plusph11 Privacy Policy

1. Introduction & Scope

This Policy applies to all personal data collected by plusph11 in connection with the operation of the Platform, including data collected through account registration, identity verification, financial transactions, gameplay activity, customer support interactions, and use of the plusph11 website and mobile interface. It applies to all registered players, prospective players who browse the Platform without registering, and individuals who contact plusph11 via any communication channel.

This Policy does not apply to third-party websites, services, or applications that may be linked to or from the Platform. plusph11 is not responsible for the privacy practices of such third parties, and we encourage you to review the privacy policies of any external service you access.

2. Data Controller Identity

plusph11 acts as the personal information controller ("PIC") in respect of the personal data processed under this Policy, as that term is defined in RA 10173. The platform operates under PAGCOR regulatory oversight within the Philippines. For all data privacy matters, including the exercise of data subject rights, you may contact our designated Data Protection Officer at the contact details provided in Section 13 of this Policy.

3. Categories of Personal Data We Collect

plusph11 collects the following categories of personal data, depending on how you interact with the Platform:

plusph11 does not intentionally collect sensitive personal information (as defined by RA 10173 — including health data, religious beliefs, political opinions, or sexual orientation) except where required by specific regulatory obligations such as responsible gaming assessments.

4. How We Use Your Personal Data

plusph11 uses your personal data for the following purposes:

• Account creation and management: To register your plusph11 account, verify your identity, and maintain your account in good standing.
• Service delivery: To provide access to games, process bets and transactions, credit winnings, and operate all Platform features you use.
• Identity verification and KYC: To comply with PAGCOR's player registration requirements and verify that you meet the 21+ age requirement and are not on any self-exclusion registry.
• Payment processing: To process GCash, Maya, bank transfer, and other deposits and withdrawals through our payment service providers.
• Fraud prevention and security: To detect and prevent fraud, money laundering, account takeover, and other security threats to you and the Platform.
• Regulatory compliance: To meet our obligations under PAGCOR regulations, the Anti-Money Laundering Act (RA 9160), and reporting requirements to the AMLC.
• Responsible gaming: To monitor gaming patterns, enforce deposit and loss limits you have set, and fulfil our obligations under PAGCOR's responsible gaming framework.
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Platform improvement: To analyse aggregated usage data, improve game offerings, and optimise the Platform's performance for Filipino players on mobile networks.
• Marketing communications: Where you have given consent, to send promotional offers, bonuses, and platform updates by email or SMS. You may withdraw consent at any time via your account settings.

5. Legal Basis for Processing

plusph11 processes your personal data on one or more of the following legal bases under RA 10173:

• Performance of a contract: Processing necessary to provide the services you have requested under the plusph11 Terms & Conditions.
• Legal obligation: Processing required to comply with PAGCOR regulations, AML legislation (RA 9160), tax obligations, and other applicable Philippine laws.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where our interests do not override your fundamental rights.
• Consent: Where you have explicitly consented, such as for marketing communications or optional data sharing. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

6. Disclosure & Data Sharing

plusph11 does not sell, rent, or trade your personal data. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate contractual safeguards:

• Payment service providers: GCash (GXI), Maya (Paymaya Philippines Inc.), BancNet, and other PSPs required to process your financial transactions. These processors act as personal information processors under binding data processing agreements.
• Game software providers: Third-party game providers whose titles are hosted on the plusph11 Platform may receive minimum necessary session data for game delivery and RNG certification purposes.
• Identity verification providers: Third-party KYC service providers who assist with document verification and liveness detection during the account verification process.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government agencies when disclosure is required or compelled by law.
• Professional advisers: Legal counsel, auditors, and compliance consultants who are bound by professional confidentiality obligations.

Any cross-border transfer of personal data (e.g., to cloud infrastructure providers with servers outside the Philippines) is subject to appropriate safeguards as required by RA 10173 and NPC guidelines.

