Live Chat: Available 24/7 on the s5.com Platform — for general privacy enquiries.
• Viber & Messenger: Contact details available within the Platform's Help Centre.

You also have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe s5.com has not adequately addressed your data privacy concerns. Information on the NPC complaints procedure is available via the NPC's official website.

This Privacy Policy was last updated in June 2026 and supersedes all previous versions. Last reviewed and approved by the s5.com Data Protection Officer.