s5com Privacy Policy

1 Introduction

Welcome to s5com. s5com ("we", "us", "our", or "the Platform") is a premium online casino and sports betting platform operated for Filipino players under PAGCOR regulatory oversight. We take the privacy and security of your personal data seriously, and this Privacy Policy ("Policy") sets out in clear, honest terms exactly how we handle the information you entrust to us when you use our website at s5com.ws and any related services, mobile features, or promotions.

This Policy applies to all registered players, visitors, and any person who interacts with the s5com Platform in any capacity. By accessing or using s5com, you acknowledge that you have read, understood, and agree to the collection and use of information as described herein. If you do not agree to this Policy, you must immediately stop using the Platform and contact us to close any existing account.

This Policy must be read together with our Terms & Conditions and our Responsible Gaming Policy, both of which form part of the overall agreement between you and s5com.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, s5com acts as the Personal Information Controller (PIC) in respect of the personal data collected through this Platform.

As PIC, s5com determines the purposes for which, and the means by which, personal data is processed. s5com has designated a Data Protection Officer (DPO) responsible for overseeing our data protection practices and serving as your point of contact for all privacy-related queries. Contact details for the DPO are provided in Section 14 of this Policy.

Where s5com engages third-party service providers — such as payment processors, KYC verification providers, or analytics platforms — those parties act as Personal Information Processors (PIP) on our instruction and are bound by written data processing agreements consistent with the requirements of RA 10173.

3 Data We Collect

s5com collects personal data through several channels: information you provide directly during registration and use of the Platform, information generated automatically by your device and browser as you interact with our services, and information obtained from trusted third-party verification and payment providers where necessary for legal compliance. The categories of personal data we collect are detailed in the table below.

3.1 Data We Do Not Collect

s5com does not intentionally collect special categories of sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data beyond what is strictly necessary for responsible gaming assessments, or biometric data beyond what is required for identity verification. Any such data inadvertently received will be promptly deleted.

4 How We Use Your Data

s5com processes your personal data for specific, legitimate purposes only. We do not use your data in ways that are incompatible with the purposes described below without first seeking your additional consent or establishing another lawful basis for the new processing activity.

• Account creation and management: To register your s5com account, verify your identity, manage your wallet balance, and provide you with access to all Platform features;
• Payment processing: To facilitate deposits and withdrawals via GCash, Maya, BPI, BDO, UnionBank, Coins.ph, 7-Eleven Cliqq, and USDT TRC20;
• Legal and regulatory compliance: To fulfil our obligations under the Anti-Money Laundering Act (RA 9160), the Data Privacy Act (RA 10173), and PAGCOR licensing requirements, including KYC verification, suspicious transaction reporting to AMLC, and record-keeping;
• Fraud prevention and platform security: To detect, investigate, and prevent fraud, account compromise, multi-accounting, bonus abuse, and other prohibited conduct described in our Terms & Conditions;
• Responsible gaming: To monitor gambling behaviour for signs of problem gambling, enforce self-exclusion requests, apply deposit limits, and comply with responsible gaming obligations;
• Customer support: To respond to your queries, complaints, and requests, and to maintain a record of our communications with you;
• Platform improvement and analytics: To understand how players use s5com, identify technical issues, improve game offerings, and optimise the user experience;
• Marketing communications (with consent): To send you promotional offers, bonus notifications, and platform updates where you have opted in to receive such communications.

5 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, s5com relies on the following lawful bases for processing your personal data:

• Contractual necessity: Processing is necessary to fulfil our contractual obligations to you under the s5com Terms & Conditions — including account management, payment processing, and game delivery;
• Legal obligation: Processing is required to comply with applicable Philippine laws and PAGCOR regulatory requirements, including AML obligations and KYC verification;
• Legitimate interests: Processing is necessary for purposes of fraud prevention, platform security, responsible gaming monitoring, and general Platform analytics, where these interests are not overridden by your fundamental rights;
• Consent: For marketing communications and non-essential cookies, we rely on your freely given, specific, and informed consent, which you may withdraw at any time.

6 Data Sharing & Disclosure

s5com does not sell, rent, or otherwise disclose your personal data to third parties for their own commercial purposes. We share your personal data only in the following limited and controlled circumstances:

6.1 Service Providers

We engage carefully selected third-party service providers who process personal data on our behalf and under our instruction, solely to support the operation of s5com. These include payment processors, KYC and identity verification platforms, cloud infrastructure providers, customer support software vendors, and analytics providers. All processors are bound by written agreements that require them to process data only as instructed and to maintain appropriate security measures.

6.2 Regulatory and Law Enforcement Authorities

s5com is legally required to disclose personal data to the following authorities where mandated by Philippine law: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent government agencies. Such disclosures are made in strict compliance with applicable legal requirements and, where legally permitted, we will notify affected players.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of substantially all of s5com's assets, your personal data may be transferred to the successor entity as part of that transaction. We will provide reasonable notice prior to any such transfer and will ensure that the successor entity maintains privacy standards consistent with this Policy.

6.4 With Your Consent

We may share your data with third parties in circumstances not described above where you have provided your explicit, informed consent for that specific sharing activity.

7 Data Retention

s5com retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including satisfying any legal, regulatory, accounting, or reporting requirements.

