Privacy Policy — juan356

1. Introduction

This Privacy Policy ("Policy") is issued by juan356 ("juan356", "we", "us", "our") and governs the collection, use, storage, disclosure, and protection of personal information ("Personal Data") relating to registered users, prospective users, and visitors to the juan356 platform at juan356.club (the "Platform").

juan356 is committed to protecting the privacy and personal data of all individuals who interact with our Platform in compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC"). Where applicable, juan356 also observes internationally recognised data protection principles consistent with those standards.

By accessing the Platform, creating an account, or using any juan356 Service, you acknowledge that you have read, understood, and consent to the practices described in this Policy. If you do not agree with this Policy, please do not use the Platform or submit any personal information to us.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and applicable data protection law, juan356 is the Personal Information Controller in respect of Personal Data collected through the Platform.

All enquiries relating to this Policy, data subject rights requests, or data protection concerns may be directed to juan356's designated data protection contact. Contact details are provided in Section 14 of this Policy.

3. Personal Data We Collect

juan356 collects Personal Data through your direct interactions with the Platform, through automated technical means, and from third parties in limited circumstances. The categories of Personal Data we collect include:

3.1 Registration & Identity Data

• Full legal name as it appears on a government-issued ID
• Date of birth (for age verification — minimum 21 years)
• Philippine mobile number and/or email address
• Username chosen at registration
• Password (stored in encrypted, hashed form — never in plain text)
• Government-issued ID type and number (collected during KYC verification)
• Photograph or scan of government-issued identification document
• Proof of address documentation (utility bill, bank statement, or equivalent)

3.2 Financial & Transaction Data

• Registered GCash or Maya account number (name-matched to account)
• Bank account details (BDO, BPI, Metrobank, UnionBank, or other banks) where used for deposits or withdrawals
• Transaction history: deposits, withdrawals, amounts, timestamps, and payment method used
• Wallet balance and transaction reference numbers

3.3 Gaming Activity Data

• Game session data: games played, stakes, outcomes, duration
• Sports betting selections, odds accepted, and results
• Bonus and promotion participation history
• VIP tier, loyalty points balance, and reward redemption history
• Responsible gaming tool settings: deposit limits, session reminders, self-exclusion status

3.4 Technical & Device Data

• IP address and approximate geographic location
• Device type, operating system, and browser type/version
• Session timestamps, login and logout records
• Cookies and similar tracking technologies (see Section 9)
• Referral URL and navigation path within the Platform

3.5 Communications Data

• Records of communications with juan356 customer support (chat transcripts, email correspondence)
• Feedback, complaints, and dispute records
• Marketing communication preferences

4. How We Use Your Personal Data

juan356 uses the Personal Data collected for the following purposes:

Purpose	Data Used
Account creation & management	Registration data, identity data, contact details
Age verification (21+ requirement)	Date of birth, government-issued ID
KYC / AML compliance	Identity documents, proof of address, financial data
Processing deposits & withdrawals	Financial data, transaction history, payment method details
Delivering gaming services	Gaming activity data, device data, session data
Fraud prevention & security	All categories — used to detect anomalous or prohibited behaviour
Responsible gaming support	Gaming activity data, self-exclusion settings, deposit limit data
Customer support	Communications data, account data, transaction data
VIP programme & promotions	Gaming activity data, registration data, preferences
Legal & regulatory compliance	All relevant categories as required by law
Platform improvement & analytics	Technical data, gaming activity data (aggregated/anonymised where possible)

5. Legal Basis for Processing

juan356 processes Personal Data only where there is a lawful basis to do so. The primary legal bases under the Data Privacy Act of 2012 that apply to our processing activities are:

• Contractual necessity: Processing required to perform our obligations under the Terms and Conditions you accepted at registration (e.g., account management, payment processing, game delivery).
• Legal obligation: Processing required to comply with applicable Philippine law, including AML obligations, tax reporting requirements, and regulatory directives from PAGCOR and the National Privacy Commission.
• Legitimate interests: Processing for fraud prevention, security monitoring, and Platform improvement — balanced against your privacy rights.
• Consent: Processing for direct marketing communications, where you have provided specific, informed consent. You may withdraw marketing consent at any time through your account settings.

6. Data Sharing & Third-Party Disclosure

juan356 does not sell, rent, or trade your Personal Data to third parties for their own marketing purposes. We share Personal Data only in the following circumstances:

• Payment processors: GCash, Maya, BDO, BPI, Metrobank, UnionBank, and other payment service providers — solely to process transactions you initiate.
• Game software providers: Third-party studios (e.g., PG Soft, Pragmatic Play) may receive session identifiers necessary to deliver games. They do not receive your identity or financial data.
• KYC verification services: Identity verification providers used to confirm the authenticity of documents submitted during KYC — operating under strict confidentiality agreements.
• Regulatory authorities: Government bodies, law enforcement agencies, and regulatory authorities (including PAGCOR and the NPC) where disclosure is required by law or court order.
• Professional advisers: Legal counsel, auditors, and financial advisers under professional secrecy obligations.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of the business, Personal Data may be transferred to the acquiring entity, subject to equivalent privacy protections.

