Spurt Plus Privacy Policy – How We Handle Your Personal Data

01 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, the data controller responsible for your personal information is Spurt Plus, operating the platform at spurtplus.net.

If you have any questions about how your personal data is handled, or if you wish to exercise any of the rights described in this Privacy Policy, you may contact our Data Protection Officer (DPO) at:

• Email: support@spurtplus.net
• Subject Line: "Privacy / DPO Request"

Spurt Plus aims to acknowledge all privacy-related requests within 48 hours and to provide a substantive response within 15 calendar days.

02 Data We Collect

Spurt Plus collects the following categories of personal data in connection with your use of the platform:

Identity & Contact Data

• Full legal name
• Date of birth
• Gender (where provided voluntarily)
• Mobile number and email address
• Residential address

Verification Data

• Government-issued ID details (e.g., PhilSys ID, passport, driver's licence, UMID, SSS/GSIS ID)
• Selfie or liveness check images used for identity verification
• Source of funds documentation where required by anti-money laundering regulations

Financial Data

• GCash or Maya account number (used for deposit/withdrawal matching)
• Bank account details for BDO, BPI, UnionBank, and other PH banks
• Transaction history within your Spurt Plus account
• Deposit amounts, withdrawal requests, and payment method references

Technical & Usage Data

• IP address and device type
• Browser type and operating system
• Pages visited, features used, and session duration on Spurt Plus
• Login timestamps and geolocation data (where you grant permission)

Gaming Activity Data

• Bets placed, games played, and results
• Bonus activation and wagering history
• VIP Club points accumulation and redemption
• Responsible gaming settings and limit history

03 How We Collect Your Data

Spurt Plus collects personal data through the following channels:

• Registration Form: When you sign up for a Spurt Plus account, you provide your name, contact details, date of birth, and chosen login credentials.
• Identity Verification: When you verify your account, you upload identity documents and complete liveness checks through our verification partner.
• Deposits and Withdrawals: When you transact through GCash, Maya, or a Philippine bank, your payment reference details are recorded by Spurt Plus for account matching and audit purposes.
• Platform Use: When you browse and play on Spurt Plus, our servers automatically log technical and usage data including your IP address, device information, and navigation patterns.
• Cookies and Tracking Technologies: Spurt Plus uses cookies and similar technologies on the platform. Full details are in Section 9 (Cookies & Tracking).
• Support Interactions: When you contact our support team via live chat or email, the content of those communications is recorded for quality assurance, dispute resolution, and regulatory compliance.
• Promotions and Surveys: If you participate in a promotion or voluntary survey on Spurt Plus, any information you provide in that context is collected and processed according to this policy.

04 Why We Use Your Data

Spurt Plus uses your personal data for the following purposes:

Spurt Plus does not use your personal data for any purpose not listed above without first notifying you and, where required, obtaining your consent.

05 Legal Basis for Processing

Under the Philippine Data Privacy Act, Spurt Plus processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to provide the services described in our Terms and Conditions — including account management, payment processing, and game provision.
• Legal Obligation: Processing required to comply with Philippine laws, including anti-money laundering regulations, gaming licence conditions, and tax reporting requirements.
• Legitimate Interest: Processing carried out for fraud prevention, platform security, and service improvement, where these interests do not override your privacy rights.
• Consent: Marketing communications and optional data processing activities where consent is explicitly obtained. You may withdraw this consent at any time without affecting your ability to use Spurt Plus.

06 Data Sharing

Spurt Plus shares your personal data with third parties only in the following limited circumstances, and only to the extent necessary for each purpose:

• Payment Processors: GCash, Maya, InstaPay/PESONet network participants, and card payment gateways receive the minimum transaction data needed to process your deposit or withdrawal.
• Identity Verification Providers: Our KYC (Know Your Customer) verification partner receives identity documents and biometric check data solely for the purpose of verifying your identity. This provider operates under strict contractual data protection obligations.
• Regulatory Authorities: Spurt Plus may be legally required to disclose player information to the relevant Philippine gaming regulator, anti-money laundering authorities, or law enforcement agencies. Spurt Plus will comply with lawful requests and will notify you unless legally prohibited from doing so.
• Technology Service Providers: Hosting, analytics, customer support, and fraud detection services that support the Spurt Plus platform. These providers are engaged under data processing agreements that restrict their use of your data to providing services to Spurt Plus exclusively.

