the5rs Privacy Policy — How We Collect, Use, and Protect Your Data

the5rs ("we", "us", "our") is committed to protecting and respecting the privacy of every individual who visits, registers on, or interacts with the the5rs platform accessible at the5rs.net (the "Platform"). This Privacy Policy sets out the basis on which any personal data we collect from you — or that you provide to us — will be processed.

This policy applies to all players, visitors, and any other individuals whose personal data is processed by the5rs in connection with the operation of the Platform. It covers data collected through the website, mobile interface, live chat, email correspondence, and any other channel through which you interact with the5rs.

By accessing the Platform or creating an Account, you acknowledge that you have read and understood this Privacy Policy and that you consent to the collection and use of your personal data as described herein. If you do not agree with the terms of this Privacy Policy, you should not access or use the Platform.

For the purposes of applicable data protection legislation, the5rs acts as the data controller in respect of the personal data collected through and in connection with the Platform. As data controller, the5rs determines the purposes for which, and the means by which, your personal data is processed.

If you have any questions about how your personal data is handled, or wish to exercise any of the rights described in this Privacy Policy, you may contact the5rs data protection team using the contact details set out in Section 16 of this document.

the5rs collects personal data from players and Platform users across the following categories. Not all categories of data will apply to every user — the specific data collected depends on how you interact with the Platform:

the5rs does not knowingly collect sensitive personal data such as racial or ethnic origin, religious beliefs, health data, or biometric data, except where expressly required for identity verification purposes (for example, a CNIC photograph may incidentally contain a facial image).

the5rs collects personal data through the following means:

• Direct Submission: Data you provide when completing the registration form, submitting a KYC document upload, contacting support via live chat or email, or updating your account profile.
• Automated Collection: Technical and usage data collected automatically through server logs, cookies, and similar technologies whenever you access or interact with the Platform. This includes IP address, device fingerprint, and session activity data.
• Payment Processors: Transaction reference data received from payment service providers such as JazzCash, EasyPaisa, HBL, UBL, SadaPay, and USDT TRC20 processors when you make deposits or withdrawals. the5rs does not store full bank account or wallet credentials — only transaction reference identifiers necessary for reconciliation and fraud prevention.
• KYC and Identity Verification Partners: Where a third-party verification service is used to validate the authenticity of identity documents, that partner may share verification outcome data with the5rs. the5rs does not receive raw biometric data from such partners unless required for manual review.
• Customer Support Interactions: Any information you choose to share when communicating with the5rs support team, including through live chat, email, or any other support channel.

the5rs processes personal data only for specified, explicit, and legitimate purposes. The table below sets out the primary purposes for which we process personal data and the legal basis on which each processing activity rests:

the5rs does not sell, rent, or otherwise transfer your personal data to third parties for their own independent marketing or commercial purposes. Personal data is shared only in the following limited circumstances:

• Payment Service Providers: Transaction data is shared with payment processors (JazzCash, EasyPaisa, HBL, UBL, SadaPay, and authorised USDT processors) solely for the purpose of processing your deposit or withdrawal. These processors operate under their own privacy policies and are independently responsible for the data they collect.
• KYC and Identity Verification Partners: Identity documents submitted for verification may be processed by authorised third-party KYC service providers engaged by the5rs. These providers are bound by strict data processing agreements and may only use your data for the specific verification purpose for which it was shared.
• Game Content Providers: Certain usage data — such as game session identifiers and bet amounts — may be transmitted to third-party game providers whose titles are hosted on the Platform. This data is used for game outcome calculation, RNG auditing, and session management. No personally identifiable contact or financial data is shared with game providers.
• Legal and Regulatory Authorities: the5rs may be required by law, court order, or regulatory directive to disclose certain player data to competent authorities. In such cases, the5rs will disclose only the minimum data required to comply with the legal obligation and will, where legally permissible, notify the affected player of such disclosure.
• Professional Advisors: Lawyers, auditors, and consultants engaged by the5rs may have access to player data on a strictly need-to-know basis, subject to professional confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, restructuring, or sale of the5rs or its assets, player data may be transferred to the relevant successor entity. Players will be notified of any such transfer and of any material changes to data handling practices that result from it.

