5pcom Privacy Policy — Your Data, Protected

1Who We Are — Data Controller

The 5pcom is the online casino and Sports Betting platform available at 5pcom.click, operated with an exclusive focus on the Brazilian market. For the purposes of the LGPD (Law No. 13.709/2018), 5pcom acts as controller of personal data collected from users who register and use the platform's services.

As the data controller, 5pcom is responsible for all decisions regarding the processing of users' personal data — defining the purpose, means, and duration of processing, always in compliance with applicable Brazilian law.

2What Personal Data We Collect

The 5pcom only collects the data necessary to provide its services properly, securely, and in compliance with legal obligations. The data collected falls into the following categories:

2.1 Registration Data

• Full name
• Date of birth
• CPF (Cadastro de Pessoa Física)
• Email address
• Full residential address (street, number, ZIP code, city, state)
• Mobile number
• Access password (stored in encrypted form — 5pcom does not have access to your password in plain text)

2.2 Identity Verification Data (KYC)

• Government-issued ID (RG, CNH, or passport)
• Proof of address
• Selfie with ID document for biometric verification, when requested
• Proof of ownership of the payment method, where applicable

2.3 Financial Data

• Pix key linked to the account (CPF, email, phone number, or random key)
• Partial credit or debit card details (last 4 digits and card brand only — 5pcom does not store full card numbers)
• History of deposits and withdrawals made on the platform
• Current account balance

2.4 Usage and Browsing Data

• IP address
• Device type and operating system (Android phone, iPhone, desktop)
• Browser used
• Pages visited and time spent
• Betting and gaming history
• Date and time of platform access
• Cookie and similar technology data (detailed in Section 7)

3How We Collect Your Data

The 5pcom collects personal data through the following means:

• Directly by you: at the time of registration, profile updates, KYC document submission, support interactions, or participation in promotions.
• Automatically: while browsing the platform, through cookies, tracking pixels, and server logs — recording technical information about platform usage.
• From third parties: from payment processors such as Pix operators, credit card networks, PicPay, and Mercado Pago, which confirm transaction data; and from identity verification tools used in the KYC process.

When providing third-party data (such as referring a friend), you confirm that you have obtained that person's consent to share their information with 5pcom.

4How We Use Your Data

Each piece of data collected by 5pcom has a specific, declared purpose. The table below summarizes the main purposes of use:

5pcom does not use your personal data for purposes not stated in this Policy or for which you have not given consent, where consent is the applicable legal basis.

5Legal Basis for Processing (LGPD)

Every data processing operation carried out by 5pcom has a legal basis provided for under the LGPD. The legal bases used are:

• Performance of a contract (art. 7, V): processing required to perform the service agreement entered into between you and 5pcom when you create your account — such as processing deposits via Pix, recording bets, and making games available.
• Compliance with a legal or regulatory obligation (art. 7, II): processing required by law, such as identity verification (KYC) and anti-money laundering obligations imposed by Brazilian financial legislation.
• Consent (art. 7, I): for purposes such as sending promotional communications by email or SMS. You may withdraw consent at any time, without affecting the validity of any processing carried out prior to that withdrawal.
• Legitimate interest (art. 7, IX): for activities such as improving our services, analyzing platform usage, and preventing fraud, provided that your fundamental rights and freedoms do not override this interest.
• Credit protection (art. 7º, X): where applicable, for risk analysis in financial transactions carried out on the platform.

6Data Sharing with Third Parties

The 5pcom does not sell users' personal data. Data sharing with third parties only occurs in the situations described below, always with the necessary contractual safeguards:

6.1 Essential Operational Partners

• Payment processors: data required to process deposits and withdrawals via Pix, boleto bancário, credit or debit card, PicPay, Mercado Pago, and TED transfers (Nubank, Itaú, Bradesco, Banco do Brasil, Caixa, and other banks).
• Game providers: minimum technical data required to operate slots, Live Casino, and other titles provided by partners such as Pragmatic Play, NetEnt, Play'n GO, and other providers registered on the platform.
• Identity verification services: documentation data submitted during the KYC process is handled by specialized, certified vendors authorized for that purpose.
• Analytics tools and infrastructure: technology services used for platform operations, security, and performance analysis — always governed by appropriate data protection agreements.

6.2 Legal obligations

5pcom may share data with public authorities, regulatory bodies, and government agencies when required by law, court order, or official request from a competent authority — including the Financial Activities Control Council (COAF) and other bodies with oversight of betting activities in Brazil.

7Cookies and Tracking Technologies

The 5pcom uses cookies and similar technologies to improve the browsing experience, keep your account secure, and understand how users interact with the platform. The types of cookies used are:

7.1 Essential cookies

Required for the platform's basic functionality — such as keeping your session active after login, remembering language preferences, and ensuring transaction security. They cannot be disabled without affecting how the site works.

7.2 Performance and analytics cookies

They collect aggregated information about how users navigate 5pcom — which pages are most visited, how much time is spent in each section, and which features are used most. This data is used to improve the platform experience. They can be disabled in browser settings with no impact on core functionality.

7.3 Personalization cookies

They allow 5pcom to deliver personalized experiences — such as displaying games and promotions most relevant to you based on your usage history. They require your consent, which can be withdrawn at any time.

