5qqq Privacy Policy
How We Protect Your Personal Data

1 Introduction & Scope

This Privacy Policy ("Policy") describes how 5qqq ("the Platform", "we", "us", "our") collects, uses, stores, shares, and protects personal information relating to individuals ("you", "the Player", "the User") who access or use the 5qqq online gaming platform, including the website at 5qqq.io, any associated mobile-optimised interfaces, and all related services offered under the 5qqq brand.

This Policy applies to all personal data collected from players based in Bangladesh and internationally, regardless of the device or method used to access the Platform. It covers information collected at the point of registration, during active play, through customer support interactions, and via passive tracking technologies such as cookies.

By accessing the 5qqq website, creating a player account, or otherwise engaging with our services, you acknowledge that you have read this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you must not use the Platform.

2 Data Controller

For the purposes of applicable data protection law, 5qqq acts as the data controller in respect of the personal information it collects from players. As data controller, 5qqq determines the purposes and means by which personal data is processed, and is responsible for ensuring that processing activities are carried out lawfully, fairly, and transparently.

All data protection enquiries, subject access requests, and privacy-related complaints should be directed to the 5qqq Data Protection contact at [email protected]. Please include "Privacy Request" in the subject line of your communication to ensure it is routed to the appropriate team member.

5qqq is committed to responding to all privacy-related enquiries within 30 calendar days of receipt. In cases of particular complexity, we may extend this period by a further 60 days, in which case we will notify you of the extension and the reasons for it within the initial 30-day window.

3 Data We Collect

5qqq collects several categories of personal data in the course of providing its gaming and betting services. The following table summarises the main categories of data collected and provides examples of specific data points within each category.

Where 5qqq is required to collect personal data by applicable law or by the terms of a contractual relationship with the player, and the player fails to provide that data when requested, 5qqq may be unable to continue providing the relevant service. In such cases, 5qqq will notify the player at the time of the request.

4 How We Collect Your Data

4.1 Directly from You

The majority of personal data held by 5qqq is provided directly by the player through the account registration process, KYC verification submissions, deposit and withdrawal requests, customer support contacts, and completion of responsible gaming tools such as deposit limit or self-exclusion requests.

4.2 Automated Technologies

When you visit the 5qqq website, certain technical and usage data is collected automatically through cookies, web beacons, server log files, and similar tracking technologies. This data is collected regardless of whether you are logged into an account and is used primarily for security monitoring, platform performance optimisation, and fraud detection purposes. Please refer to Section 8 of this Policy for full details on our use of cookies.

4.3 Third-Party Sources

In limited circumstances, 5qqq may receive personal data about you from third-party sources, including:

• Identity verification providers: Third-party KYC and document verification services used to confirm the authenticity of identity documents submitted by players.
• Payment processors: Mobile financial service providers (including bKash, Nagad, and Rocket) and banking partners may share transaction confirmation data with 5qqq to reconcile deposits and withdrawals.
• Fraud and AML screening services: Third-party databases used to screen players against sanctions lists, politically exposed person (PEP) registries, and known fraud networks.
• Analytics providers: Aggregated, anonymised statistical data from analytics platforms used to understand overall platform usage patterns. Such data does not identify individual players.

5 Legal Basis for Processing

5qqq processes personal data only where a valid legal basis exists. The legal bases on which 5qqq relies for different processing activities are summarised below:

• Contractual necessity: Processing that is necessary to enter into and perform the contract between 5qqq and the player, including account registration, processing deposits and withdrawals, and providing access to games.
• Legal obligation: Processing required to comply with applicable legal obligations, including anti-money-laundering (AML) regulations, Know Your Customer (KYC) requirements, and regulatory reporting obligations.
• Legitimate interests: Processing necessary for the legitimate interests of 5qqq, including fraud prevention, platform security monitoring, responsible gaming compliance, and improving the player experience — provided those interests are not overridden by your rights and interests.
• Consent: Where 5qqq relies on your consent as the legal basis for processing (for example, for certain marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 How We Use Your Data

5qqq uses the personal data it collects for the following purposes:

• Account management: Creating, maintaining, and administering your 5qqq player account, including processing account updates and managing login credentials.
• Identity verification: Conducting KYC verification to confirm your identity, age (minimum 21 for Bangladesh players), and residential address as required by our compliance obligations.
• Payment processing: Processing deposits via bKash, Nagad, Rocket, Upay, and other accepted payment methods, and processing withdrawal requests to verified player accounts.
• Game and betting services: Enabling access to the 5qqq game library, recording game activity for accuracy and dispute resolution, and maintaining a complete and auditable transaction history.
• Customer support: Responding to your enquiries, resolving disputes, processing complaints, and providing technical assistance via email, live chat, and other support channels.
• Responsible gaming: Monitoring gaming patterns for signs of problem gambling, enforcing player-set limits and self-exclusion requests, and fulfilling obligations under our Responsible Gaming Policy.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent transactions, unauthorised account access, multi-accounting, bonus abuse, money laundering, and other prohibited conduct.
• Legal compliance: Retaining records and fulfilling reporting obligations as required by applicable financial crime legislation, tax authorities, and regulatory bodies.
• Platform improvement: Analysing aggregated usage patterns to identify areas for improvement in platform performance, game selection, and user experience — all on an anonymised basis where possible.
• Communications: Sending transactional notifications (deposit confirmations, withdrawal approvals, security alerts) and, where consent has been obtained, promotional communications about 5qqq offers and events.