07 International Data Transfers

Some of the third-party service providers used by Spurt Plus may process personal data outside the Philippines. Where this occurs, Spurt Plus ensures that appropriate safeguards are in place, including:

• Contractual clauses that require the recipient to protect personal data to standards equivalent to Philippine law
• Transfer only to jurisdictions with an adequate level of data protection as recognised by the NPC
• Binding corporate rules where the recipient is part of a group with approved internal data protection standards

If you would like information about the specific safeguards applied to international transfers involving your data, contact our DPO at the address in Section 1.

08 Data Retention

Spurt Plus retains your personal data for as long as your account is active and for a period after closure as required by Philippine law and our regulatory obligations. The following general timelines apply:

• Active account data: Retained for the duration of your account.
• Financial transaction records: Retained for a minimum of 5 years after the date of the transaction, in line with Philippine AML regulations.
• Identity verification documents: Retained for a minimum of 5 years after account closure.
• Customer support records: Retained for 3 years after the close of the relevant support interaction, unless the matter is subject to ongoing legal proceedings.
• Marketing consent records: Retained for the period your consent is active, plus 1 year after withdrawal of consent.
• Technical logs: Retained for 12 months on a rolling basis, unless required for an ongoing investigation.

Once the applicable retention period expires, personal data is securely deleted or anonymised so that it can no longer be associated with your identity.

09 Cookies & Tracking Technologies

Spurt Plus uses cookies and similar tracking technologies on the platform. These are small data files stored on your device that help us deliver a functional and personalised experience.

Types of Cookies We Use

Spurt Plus does not use advertising or third-party marketing cookies. You can manage non-essential cookie preferences through the cookie settings panel accessible from the platform footer. Note that disabling essential cookies will affect your ability to use the platform.

10 Security Measures

Spurt Plus implements a comprehensive set of technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or loss:

• TLS Encryption: All data transmitted between your device and Spurt Plus is encrypted in transit using Transport Layer Security (TLS 1.2 or higher).
• Encryption at Rest: Sensitive stored data — including payment references and identity documents — is encrypted at rest using AES-256.
• Access Controls: Access to personal data is restricted to authorised staff on a strict need-to-know basis, enforced through role-based access control (RBAC).
• Two-Factor Authentication (2FA): Spurt Plus supports 2FA for player accounts and requires it for all staff with access to player data systems.
• Penetration Testing: Our platform and data systems undergo regular third-party security assessments and penetration testing.
• Incident Response: Spurt Plus maintains a documented data breach response procedure. In the event of a breach that affects your rights and freedoms, we will notify you and the National Privacy Commission (NPC) within the timeframes required by law.

While Spurt Plus takes all reasonable precautions, no online platform can guarantee 100% security. We encourage you to use a strong, unique password for your Spurt Plus account and to enable two-factor authentication.

11 Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by Spurt Plus. These rights can be exercised by contacting our DPO at the address in Section 1.

Spurt Plus will not charge a fee for exercising these rights in normal circumstances. If a request is manifestly unfounded or excessive, we reserve the right to charge a reasonable administrative fee or decline the request, providing written reasons in either case.

12 Minors

Spurt Plus is strictly an adults-only platform. The minimum age to register is 21 years, in line with Philippine gaming regulations. Spurt Plus does not knowingly collect personal data from individuals under the age of 21.

If you believe that a minor has registered on Spurt Plus or has provided us with personal data, please contact our DPO immediately at support@spurtplus.net. We will promptly investigate and, if confirmed, close the account and securely delete the associated data.

13 Policy Changes

Spurt Plus reviews this Privacy Policy regularly and will update it to reflect changes in our data practices, legal requirements, or platform features. When material changes are made:

• We will update the "Last Updated" date at the top of this page.
• We will notify registered players via email and in-platform notification at least 14 days before the changes take effect.
• Where a change materially affects how we use your data, we will seek fresh consent where legally required.

Your continued use of Spurt Plus after the effective date of any update constitutes your acknowledgment of the revised Privacy Policy. If you disagree with changes, you may close your account by contacting support.

14 Contact & Complaints

For any privacy-related queries, data subject requests, or concerns about how Spurt Plus handles your personal data, contact our Data Protection Officer:

• Email: support@spurtplus.net
• Subject Line: "Privacy / DPO Request"
• Response Time: Acknowledgement within 48 hours; substantive response within 15 calendar days

If you are not satisfied with Spurt Plus's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). The NPC is the Philippine government body responsible for enforcing the Data Privacy Act and can be reached through their official website.