Privacy Policy

Introduction

the5rs ("we", "us", "our", "Platform") is committed to protecting the privacy and personal data of all individuals who access and use our website at https://the5rs.cam ("Platform"). This Privacy Policy ("Policy") explains how we collect, use, store, share and protect your personal data, and sets out your rights in relation to that data.

This Policy applies to all Users of the Platform, including visitors who browse without registering an account and registered account holders. It covers personal data collected through: direct interactions with our website; automated technologies such as cookies and analytics tools; and any communications you send to us.

This Policy should be read in conjunction with our Terms and Conditions, which govern your general use of the Platform and are incorporated herein by reference. By accessing or using the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

Definitions

The following definitions apply throughout this Policy:

Data Controller Identity

For the purposes of this Policy, the Data Controller in respect of personal data collected through the Platform is the5rs, operating the website at https://the5rs.cam.

the5rs is an English-language online betting and casino information platform. We are not a casino, sportsbook, payment processor or financial institution. We do not accept, hold or transmit player funds, nor do we process gambling transactions on behalf of any user. Our data processing activities relate exclusively to the operation and improvement of this information Platform.

Contact details for data protection enquiries are provided in Section 17 of this Policy.

Categories of Personal Data We Collect

We collect the following categories of personal data from Users of the Platform:

4.1 — Identity & Contact Data

• Full name (where provided during registration or contact form submissions);
• Email address (for account registration, newsletter subscription or support communications);
• Username or display name chosen during account creation.

4.2 — Technical & Usage Data

• Internet Protocol (IP) address;
• Browser type and version;
• Operating system and device type (e.g., Android smartphone, Windows desktop — common device types among users in Karachi, Lahore and other Pakistani cities);
• Pages visited, time spent on pages, click paths and scroll depth;
• Referring URL and exit URL;
• Session duration and frequency of visits;
• Error logs and diagnostic data.

4.3 — Preference & Interaction Data

• Cookie preferences and consent choices;
• Language and display preferences saved to your account or browser;
• Content bookmarks or saved guides (where such functionality is offered).

4.4 — Communications Data

• Content of messages submitted through our support or contact channels;
• Support ticket history and correspondence records;
• Feedback, survey responses and other voluntary submissions.

How We Collect Personal Data

We collect personal data through the following channels:

• Direct interactions: When you create an account, subscribe to updates, contact our support team or submit any form on the Platform, you provide us with personal data directly.
• Automated technologies: When you visit the Platform, we automatically collect technical and usage data through cookies, server logs, pixel tags and similar technologies. This collection occurs whether or not you are logged in to an account.
• Analytics providers: We use third-party web analytics services (such as aggregated traffic analysis tools) to understand how Users interact with the Platform. These services may set their own cookies and collect usage data subject to their own privacy policies.
• Third-party sources: In limited circumstances, we may receive data about you from third parties — for example, technical security providers who flag suspicious access patterns to our Platform. We do not purchase marketing lists or receive personal data from gambling operators.

Purposes of Processing

We process personal data for the following stated purposes only:

We do not use personal data for purposes incompatible with those listed above without first providing notice and, where required by law, obtaining fresh consent.

Legal Basis for Processing

Our processing of personal data is conducted on one or more of the following legal bases:

• Consent: Where you have given clear, informed and freely given consent for a specific processing activity — for example, subscribing to marketing communications or accepting non-essential cookies. You may withdraw consent at any time without detriment to your general use of the Platform.
• Contract performance: Where processing is necessary to fulfil our obligations under an agreement with you — for example, managing your registered account or responding to a support request you have submitted.
• Legitimate interests: Where processing is necessary for purposes we have assessed as not overriding your fundamental privacy rights — including Platform security, fraud prevention, product improvement and internal analytics. You may object to processing on this basis in accordance with Section 12.
• Legal obligation: Where processing is required to comply with applicable law — for example, retaining records in response to a lawful enforcement request or meeting data protection compliance obligations.

Data Sharing & Disclosure

the5rs does not sell, rent or trade your personal data to any third party for commercial purposes. We do not share personal data with gambling operators, payment providers or advertisers as a standard business practice.

We may share personal data with the following limited categories of recipients:

• Service providers and Data Processors: Third-party providers who process data strictly on our documented instruction and for no other purpose — including web hosting providers, analytics platforms, email delivery services and security monitoring tools. All such providers are bound by data processing agreements consistent with applicable data protection law.
• Legal and regulatory authorities: Where we are required by applicable law, court order, or a lawful request from a competent public authority (including law enforcement) to disclose personal data. We will notify you of such requests where legally permissible.
• Business transfer: In the event of a merger, acquisition, asset sale or restructuring of the5rs, personal data may be transferred to the successor entity. You will be notified before your personal data becomes subject to a different privacy policy.

International Data Transfers

Some of our service providers are located outside Pakistan. Where personal data is transferred to countries that may not provide the same level of data protection as Pakistan, we implement appropriate safeguards including:

• Contractual clauses in our data processing agreements requiring recipient parties to maintain protections equivalent to those described in this Policy;
• Selection of service providers who operate under internationally recognised data protection frameworks;
• Technical measures including encryption in transit and at rest.

