Privacy Policy – juan1365

1. Introduction & Scope

This Privacy Policy ("Policy") is issued by juan1365 ("we," "us," "our," or "the Company"), the operator of the online gaming and sports betting platform accessible at juan1365.org ("the Platform"). This Policy describes how juan1365 collects, uses, stores, discloses, and otherwise processes the personal data of persons who access or use the Platform, including registered players and visitors who have not created an account ("you," "your," or "Data Subject").

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations (IRR), as administered by the National Privacy Commission (NPC) of the Philippines. It should be read alongside our Terms and Conditions and Responsible Gaming Policy, which together govern your use of the Platform.

By accessing the Platform or registering a Player Account, you acknowledge that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein. If you do not consent to any part of this Policy, you must not use the Platform.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, juan1365 is the Personal Information Controller (PIC) responsible for your personal data collected in connection with the Platform. Juan1365 determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with applicable Philippine data privacy law.

Juan1365 has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with data privacy obligations, handling data subject requests, and serving as the primary point of contact for the National Privacy Commission. Contact details for the DPO are provided in Section 16 of this Policy.

3. Data We Collect

Juan1365 collects and processes the following categories of personal data in connection with the Platform:

3.1 Identity and Contact Information

This data is collected during account registration and KYC verification.

3.2 Financial and Transaction Data

Required for processing deposits and withdrawals and for compliance with anti-money laundering obligations under Republic Act No. 9160 (as amended).

3.3 Gaming and Behavioral Data

Used to operate the Platform, calculate balances, resolve disputes, and fulfil responsible gaming obligations.

3.4 Technical and Device Data

Collected automatically when you access the Platform. Used for security monitoring, fraud detection, and service optimization.

3.5 Communications Data

Records of your communications with juan1365 customer support — including live chat transcripts, email correspondence, and support ticket content — are stored for quality assurance, dispute resolution, and regulatory purposes.

3.6 Sensitive Personal Information

Juan1365 may collect certain sensitive personal information as defined under the DPA, including government-issued identification numbers and financial account information, strictly to the extent required for identity verification, KYC compliance, and transaction processing. Such data is afforded enhanced security measures and is processed only on the basis of explicit consent or as required by applicable law.

4. How We Collect Your Data

Juan1365 collects personal data through the following means:

• Directly from you: Information you provide during account registration, KYC document submission, payment processing, support interactions, and any form you complete on the Platform.
• Automatically: Technical data collected when you access the Platform via cookies, server logs, and similar tracking technologies as described in Section 10 of this Policy.
• From third parties: Identity verification information from KYC service providers; payment confirmation data from GCash, Maya, BDO, BPI, and other payment processors; fraud-screening data from security service providers; and information shared by PAGCOR or Philippine law enforcement authorities in the context of regulatory compliance.

5. Purpose & Legal Basis for Processing

Juan1365 processes your personal data on the following legal bases and for the following purposes:

6. Sharing Your Personal Data

Juan1365 does not sell, rent, or trade your personal data to third parties. We may, however, share your personal data with the following categories of recipients where necessary and on a need-to-know basis:

• Payment processors: GCash, Maya, BDO, BPI, Metrobank, UnionBank, Visa, and Mastercard, as required to process your deposits and withdrawals.
• KYC and identity verification providers: Third-party providers engaged by juan1365 to verify the authenticity of identity documents submitted during account verification.
• Fraud detection and security services: Specialized third-party providers used to screen transactions, detect suspicious login activity, and prevent abuse of the Platform.
• Game software providers: Licensed game studios and live casino providers whose products are integrated into the Platform. Data shared is limited to the minimum necessary to operate the relevant game.
• PAGCOR and Philippine regulatory authorities: Juan1365 is legally required to disclose player information to PAGCOR and, where applicable, to the AMLC (Anti-Money Laundering Council) and other Philippine government agencies in connection with their regulatory and law enforcement functions.
• Professional advisers: Lawyers, auditors, and accountants engaged by juan1365 in the ordinary course of business, subject to confidentiality obligations.
• Business successors: In the event of a merger, acquisition, or sale of all or substantially all of the assets of juan1365, personal data held by the Company may be transferred to the successor entity, subject to the same data protection obligations under this Policy.

7. International Transfers of Personal Data

Some of the third-party service providers engaged by juan1365 — including game software providers, technical infrastructure vendors, and security service providers — may be located outside the Philippines. Where personal data is transferred to a recipient in another country, juan1365 ensures that such transfer is made only where:

• The receiving country provides an adequate level of data protection as determined by the National Privacy Commission; or
• Appropriate safeguards are in place, such as contractual clauses that impose data protection obligations consistent with the DPA; or
• The transfer is necessary for the performance of a contract to which you are a party, or for the implementation of pre-contractual measures taken at your request.

You may request information about the safeguards applied to international transfers of your data by contacting our Data Protection Officer at [email protected].