the5rs retains personal data only for as long as is necessary for the purpose for which it was collected, or as required to satisfy applicable legal, regulatory, accounting, or reporting obligations. The following general retention periods apply:

• Account Data: Retained for the duration of the active account relationship and for a minimum of five (5) years following account closure, in line with standard gaming platform compliance and anti-money laundering record-keeping requirements.
• KYC Documents: Retained for a minimum of five (5) years from the date of submission or the date of account closure, whichever is later, in line with AML and identity verification obligations.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction to support audit, reconciliation, dispute resolution, and legal compliance purposes.
• Support Communications: Live chat transcripts and support email records are retained for a minimum of two (2) years from the date of the communication to facilitate dispute resolution and service quality monitoring.
• Technical and Log Data: Server log and IP address data is retained for a maximum of twelve (12) months unless a longer retention period is required for a specific fraud investigation or legal matter.
• Marketing Consent Records: Records of marketing consent and opt-out requests are retained for as long as necessary to demonstrate compliance with applicable marketing regulations.

Where personal data is no longer required for any lawful purpose, the5rs will securely delete or anonymise it. Anonymised data — from which all identifying information has been irreversibly removed — may be retained indefinitely for statistical and analytical purposes.

the5rs uses cookies and similar technologies on the Platform. A cookie is a small text file placed on your device by a website server. The following categories of cookies are used by the5rs:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function. They enable core features such as session management, login authentication, and account security. These cookies cannot be disabled without impairing your ability to use the Platform.
• Functional Cookies: These cookies remember your preferences — such as language settings and game display preferences — to provide a more personalised experience on return visits. Disabling these cookies may affect certain Platform features.
• Analytics Cookies: the5rs uses anonymised analytics data to understand how players navigate the Platform, which features are most used, and where technical improvements can be made. This data is aggregated and does not identify individual players.
• Fraud Prevention Cookies: Certain cookies and device fingerprinting technologies are used to detect and prevent fraudulent activity, including multi-accounting, bonus abuse, and unauthorised access attempts. These are deployed in the5rs's legitimate interest in platform security.

the5rs does not use advertising or behavioural tracking cookies that follow players across third-party websites. You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will prevent normal use of the Platform.

the5rs implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include, but are not limited to:

• AES-256 encryption for personal data stored at rest on the5rs servers.
• TLS 1.3 protocol for all data transmitted between your device and the Platform.
• Strict access controls limiting internal access to personal data to authorised personnel whose roles require such access.
• Regular security audits and penetration testing by independent third-party security professionals.
• Two-factor authentication (2FA) available to all registered players as an additional account security measure.
• Automated intrusion detection systems monitoring for unusual or potentially malicious access patterns.

While the5rs takes all reasonable steps to protect your personal data, no system of data transmission or storage can be guaranteed to be 100% secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, the5rs will take immediate steps to contain the breach and will notify affected players without undue delay in accordance with applicable data protection obligations.

Subject to applicable law and certain limited exceptions, you have the following rights in respect of your personal data held by the5rs:

• Right of Access: You may request a copy of the personal data the5rs holds about you. the5rs will provide this information within a reasonable timeframe and at no charge for routine requests.
• Right to Rectification: If any personal data held by the5rs is inaccurate or incomplete, you have the right to request that it be corrected or updated. You may update basic account details directly through your account profile, or contact support for more complex corrections.
• Right to Erasure: You may request that the5rs delete your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where it has been processed unlawfully. Note that certain data may need to be retained by the5rs to comply with legal obligations, even following a deletion request.
• Right to Restriction: You may request that the5rs restrict processing of your personal data in certain circumstances — for example, while the accuracy of data is under dispute, or where you object to processing based on legitimate interest.
• Right to Object: You have the right to object to the processing of your personal data where the5rs relies on legitimate interest as its legal basis. You also have an absolute right to object to processing for direct marketing purposes.
• Right to Data Portability: Where processing is carried out by automated means on the basis of consent or contractual necessity, you may request a copy of the personal data you have provided to the5rs in a structured, commonly used, machine-readable format.
• Right to Withdraw Consent: Where the5rs processes your data on the basis of consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.

