Privacy Policy – 5161vip: Transparency and Data Protection

5161vip is a digital entertainment platform exclusively serving the Brazilian market, offering online casino games, Sports Betting on events such as football (Brasileirão Série A, Copa do Brasil, and Libertadores), UFC, basketball (NBB), volleyball, and e-sports, as well as slots, blackjack, roulette, and poker.

This Policy applies to all personal data collected at any point of contact with 5161vip, including:

• The main website at https://5161vip.best and all its pages and subsections;
• The registration and identity verification process;
• Financial transactions made via Pix, boleto bancário, credit/debit card, Mercado Pago, PicPay, and TED bank transfer;
• Support communications via live chat, email, or WhatsApp;
• Participation in promotions, welcome bonuses, and loyalty programs.

The controller of personal data processed under this Policy is 5161vip, responsible for decisions regarding the purpose and means of data processing described in this document.

5161vip collects personal data at various points during your interaction with the platform. Below is a full description of the categories of data processed:

5161vip does not collect special categories of sensitive personal data — such as health data, racial or ethnic origin, religious beliefs, or sexual orientation — except where strictly necessary to comply with specific legal obligations (such as identifying vulnerability in a responsible gambling context, based on the User's explicit consent).

Personal data collected by 5161vip is used exclusively for the following purposes:

• Account creation and management: Identity verification at registration, access authentication, profile management, and account settings;
• Service delivery: Processing of Sports Betting, casino games, slots, and other bet types; crediting of balances, welcome bonuses, and cashback; transaction history;
• Financial processing: Processing of deposits via Pix, boleto, credit/debit card, Mercado Pago, and PicPay; processing of withdrawals via Pix to accounts at Nubank, Itaú, Bradesco, Banco do Brasil, and other Brazilian banks;
• Fraud prevention and regulatory compliance: Eligibility verification, anti-money laundering, detection of multiple-account use, and compliance with legal obligations;
• Customer support: Resolving questions, complaints, and requests submitted via live chat, e-mail, or WhatsApp;
• Responsible gaming: Monitoring usage patterns to identify risky behavior and activating protection tools where applicable;
• Marketing communications: Sending information about promotions, new games, and personalized offers, exclusively with your express consent and with the option to unsubscribe at any time;
• Platform improvement: Analysis of aggregated, anonymized data to improve the player experience, resolve technical issues, and develop new features.

5161vip does not use your data for purposes incompatible with those listed above without obtaining fresh consent or a proper legal basis under the LGPD.

As required by the LGPD, every instance of personal data processing carried out by 5161vip has a specific legal basis. The legal bases used are:

• Contract performance (art. 7, V of the LGPD): Processing required to deliver the services contracted by the User upon creating an account at 5161vip, including handling BRL deposits and withdrawals;
• Compliance with a legal or regulatory obligation (LGPD, art. 7, II): Identity verification (KYC), anti-money laundering, financial record retention, and compliance with court orders;
• Legitimate exercise of rights (art. 7, VI of the LGPD): Defense in judicial, administrative, or arbitration proceedings and response to consumer complaints;
• Consent (art. 7, I of the LGPD): Sending marketing communications by email, SMS, or WhatsApp; use of non-essential cookies; collection of sensitive data in specific responsible gambling contexts;
• Legitimate interest (Art. 7, IX of the LGPD): Fraud detection, platform security, and aggregated usage analysis to improve our services — always respecting Users' rights and expectations.

5161vip may share Users' personal data with third parties in the following specific situations and always with appropriate safeguards in place:

• Brazilian payment providers: Financial institutions and fintechs that process transactions via Pix, boleto bancário, credit/debit card, Mercado Pago, and PicPay. Sharing is limited to the minimum necessary to complete the financial transaction;
• Game providers: Development studios such as Pragmatic Play, NetEnt, and others that supply the casino games and Slots available on the platform. These providers receive only the technical data required for the game to function;
• Identity verification services: Specialized KYC (Know Your Customer) companies that assist with document verification and fraud prevention;
• Technology infrastructure: Server, CDN, and security providers that host and protect the 5161vip platform, always under confidentiality and data protection agreements;
• Public authorities: When required by law, court order, or determination of a competent regulatory authority. 5161vip only shares data with authorities upon a formal legal requirement;
• Fraud prevention: In cases of suspected money laundering or criminal activity, data may be shared with financial regulatory authorities in accordance with applicable Brazilian law.

5161vip contractually requires all third parties that receive Users' personal data to maintain the same security and confidentiality standards adopted by the platform. No data is sold, rented, or transferred to third parties for advertising or external commercial purposes.

5161vip applies a robust set of technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, alteration, or improper disclosure.