7. Data Retention

juan356 retains Personal Data for as long as necessary to fulfil the purposes for which it was collected, including legal, regulatory, and compliance obligations. Specific retention periods include:

• Account and identity data: Retained for the duration of the account relationship and for a minimum of five (5) years after account closure, in compliance with AML and financial record-keeping obligations.
• Transaction records: Retained for a minimum of five (5) years in compliance with applicable financial regulations.
• KYC documentation: Retained for a minimum of five (5) years after the end of the business relationship.
• Gaming activity logs: Retained for a minimum of three (3) years for audit, responsible gaming, and dispute resolution purposes.
• Communications with support: Retained for three (3) years for training, quality assurance, and dispute resolution.
• Marketing preferences: Retained until you withdraw consent or close your account.

Data that is no longer required for any lawful purpose is securely deleted or anonymised in accordance with our data destruction procedures.

8. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your Personal Data held by juan356:

• Right to be informed: The right to know what Personal Data we hold about you and how it is being used — which this Policy provides.
• Right of access: The right to request a copy of the Personal Data juan356 holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete Personal Data.
• Right to erasure: The right to request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected — subject to our legal retention obligations.
• Right to data portability: The right to receive your Personal Data in a structured, commonly used, machine-readable format where technically feasible.
• Right to object: The right to object to processing based on legitimate interests, including direct marketing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data has been processed in violation of the Data Privacy Act.

To exercise any of these rights, contact juan356 using the details in Section 14. We will respond to verified requests within thirty (30) days. We may require identity verification before processing any data subject rights request.

9. Cookies & Tracking Technologies

juan356 uses cookies and similar tracking technologies to operate the Platform, maintain session continuity, prevent fraud, and improve user experience. The categories of cookies we use are:

• Strictly necessary cookies: Required for the Platform to function. These include session cookies that keep you logged in and security cookies that detect fraudulent activity. These cannot be disabled.
• Functional cookies: Remember your preferences (e.g., language, preferred game lobby view, responsible gaming settings) across sessions. Disabling these may affect Platform functionality.
• Analytics cookies: Collect anonymised or aggregated data about how users navigate the Platform to help us improve performance and usability. No personally identifiable data is exported to analytics providers.

You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent the Platform from functioning correctly. juan356 does not use third-party advertising or retargeting cookies.

10. Security Measures

juan356 implements technical and organisational measures designed to protect your Personal Data against unauthorised access, loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the Platform
• Encryption of sensitive data fields at rest (passwords stored as salted hashes; financial identifiers encrypted in the database)
• Role-based access controls limiting staff access to Personal Data on a need-to-know basis
• Two-factor authentication (2FA) available to all account holders and mandatory for administrative access
• Regular security assessments and penetration testing by qualified third parties
• Incident response procedures including breach notification protocols compliant with NPC requirements

Despite these measures, no online platform can guarantee absolute security. You are responsible for keeping your account credentials confidential and notifying juan356 immediately of any suspected unauthorised access.

11. Children & Minors

The juan356 Platform is strictly restricted to individuals aged 21 years and above. juan356 does not knowingly collect Personal Data from anyone under the age of 21. Age is verified at registration using government-issued identification, and any account found to be held by an underage individual will be immediately suspended.

If you believe that a person under 21 has provided Personal Data to juan356, please contact us immediately using the details in Section 14 so that we can take appropriate action, including deletion of the data and reporting as required by law.

12. International Data Transfers

juan356 primarily processes and stores Personal Data within the Philippines. In limited circumstances, Personal Data may be transferred to third-party service providers (such as game software vendors or fraud detection services) that operate servers outside the Philippines. When such transfers occur, juan356 ensures that:

• The recipient country or organisation provides a comparable level of data protection to that required under Philippine law; or
• Appropriate contractual safeguards are in place, such as standard contractual clauses approved by the NPC or equivalent data protection authority; and
• The transfer is limited to the minimum data necessary for the specific processing purpose.

13. Updates to This Privacy Policy

juan356 reserves the right to update this Privacy Policy at any time to reflect changes in our practices, legal obligations, or regulatory requirements. When material changes are made, registered users will be notified via email or an in-platform notification at least seven (7) days before the changes take effect, unless immediate implementation is required by law.

The effective date at the top of this Policy will be updated to reflect the most recent revision. Your continued use of the Platform after the effective date of any revised Policy constitutes your acceptance of the changes. If you do not agree, you should stop using the Platform and may request account closure.

14. Contact & Data Subject Requests

All privacy-related enquiries, data subject rights requests, and complaints relating to this Policy should be directed to juan356 as follows:

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your Personal Data has been processed in violation of the Data Privacy Act of 2012. The NPC can be reached through its official government channels.

This Privacy Policy was last reviewed on 1 January 2026.