To exercise any of the above rights, contact the5rs at [email protected] with the subject line "Data Rights Request", providing your account username and a clear description of your request. the5rs will acknowledge your request within 72 hours and respond substantively within 30 calendar days.

the5rs is strictly a platform for adults aged 21 and above. The Platform is not directed at, and is not intended for use by, individuals under the age of 21. the5rs does not knowingly collect personal data from any person under 21 years of age.

If the5rs becomes aware that personal data has been submitted by or in respect of an individual under the age of 21, that account will be immediately closed, any balance will be returned to the depositing payment method, and all associated personal data will be deleted as promptly as permitted by applicable legal obligations.

the5rs operates as an international online gaming platform. As such, personal data collected from players in Pakistan may be processed on servers or by service providers located in jurisdictions outside Pakistan. Where personal data is transferred internationally, the5rs takes reasonable steps to ensure that the transfer is subject to appropriate safeguards consistent with the purpose for which the data was originally collected.

Such safeguards may include data processing agreements with service providers that impose data protection obligations equivalent to those the5rs applies in its own operations, and selection of service providers that maintain recognised international security certifications.

By using the Platform and submitting your personal data, you acknowledge that your data may be transferred to and processed in jurisdictions outside Pakistan. If you have concerns about specific international transfers of your data, you may raise these with the5rs at [email protected].

the5rs may send promotional and marketing communications — including bonus offers, new game announcements, and platform updates — to players who have opted in to receive such communications. The following conditions apply to marketing communications from the5rs:

• Marketing communications are sent only to players who have provided explicit opt-in consent at registration or subsequently through account settings.
• You may withdraw consent to receive marketing communications at any time by updating your account notification preferences, or by contacting support at [email protected] with the subject line "Marketing Opt-Out".
• Opting out of marketing communications does not affect your receipt of service-related communications — such as deposit confirmations, withdrawal notifications, account security alerts, and KYC requests — which are sent on the basis of contractual necessity rather than consent.
• the5rs does not share your contact details with any third party for the purposes of that third party sending you their own marketing communications.
• Where applicable regulations require, marketing communications will include a clear and accessible unsubscribe mechanism.

The the5rs Platform may, from time to time, contain references to game providers or other third-party services. the5rs is not responsible for the privacy practices of any third-party organisations and does not control how those organisations collect or use personal data.

This Privacy Policy applies solely to data collected by the5rs through the Platform. the5rs strongly recommends reviewing the privacy policies of any third-party service you access in connection with your use of the Platform, including your chosen payment provider (JazzCash, EasyPaisa, HBL, UBL, SadaPay), before submitting personal information to that third party.

the5rs reserves the right to update or amend this Privacy Policy at any time. When material changes are made, the5rs will notify registered players by email to the address on file and will display a prominent notice on the Platform at the time of login. The "Last Updated" date at the top of this document will reflect the date of the most recent revision.

Your continued use of the Platform following the publication of a revised Privacy Policy constitutes your acceptance of the changes. If you do not accept the revised policy, you should cease using the Platform and may request account closure by contacting support.

the5rs recommends that you review this Privacy Policy periodically to stay informed of how your personal data is being handled. Material changes affecting your rights will always be communicated proactively — not merely made available on the website without notice.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way the5rs handles your personal data, please contact us using the details below:

• Email: [email protected]
• Live Chat: Available 24 hours a day, 7 days a week from any page of the Platform
• Support Hours (Email): 09:00 – 24:00 Pakistan Standard Time (PKT), daily

For data rights requests specifically, please use the subject line "Data Rights Request" and include your registered account username and a clear description of the action you wish the5rs to take regarding your personal data.