The main security measures in place include:

• Encryption in transit: All communications between your device and 5161vip's servers are protected by TLS 1.3 with a 256-bit SSL certificate;
• Encryption at rest: Sensitive data stored on servers — including identity documents, financial information, and passwords (stored as irreversible hashes) — is encrypted;
• Access control: Only 5161vip staff and systems with a justified operational need have access to personal data, always with a full audit trail;
• Two-factor authentication: Available to all Users and required for internal administrative operations;
• Continuous monitoring: Intrusion detection systems and 24-hour monitoring to identify suspicious activity;
• Security testing: Regular penetration testing and security audits conducted by independent firms;
• Incident response plan: A documented procedure for responding to security incidents, including notification to the National Data Protection Authority (ANPD) and affected Users as required by the LGPD.

5161vip's servers are hosted in data centers with physical and logical security certification, with geographic redundancy to ensure continuous platform availability.

5161vip uses cookies and similar technologies to ensure the platform works properly, improve the User experience, and — with your consent — personalize content and analyze site usage.

The types of cookies used are:

• Strictly necessary cookies: Essential for the platform's basic functionality — such as maintaining your logged-in session, processing bets, and security. These do not require consent, as the services cannot function without them;
• Performance cookies: These collect information about how Users interact with the platform (pages visited, errors encountered, load times) in an aggregated and anonymous form, in order to improve technical performance;
• Functionality cookies: They remember your preferences – such as language, betting settings, and preferred layout – for a more personalized experience on future visits;
• Analytical cookies: With your consent, these allow us to understand platform usage patterns at an aggregate level, supporting the development of new features and the improvement of our games and slots catalog.

You can manage your cookie preferences at any time through the consent banner shown on your first visit or through your browser settings. Disabling non-essential cookies does not affect access to the platform's core features.

The LGPD guarantees you, as the data subject whose personal data is processed by 5161vip, the following rights, which may be exercised at any time:

5161vip retains your personal data for as long as necessary to fulfill the purposes described in this Policy or as required by applicable Brazilian law. The specific retention periods are:

• Active account data: For as long as the account remains active on the platform;
• Financial and transaction data: A minimum of 5 (five) years following the completion of the transaction, as required by Brazilian tax legislation and anti-money laundering regulations;
• Support communication records: 2 (two) years after the support interaction is closed;
• Identity verification data (KYC): 5 (five) years after account closure, as required by regulation;
• Betting and gaming data: 5 (five) years, in accordance with legal obligations and potential transaction disputes;
• Data processed solely on the basis of consent: Until consent is withdrawn or deletion is requested by the User.

Once the applicable retention period expires, data is securely deleted or anonymized in a way that makes re-identification of the User impossible. Anonymized data may be retained for statistical purposes and platform improvement with no time limit.

5161vip's services are intended exclusively for individuals aged 18 (eighteen) or older. 5161vip does not intentionally collect personal data from minors and does not allow minors to register or use the platform.

If we determine that data belonging to a person under 18 was collected without the knowledge of their legal guardians, we will take the following immediate steps:

• Immediate closure of the account associated with the minor;
• Secure deletion of all collected personal data;
• Refund of any deposited amounts to the verified legal guardian, where applicable;
• Notification to the relevant authorities, where applicable.

Legal guardians who suspect their minor child has created an account at 5161vip should contact our support team immediately at contato@5161vip.best or via live chat so that the measures above can be taken as quickly as possible.

Although 5161vip is a platform designed exclusively for the Brazilian market, some of our technology partners and game providers have infrastructure located outside Brazil. In such cases, international transfers of personal data take place in compliance with Articles 33 to 36 of the LGPD.

Safeguards in place for international data transfers include:

• Data transfer agreements containing protection clauses equivalent to those required by the LGPD;
• Transfers only to countries or international organizations that provide an adequate level of personal data protection, as assessed by the ANPD;
• Use of specific contractual instruments approved by the ANPD where applicable.

The list of countries and organizations to which your data may be transferred internationally can be requested by e-mail at contato@5161vip.best. 5161vip is committed to informing you of any new international transfer involving categories of data not covered by this Policy.

5161vip may update this Privacy Policy periodically to reflect changes in our data processing practices, updates to Brazilian data protection law, or modifications to the services offered on the platform.

When we make significant changes, you will be notified via:

• A prominent notice on the platform upon your next login;
• Email sent to the address registered to your 5161vip account;
• Updating the "Last updated" date in the header of this Policy.

5161vip has appointed a Data Protection Officer (DPO) responsible for overseeing LGPD compliance, responding to data subject requests, and serving as the communication channel with the Autoridade Nacional de Proteção de Dados (ANPD).

To contact the DPO or exercise any right under the LGPD, please use the following channels:

• Primary e-mail: contato@5161vip.best (subject line: "Privacy / DPO");
• Live chat: Available directly on the 5161vip platform, 24 hours a day, 7 days a week;
• General support: For non-urgent privacy matters, 5161vip's customer support team can assist and escalate to the DPO when needed.

5161vip is committed to responding to personal data requests within 15 (fifteen) calendar days of receipt, as established by the LGPD. For complex requests requiring additional review, we will inform you of the extended timeframe needed and the reason for it.

For complaints not resolved through the channels above, you may contact the Autoridade Nacional de Proteção de Dados (ANPD) via the official Brazilian federal government website.