By using the Platform, you acknowledge that your personal data may be processed in jurisdictions outside Pakistan. We take reasonable steps to ensure that cross-border transfers are conducted with appropriate safeguards in place.

Data Retention

We retain personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our general retention standards are as follows:

• Account data: Retained for the duration of your active account, plus a reasonable period following account closure to address any outstanding support queries or legal obligations.
• Support communications: Retained for up to 24 months from the date of last correspondence to support follow-up enquiries and quality assurance.
• Technical and usage data: Anonymised or aggregated after a maximum of 26 months from collection. Raw log data is retained for shorter periods consistent with security and debugging requirements.
• Marketing consent records: Retained for the duration of the marketing relationship plus a period sufficient to demonstrate consent compliance if required.
• Legal hold data: Where we are subject to a legal obligation to retain specific data, we retain it for the period specified by the applicable law or authority, after which it is deleted.

When data is no longer required, we securely delete or anonymise it using industry-standard procedures. You may request earlier deletion in accordance with your rights under Section 12.

Security Measures

We implement a range of technical and organisational security measures to protect personal data against unauthorised access, loss, alteration or disclosure:

• Encryption in transit: All data transmitted between your browser and the Platform is encrypted using TLS (Transport Layer Security). Users should verify the padlock indicator in their browser address bar.
• Encryption at rest: Stored personal data is encrypted using industry-standard algorithms.
• Access controls: Personal data access is restricted to authorised personnel on a need-to-know basis. Role-based access controls and authentication requirements are enforced.
• Security monitoring: We employ automated and manual monitoring tools to detect and respond to suspicious activity, intrusion attempts and data anomalies.
• Incident response: We maintain documented procedures for responding to personal data breaches, including notification to affected users and, where applicable, competent authorities within the timescales required by law.

Your Data Protection Rights

You have a range of rights in relation to your personal data. The availability and scope of these rights may vary depending on the legal basis for processing and the applicable law in your jurisdiction. We are committed to facilitating the exercise of these rights promptly and without undue obstacle.

To exercise any of the above rights, please contact us using the details in Section 17. We will respond to all valid requests within a reasonable timeframe — generally within 30 days — and will not charge a fee for reasonable requests.

Cookies & Tracking Technologies

the5rs uses cookies and similar tracking technologies to improve the functionality and performance of the Platform. The categories of cookies we use are as follows:

• Strictly necessary cookies: Essential for the basic operation of the Platform — for example, maintaining session state, security tokens and your cookie consent preferences. These cookies cannot be disabled without significantly impairing Platform functionality.
• Analytics cookies: Used to collect aggregated data about how Users interact with the Platform — including which pages are visited most frequently and how long Users spend on each section. This data helps us improve content relevance and navigation. We use anonymised or pseudonymised data wherever possible.
• Preference cookies: Store your chosen Platform settings such as display preferences, so these do not need to be reselected on each visit.
• Marketing cookies: Where you have given explicit consent, we may use cookies to deliver relevant promotional content. We do not use marketing cookies to serve gambling advertisements to you on third-party websites.

You can manage your cookie preferences through your browser settings. Instructions for the most common browsers — Chrome, Firefox, Safari and Edge — are available in those browsers' help documentation. Please note that disabling certain cookies may affect the functionality of the Platform.

Minors' Privacy

The Platform and all gambling-related content it contains is strictly intended for users aged 18 or older — or the higher minimum age required by the applicable operator's licence jurisdiction. We do not knowingly collect, process or retain personal data from individuals under the applicable minimum age.

If you are a parent or guardian and believe that a minor has provided personal data to us without appropriate consent, please contact us immediately at the address provided in Section 17. We will take prompt steps to verify the concern and, where confirmed, delete the relevant data without undue delay.

Specific Notice for Pakistani Users

The primary audience of this Platform is users based in Pakistan — including users in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar and other cities and regions across the country.

Pakistan does not currently have a comprehensive, standalone personal data protection law of general application analogous to the GDPR; however, data protection principles are reflected in various Pakistani statutes including the Pakistan Telecommunication (Re-organisation) Act 1996, the Electronic Transactions Ordinance 2002, and the Prevention of Electronic Crimes Act 2016 (PECA). The Personal Data Protection Bill, when enacted, will impose more comprehensive obligations on data controllers operating in or targeting Pakistan.

We are committed to processing personal data of Pakistani users responsibly and in accordance with the principles described in this Policy, regardless of the current legislative framework. We do not share personal data with the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan or any other Pakistani government body except where required by lawful and documented legal obligation.

Amendments to This Policy

We reserve the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or the operational structure of the Platform. The effective date shown at the top of this page will be updated with each revision.

Where changes are material — meaning they affect your rights or our obligations in a substantive way — we will provide a prominent notification on the Platform homepage for a minimum of 14 days prior to the changes taking effect.

Your continued use of the Platform after any amendment to this Policy constitutes acceptance of the revised terms. If you do not accept the revised Policy, please cease use of the Platform and, if you hold an account, contact us to request account closure and data deletion.

Contact Us — Data Protection Enquiries

For all data protection enquiries, requests to exercise your rights, or complaints regarding the handling of your personal data, please contact us using the details below. All communications should be in English. We aim to respond to all data-related requests within 30 calendar days.