• Active account data is retained for the duration of your account registration with s5com;
• KYC and identity verification records are retained for a minimum of five (5) years following account closure, in compliance with Philippine AML legislation;
• Transaction and financial records are retained for a minimum of five (5) years following the date of the transaction, in compliance with the Anti-Money Laundering Act;
• Customer support communications are retained for three (3) years following the closure of the support case;
• Marketing preference records (including consent records) are retained for three (3) years following the withdrawal of consent or account closure, whichever is earlier;
• Technical and usage logs used for security and fraud detection are retained for up to twenty-four (24) months.

Upon the expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be linked to any identifiable individual.

8 Data Security

s5com implements a comprehensive set of technical and organisational security measures designed to protect your personal data against accidental loss, unauthorised access, alteration, disclosure, or destruction. Our security infrastructure includes, but is not limited to:

• AES-256 encryption for data stored at rest;
• TLS 1.3 encryption for all data transmitted between your device and s5com servers;
• Multi-factor authentication options for player accounts;
• Role-based access controls ensuring that s5com staff access personal data only on a strict need-to-know basis;
• Regular penetration testing and vulnerability assessments conducted by independent third-party security specialists;
• Real-time intrusion detection and monitoring systems;
• Regular staff training on data protection and information security best practices.

While s5com takes all reasonable steps to protect your data, no method of transmission over the internet or method of electronic storage is completely secure. Players are encouraged to use strong, unique passwords and to enable multi-factor authentication on their s5com accounts. If you suspect your account has been compromised, please contact our support team immediately.

9 Cookies & Tracking Technologies

s5com uses cookies and similar technologies (including web beacons and local storage) to operate and improve the Platform. Below is a transparent breakdown of the cookie categories we use:

9.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function correctly. They enable core features such as user authentication, session management, and security. These cookies cannot be disabled without significantly impairing Platform functionality, and no consent is required for their use.

9.2 Analytics Cookies

We use analytics cookies to understand how players navigate and use s5com — such as which pages are visited most frequently, how long sessions last, and where technical errors occur. This data is used in aggregate and anonymised form to improve Platform performance. Analytics cookies are activated only with your consent.

9.3 Functional Cookies

Functional cookies remember your preferences — such as your preferred language, display settings, and game lobby filters — to provide a more personalised experience. These are activated with your consent and can be disabled via your browser or account settings.

9.4 Managing Cookies

You can manage, restrict, or delete cookies at any time through your browser settings or through the cookie preference panel available on the s5com Platform. Please note that disabling certain categories of cookies may affect your ability to use some features of the Platform.

10 Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by s5com. You may exercise any of these rights by contacting our Data Protection Officer using the details in Section 14.

11 Minors & Age Restriction

s5com's services are strictly restricted to individuals aged 21 years and above, in accordance with PAGCOR regulations and Philippine law. s5com does not knowingly collect, process, or store personal data from any individual under the age of 21. The Platform is not directed at minors in any capacity.

During the registration process, all applicants must confirm their date of birth and agree that they meet the 21+ age requirement. Where s5com has reasonable grounds to suspect that a registered user is under 21 years of age, the account will be suspended immediately pending age verification. If it is confirmed that the account holder is under 21, the account will be permanently closed, all associated data will be deleted to the extent permitted by law, and any deposits made will be returned to the source payment method.

If you are a parent or guardian and believe that a minor has accessed s5com or provided us with personal data, please contact our support team immediately using the details in Section 14 so that we can take appropriate action.

12 Cross-Border Data Transfers

s5com primarily stores and processes personal data within the Philippines. However, some of our trusted third-party service providers — including cloud infrastructure, analytics, and KYC verification partners — may operate servers in other countries. Where personal data is transferred outside the Philippines, s5com ensures that appropriate safeguards are in place to protect that data to a standard at least equivalent to that required under RA 10173.

Safeguards for international transfers include:

• Data processing agreements incorporating standard contractual clauses approved by the National Privacy Commission or equivalent competent authority;
• Transfers only to jurisdictions that the NPC has recognised as providing an adequate level of data protection;
• Binding corporate rules where applicable within group entities.

Where technically and contractually feasible, s5com configures its service providers to store data in Philippine or ASEAN-region data centres. If you have questions about specific cross-border transfers, please contact our Data Protection Officer.

13 Changes to This Policy

s5com reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. We will communicate material changes to this Policy by:

• Posting a notice on the s5com Platform homepage and relevant pages;
• Sending an email notification to your registered email address;
• Updating the "Effective Date" and version number at the top of this Policy.

Where changes require your consent under applicable law, we will seek that consent before the changes take effect. Your continued use of the s5com Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. If you do not agree to the revised Policy, you must stop using the Platform and request account closure prior to the effective date.

14 Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the way s5com processes your personal data, you may contact our Data Protection Officer (DPO) at any time. Our DPO is responsible for overseeing s5com's compliance with RA 10173 and serves as your primary point of contact for all privacy-related matters.

Data Protection Officer Email: [email protected]

Customer Support (24/7): [email protected]

When contacting the DPO, please include your registered s5com username, a clear description of your request or concern, and any relevant reference numbers from previous correspondence. We aim to acknowledge all privacy-related requests within five (5) business days and to resolve them fully within thirty (30) calendar days.