7 Sharing Your Data

5qqq does not sell, rent, or trade your personal data. We share personal information only with the categories of third parties described below, and only to the extent necessary for the stated purpose:

7.1 Game Technology Providers

Game providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi may receive limited technical data (such as session identifiers and game round data) necessary to deliver their games to you through the 5qqq platform. These providers are contractually prohibited from using such data for any purpose other than providing the gaming service.

7.2 Payment Service Providers

To process deposits and withdrawals, 5qqq shares necessary payment and identity data with mobile financial service providers (bKash, Nagad, Rocket, Upay) and banking partners (Dutch-Bangla Bank, City Bank, BRAC Bank, and others). These providers are regulated financial institutions subject to their own data protection and AML obligations.

7.3 Identity Verification & Compliance Services

Third-party KYC, AML screening, and fraud prevention service providers may receive identity and financial data necessary to perform verification checks and compliance screenings on behalf of 5qqq. These providers operate under strict data processing agreements and are not permitted to use your data for their own purposes.

7.4 Legal & Regulatory Authorities

5qqq may disclose personal data to law enforcement agencies, financial intelligence units, regulatory authorities, or courts where required by applicable law, where compelled by a valid legal order, or where 5qqq reasonably suspects that criminal activity has occurred in connection with a player account. Such disclosures will be made only to the extent required or permitted by applicable law.

7.5 Business Transfers

In the event of a merger, acquisition, reorganisation, or sale of all or substantially all of 5qqq's assets, player data may be transferred to the relevant successor entity as part of the transaction. Players will be notified of any such transfer and the privacy implications via the email address registered on their account.

8 Cookies & Tracking Technologies

8.1 What Are Cookies?

Cookies are small text files placed on your device by a website when you visit it. They are widely used to make websites work efficiently, to remember user preferences, and to provide information to the site owner. 5qqq uses cookies and similar technologies (including web beacons and local storage) on its platform.

8.2 Types of Cookies Used by 5qqq

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies that keep you logged into your account and security cookies that help protect against fraudulent login attempts. These cannot be disabled.
• Performance cookies: Used to collect anonymised information about how visitors use the 5qqq website, including which pages are visited most frequently and whether users encounter error messages. This data helps 5qqq improve platform performance.
• Functionality cookies: Used to remember your preferences such as language settings, preferred game categories, and responsible gaming tool configurations so that you receive a more personalised experience each time you visit.
• Analytics cookies: Used by analytics service providers on an anonymised, aggregated basis to help 5qqq understand overall usage trends. Individual players are not identifiable from analytics data.

8.3 Managing Cookies

You may control non-essential cookies through your web browser settings. Most modern browsers allow you to block, delete, or receive warnings before cookies are set. Please note that disabling certain cookies may affect the functionality of the 5qqq platform, particularly features that rely on session data such as maintaining your logged-in state.

9 Data Retention

5qqq retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable legal, regulatory, or contractual obligations. The retention periods applicable to the main categories of data held by 5qqq are outlined below:

• Account and identity data: Retained for a minimum of five (5) years following the closure or permanent suspension of a player account. This retention period is necessary to comply with anti-money-laundering regulations and to support any post-closure investigations or legal proceedings.
• Financial transaction records: Retained for a minimum of seven (7) years in accordance with standard financial record-keeping requirements. This includes all deposit and withdrawal records, bonus transactions, and wagering history.
• Customer support records: Email and live chat correspondence is retained for three (3) years following the resolution of a support interaction, to enable reference in the event of a related future dispute.
• Technical and usage logs: Server log files and technical access data are retained for up to twelve (12) months. Anonymised or aggregated analytics data may be retained indefinitely as it does not constitute personal data.
• Marketing consent records: Records of player consent to receive marketing communications are retained for the duration of the consent and for three (3) years thereafter to demonstrate compliance with consent requirements.

At the expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with 5qqq's data disposal procedures. Securely deleted data cannot be recovered or restored.