7. Cookies & Tracking Technologies

plusph11 uses cookies and similar tracking technologies to operate the Platform, maintain your login session, remember your preferences, detect fraud signals, and analyse aggregate usage patterns. The following cookie categories are used:

• Strictly Necessary Cookies: Required for core Platform functionality, including authentication and security. These cannot be disabled.
• Functional Cookies: Enable personalisation features such as language preference, last-visited game category, and deposit method memory.
• Analytical Cookies: Aggregate, anonymised data on how users interact with the Platform, used to improve product features and performance. No individual-level profiling is conducted using analytical cookies.
• Marketing Cookies: Used only with your explicit consent to deliver relevant promotional content. You may opt out of marketing cookies at any time via the cookie preference centre accessible from the Platform footer.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair the functionality of the Platform.

8. Data Retention

plusph11 retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by law:

• KYC and identity documents: Minimum 5 years from account closure, as required by AML regulations under RA 9160.
• Transaction records: Minimum 5 years from the date of transaction, as required by the AMLC and PAGCOR.
• Gaming activity logs: Minimum 3 years from the recorded session, for dispute resolution and regulatory audit purposes.
• Communications data (support tickets): 2 years from closure of the relevant support case.
• Marketing consent records: Retained for the duration of your account plus 1 year, as evidence of lawful basis for any marketing communications sent.

After the applicable retention period, personal data is securely deleted or anonymised such that re-identification is not possible.

9. Data Security Measures

plusph11 implements technical and organisational measures appropriate to the risk level of data processing activities, including:

• 256-bit SSL/TLS encryption for all data in transit between your browser and plusph11 servers.
• Encryption of sensitive data fields (financial data, ID document scans) at rest using AES-256 or equivalent standards.
• Role-based access controls ensuring that employee access to player data is limited to what is required for their specific job function.
• Multi-factor authentication requirements for administrative access to production systems.
• Regular penetration testing and security audits by independent third-party firms.
• A documented data breach response procedure in compliance with NPC Circular 16-03 on Personal Data Breach Management, including mandatory breach notification within 72 hours where required.

10. Your Data Subject Rights

Under the Data Privacy Act of 2012, you are entitled to the following rights with respect to your personal data held by plusph11:

• Right to be Informed: The right to know what personal data plusph11 collects, how it is used, and with whom it is shared — as set out in this Policy.
• Right to Access: The right to obtain a copy of the personal data we hold about you, along with information about how it has been processed.
• Right to Rectification: The right to have inaccurate or outdated personal data corrected without undue delay.
• Right to Erasure: The right to request deletion of your personal data, subject to legal retention obligations.
• Right to Object: The right to object to processing based on legitimate interests, including for direct marketing purposes.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission if you believe your data privacy rights have been violated.

To exercise any of these rights, submit a written request to our Data Protection Officer at [email protected]. Requests will be acknowledged within 5 business days and responded to within 15 business days.

11. Children's Privacy & Age Restriction

The plusph11 Platform is strictly intended for persons aged 21 years and above, consistent with PAGCOR's age requirements for online gambling in the Philippines. plusph11 does not knowingly collect personal data from individuals under the age of 21. If we become aware that an account has been created or operated by a person below the minimum age requirement, the account will be immediately suspended, any balance will be withheld pending investigation, and the personal data associated with the account will be reviewed and handled in accordance with PAGCOR guidelines and this Policy.

Parents and guardians who believe their minor child has registered an account on plusph11 should contact [email protected] immediately.

12. Changes to This Privacy Policy

plusph11 reserves the right to update this Privacy Policy periodically to reflect changes in our data processing practices, legal obligations, or regulatory requirements. The "Last Updated" date at the top of this Policy will be revised accordingly. Material changes — those that significantly affect your rights or how your data is used — will be communicated to registered users by email or prominent Platform notification at least 14 days before taking effect. Continued use of the Platform after the effective date of a revised Policy constitutes acceptance of the changes. If you do not agree to a revised Policy, you should close your account before the changes take effect.

13. Contact & Data Protection Officer

For all data privacy enquiries, access requests, complaints, or notices, please contact the plusph11 Data Protection Officer:

• Email: [email protected]
• Subject Line: DATA PRIVACY REQUEST – [YOUR ACCOUNT EMAIL]
• Response Time: Acknowledgement within 5 business days; full response within 15 business days
• Platform: plusph11.one
• Regulatory Framework: Republic Act No. 10173 (Data Privacy Act of 2012), Philippines

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe plusph11 has processed your personal data in violation of RA 10173. Information on how to file a complaint with the NPC is available on the NPC's official website.