To manage your cookie preferences, use your browser settings (Chrome, Firefox, Safari, etc.) or access the privacy settings available in your 5pcom account.

8Data Security

The 5pcom implements appropriate technical and organizational measures to protect users' personal data against unauthorized access, alteration, disclosure, loss, or destruction. The main security measures in place include:

• 256-bit SSL/TLS encryption across all communications between the user's browser and 5pcom's servers.
• Hashed password storage using secure algorithms — 5pcom does not store passwords in plain text and has no access to your original password.
• Two-factor authentication (2FA) available as an additional layer of security for account login.
• Continuous monitoring of suspicious activity on the platform, with automated systems for detecting fraud and unauthorized access.
• Restricted access to personal data, limited to the employees and systems that require this information to perform their functions.
• Regular security testing and vulnerability audits carried out by the technical team and specialized partners.

Despite the measures in place, no security system is foolproof. In the event of a security incident affecting your personal data, 5pcom is committed to notifying you and taking the necessary corrective actions in a transparent manner and within the legal timeframes.

9Data Retention and Deletion

The 5pcom retains users' personal data for as long as necessary to fulfill the purposes for which it was collected, in compliance with applicable legal retention periods:

• Registration and active account data: retained for as long as the account remains active and for the period required after closure to fulfill legal obligations.
• Financial and transaction data: retained for a minimum of 5 (five) years after the transaction, as required by Brazilian anti-money laundering regulations and tax obligations.
• KYC documents: retained for the period required by the regulations applicable to the betting sector in Brazil, generally 5 to 10 years.
• Browsing data and cookies: depending on the applicable technical configuration for each category, generally ranging from 30 days to 2 years.
• Support communications: retained for 5 years for dispute resolution and service improvement purposes.

Once the applicable retention period has ended, data is anonymized or securely deleted in a way that makes it impossible to recover or link back to the data subject.

10Your Rights as a Data Subject

The LGPD grants personal data subjects a set of rights that 5pcom is fully committed to upholding. You may exercise these rights at any time by emailing contato@5pcom.click or through the platform's live chat:

5pcom is committed to responding to data subject rights requests within 15 (fifteen) business days of receipt. In more complex cases, this deadline may be extended by an equal period, with notice provided to the requester.

11Minors

The 5pcom is a platform exclusively intended for users aged 18 (eighteen) and over. We do not intentionally collect personal data from minors. If we identify that a user is under 18, the account will be immediately closed and all collected data will be deleted, as set out in our Terms and Conditions.

If you are the guardian of a child or teenager and believe they have accessed 5pcom or submitted personal data to the platform, please contact us immediately at contato@5pcom.click so the necessary steps can be taken as a priority.

12International Data Transfers

To operate the platform, some data may be processed on technology infrastructure located outside Brazil — such as cloud servers provided by international providers. When this occurs, 5pcom ensures that the transfer is carried out with the appropriate safeguards required by the LGPD, including:

• Specific data protection contractual clauses with international service providers.
• Selection of service providers that adopt security standards equivalent to or higher than those required by Brazilian law.
• Transfers only to countries or organizations with an adequate level of data protection, as assessed by the ANPD where available.

5pcom's partner game providers are internationally recognized companies in the industry, with established data protection policies and subject to regular audits by independent certification bodies.

13Changes to this Privacy Policy

The 5pcom may periodically update this Privacy Policy to reflect changes in data processing practices, applicable legislation, or the services offered. The date of the most recent update is always indicated at the top of the document.

Material changes that affect user rights will be communicated by email at least 7 (seven) days before taking effect. For minor or purely technical changes, the update may be published directly on the platform without prior individual notification.

Continued use of the platform after changes take effect constitutes acceptance of the new terms. If you disagree with any change, you may request account closure before the effective date by following the process described in the 5pcom Terms and Conditions.

14Data Processing Officer (DPO)

In compliance with the LGPD, 5pcom has appointed a Personal Data Processing Officer (DPO — Data Protection Officer). The DPO serves as the communication channel between 5pcom, data subjects, and the National Data Protection Authority (ANPD).

The Data Protection Officer has the following responsibilities at 5pcom:

• Receiving and responding to communications from data subjects and the ANPD regarding matters related to the processing of personal data.
• Guide the internal team on proper data protection practices in accordance with the LGPD.
• Carrying out actions determined by the ANPD.
• Promote a data protection culture within the organization.

To contact the 5pcom Data Protection Officer, send an email to contato@5pcom.click with the subject line "DPO — Data Protection". You will receive a response in Portuguese within the timeframe set out by the LGPD.

15Contact and Complaints Channel

For any questions, requests, or complaints related to this Privacy Policy or the processing of your personal data by 5pcom, use the channels below:

• Privacy email: contato@5pcom.click — subject line "Data Privacy"
• Live Chat: available 24 hours a day, 7 days a week, directly on the platform after logging in
• Frequently Asked Questions: visit 5pcom.click/faq for privacy and data protection inquiries

If your request is not satisfactorily resolved by 5pcom, you have the right to file a complaint with the National Data Protection Authority (ANPD), the Brazilian government authority responsible for enforcing the LGPD, through the official channels available on the federal government portal.