10 Data Security

5qqq implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. Key security measures include:

• 256-bit SSL/TLS encryption: All data transmitted between your browser or device and the 5qqq servers is encrypted using industry-standard Transport Layer Security protocols, ensuring that data cannot be intercepted in transit.
• Secure server infrastructure: 5qqq's servers are hosted in certified data centres with physical access controls, redundant power systems, and continuous environmental monitoring.
• Access controls: Access to personal data is restricted on a strict need-to-know basis. All 5qqq staff and contractors who have access to personal data are subject to contractual confidentiality obligations and receive regular data protection training.
• Multi-factor authentication (MFA): Internal system access for 5qqq team members requires MFA. Players are strongly encouraged to enable any available account security features.
• Regular security assessments: 5qqq conducts periodic vulnerability assessments and security audits to identify and remediate potential weaknesses in its infrastructure and application security posture.
• Incident response procedures: 5qqq maintains documented data breach response procedures. In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected players, 5qqq will notify affected individuals without undue delay and in accordance with applicable legal requirements.

11 Your Rights

Subject to applicable data protection law, you have the following rights in relation to the personal data that 5qqq holds about you. To exercise any of these rights, please contact [email protected] with "Privacy Request" in the subject line.

• Right of access: You have the right to request a copy of the personal data that 5qqq holds about you, along with information about how it is being processed. This is commonly referred to as a Subject Access Request (SAR).
• Right to rectification: If any personal data held by 5qqq is inaccurate or incomplete, you have the right to request that it be corrected or completed without undue delay.
• Right to erasure: In certain circumstances, you have the right to request the deletion of your personal data ("right to be forgotten"). This right is subject to limitations where 5qqq is required to retain data for legal, regulatory, or compliance purposes — for example, AML record-keeping requirements will override a deletion request.
• Right to restrict processing: You have the right to request that 5qqq restrict the processing of your personal data in certain circumstances, for example while a dispute about its accuracy is being resolved.
• Right to data portability: Where processing is based on your consent or on the performance of a contract, you have the right to receive a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to object: You have the right to object to processing based on 5qqq's legitimate interests. 5qqq will cease the relevant processing unless it can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
• Right to withdraw consent: Where processing is based solely on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

5qqq will respond to all valid rights requests within 30 calendar days. We will not charge a fee for handling rights requests unless a request is manifestly unfounded, excessive, or repetitive, in which case a reasonable administrative fee may be applied.

12 Children's Privacy

The 5qqq Platform is strictly for adults. 5qqq enforces a minimum age requirement of 21 years for all players accessing the platform from Bangladesh. The Platform is not directed at, and does not knowingly collect personal data from, individuals under the age of 21.

Where 5qqq becomes aware that personal data has been collected from an individual who does not meet the minimum age requirement, it will take immediate steps to delete that data, close the associated account, and refund any deposits made, less any applicable administrative costs. Any winnings accrued will be forfeited.

If you have reason to believe that a minor has registered an account with 5qqq, please notify us immediately at [email protected] so that we can take appropriate action without delay. 5qqq takes underage gambling prevention extremely seriously and cooperates fully with any inquiry related to this issue.

13 International Data Transfers

5qqq operates as an international platform and, as a result, some personal data may be transferred to, stored in, or processed in countries outside of Bangladesh. When such transfers occur, 5qqq ensures that appropriate safeguards are in place to protect your personal data to a standard that is at least equivalent to the protections afforded under applicable data protection law.

Such safeguards may include contractual clauses with third-party processors that impose data protection obligations equivalent to those applicable in Bangladesh, or reliance on the adequacy decisions of relevant data protection authorities where available. By using the 5qqq platform, you acknowledge and consent to the transfer of your personal data on this basis.

Players who have concerns about the international transfer of their personal data are encouraged to contact [email protected] for further information about the specific safeguards in place for any particular transfer.

14 Policy Updates

5qqq reserves the right to update or amend this Privacy Policy at any time. Where a proposed change is material — that is, where it significantly affects the rights of players or the way in which their data is used — 5qqq will provide at least 14 days' advance notice to registered players via the email address on their account before the changes take effect.

Minor updates — such as corrections to typographical errors, clarifications of existing practices that do not change the substance of the Policy, or updates to contact details — may be made without prior notice. The effective date at the top of this Policy will always reflect the date on which the most recent version came into force.

Continued use of the 5qqq Platform following the effective date of any update constitutes your acceptance of the revised Privacy Policy. If you do not agree with any changes, you must discontinue use of the Platform and may request account closure by contacting [email protected].

Previous versions of this Privacy Policy are available upon request by contacting our support team. All archived versions are retained for a minimum of three years following the date on which they were superseded.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the way in which 5qqq processes your personal data, please contact our Data Protection team using the details below. All privacy-related communications should be sent in English.

We are committed to working with you to resolve any privacy concerns fairly and transparently. If after contacting us you remain dissatisfied with our response, you may have the right to lodge a complaint with a relevant data protection authority or supervisory body in your jurisdiction.