8. Data Retention

Juan1365 retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the minimum retention periods required by applicable Philippine law:

• Account data: Retained for the duration of your account and for a period of five (5) years following permanent account closure, in compliance with PAGCOR record-keeping requirements.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of the relevant transaction, as required under the Anti-Money Laundering Act (RA 9160, as amended).
• KYC documents: Retained for a minimum of five (5) years following the termination of the business relationship, as required by AMLC regulations.
• Communications and support records: Retained for three (3) years from the date of the communication, unless a longer period is required for ongoing dispute resolution or legal proceedings.
• Gaming and session logs: Retained for three (3) years from the date of the relevant game session, for dispute resolution and audit purposes.
• Marketing data (where consent was provided): Retained until you withdraw consent or request erasure, whichever is earlier.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with NPC-recommended standards for data disposal.

9. Security Measures

Juan1365 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers;
• AES-256 encryption for personal data stored in our databases;
• Role-based access controls ensuring that only authorized personnel can access personal data;
• Multi-factor authentication requirements for internal access to production systems;
• Regular penetration testing and vulnerability assessments conducted by independent security firms;
• Security incident response procedures aligned with NPC breach notification requirements;
• Staff training on data privacy and security obligations under the DPA.

In the event of a personal data breach that is likely to result in serious harm to affected individuals, juan1365 will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected data subjects without undue delay, in accordance with NPC Circular 16-03 on Personal Data Breach Management.

10. Cookies & Tracking Technologies

Juan1365 uses cookies and similar tracking technologies (such as web beacons and local storage) on the Platform. Cookies are small text files stored on your device that help us recognize you and remember your preferences across sessions.

10.1 Types of Cookies Used

• Strictly necessary cookies: Essential for the Platform to function. These include session management cookies, security tokens, and authentication cookies. These cannot be disabled.
• Performance and analytics cookies: Used to collect anonymized information about how visitors use the Platform — which pages are visited most frequently, error messages encountered, and navigation patterns. This helps juan1365 improve the Platform experience.
• Functional cookies: Used to remember your preferences, such as your preferred language, last visited game section, and display settings, to provide a more personalized experience.

10.2 Managing Cookies

You can control non-essential cookies through your browser settings. Most browsers allow you to refuse cookies or to be alerted before a cookie is stored. Please note that disabling strictly necessary cookies will impair the functionality of the Platform, including your ability to log in. For guidance on managing cookies in your browser, refer to the help documentation of your browser of choice.

11. Your Data Subject Rights

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by juan1365:

To exercise any of these rights, please submit a written request to our Data Protection Officer at [email protected] with the subject line "Data Subject Request – [Right Type]". We will acknowledge your request within 5 business days and respond within 15 business days. Verification of your identity will be required before we process any data subject request.

12. Minors & Age Restriction

The juan1365 Platform is strictly intended for use by persons who are 21 years of age or older, as required under Philippine gambling regulations and PAGCOR licensing conditions. Juan1365 does not knowingly collect personal data from individuals under the age of 21. Age is verified during account registration, and juan1365 reserves the right to require documentary proof of age at any time.

If juan1365 becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to close the associated account, void any transactions, and securely delete the data. If you believe a minor has registered an account on juan1365, please notify us immediately at [email protected].

13. Marketing & Communications

Juan1365 may send you promotional communications — including bonus offers, new game announcements, tournament invitations, and platform news — by SMS, email, or in-platform notification, provided that you have given your express consent to receive such communications during account registration or at a later date via your account settings.

You may withdraw your consent to receive marketing communications at any time by:

• Updating your notification preferences in your juan1365 account settings;
• Clicking the unsubscribe link included in any email marketing communication; or
• Submitting a written request to [email protected].

Withdrawal of marketing consent does not affect the lawfulness of processing that occurred prior to withdrawal. Please note that even after withdrawing marketing consent, you will continue to receive transactional communications — such as deposit confirmations, withdrawal notifications, and security alerts — as these are necessary for the operation of your account.

14. Third-Party Links

The juan1365 Platform does not contain links to external third-party websites. This Privacy Policy applies solely to the personal data processed by juan1365 in connection with the Platform at juan1365.org. If you access any third-party service in connection with your account — such as the GCash or Maya applications when completing a payment — the privacy practices of those services are governed by their own privacy policies, which are independent of this Policy and over which juan1365 has no control.

15. Changes to This Privacy Policy

Juan1365 may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. When material changes are made, we will notify registered Players by posting a notice on the Platform and, where appropriate, by sending a notification to your registered mobile number or email address.

The revised Policy will take effect from the date indicated at the top of this document. Your continued use of the Platform following the effective date of any revision constitutes your acceptance of the updated Policy. If you do not agree with the revised Policy, you must close your account and cease using the Platform.

We recommend reviewing this Policy periodically to stay informed about how juan1365 protects your personal data.

16. Contact & Data Protection Officer

For any questions, concerns, or requests related to this Privacy Policy or the processing of your personal data by juan1365, please contact our Data Protection Officer:

If you are not satisfied with our response to your data privacy inquiry or if you believe your rights under the Data Privacy Act of 2012 have been violated, you have the right to file a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph.