Privacy Policy — juan356

This Privacy Policy ("Policy") describes how juan356 ("we," "us," "our," "the Company") collects, uses, discloses, stores, and protects the personal information of players and visitors who access the juan356 platform at juan356.one ("the Platform").

This Policy applies to all personal data processed in connection with your use of juan356, including data collected through the website, account registration process, identity verification, financial transactions, customer support interactions, and platform usage analytics. It covers all individuals who interact with the Platform, whether as registered players, prospective players browsing the site, or individuals contacting juan356 for support.

juan356 is committed to protecting your personal information in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the applicable data governance requirements of the Philippine Amusement and Gaming Corporation (PAGCOR) under whose license the Platform operates.

The data controller responsible for your personal information collected through the juan356 Platform is the Philippine-registered company that operates juan356 under its PAGCOR license. As the data controller, juan356 determines the purposes and means by which your personal data is processed.

juan356 has designated a Data Protection Officer (DPO) in accordance with the requirements of the National Privacy Commission (NPC) and Section 21 of the Data Privacy Act of 2012. The DPO is responsible for overseeing juan356's compliance with data protection obligations and handling data subject requests. Contact details for the DPO are provided in Section 15 of this Policy.

juan356 collects personal data through multiple touchpoints in the course of providing gaming services. The categories of personal data we process are outlined in the table below:

juan356 does not collect sensitive personal data beyond what is strictly required for identity verification and regulatory compliance. We do not collect racial or ethnic origin, religious beliefs, political affiliations, or health information unless directly relevant to a responsible gaming support request.

Under the Philippine Data Privacy Act of 2012, juan356 processes your personal data on one or more of the following legal grounds:

• Contractual Necessity: Processing is necessary to perform the contract between you and juan356 — specifically, to operate your account, execute gaming transactions, process deposits and withdrawals, and provide customer support.
• Legal Obligation: Processing is required to comply with PAGCOR licensing conditions, the Anti-Money Laundering Act (RA 9160 as amended), the Terrorism Financing Prevention and Suppression Act (RA 10168), the Data Privacy Act of 2012, and related Philippine laws and regulations.
• Legitimate Interest: juan356 processes certain technical and usage data to detect fraud, prevent account abuse, maintain platform security, and improve the gaming experience — where such interests do not override your fundamental privacy rights.
• Consent: Where processing is not required by contract or law, juan356 will seek your explicit consent. You have the right to withdraw consent at any time, subject to the consequences described in Section 11.

juan356 uses the personal data it collects for the following specific purposes:

• Account Management: Creating, maintaining, verifying, and closing your juan356 account.
• Identity Verification (KYC): Fulfilling PAGCOR's Know Your Customer requirements and verifying that you meet the 21+ age eligibility requirement before allowing withdrawals.
• Payment Processing: Executing deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, Coins.ph, USDT, and other supported Philippine payment channels.
• Fraud Prevention and Security: Detecting and investigating unauthorised access, suspicious transactions, money laundering indicators, bonus abuse, multiple account creation, and other prohibited activities.
• Regulatory Reporting: Filing mandatory reports with PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies as required by law.
• Responsible Gaming: Monitoring account activity for signs of problem gambling and facilitating the implementation of responsible gaming tools including deposit limits, cooling-off periods, and self-exclusion.
• Customer Support: Responding to enquiries, resolving disputes, and improving the quality of our support services.
• Platform Improvement: Analysing aggregated and anonymised usage data to improve game offerings, platform navigation, payment processes, and promotional strategies.
• Legal Defence: Maintaining records necessary to defend juan356's legal rights and interests in any dispute or regulatory proceeding.

juan356 uses cookies and similar tracking technologies to operate and improve the Platform. A "cookie" is a small data file stored on your device by your browser when you visit a website. juan356 uses the following categories of cookies:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in to your juan356 account during a session. These cannot be disabled without breaking core platform functionality.
• Performance & Analytics Cookies: Used to collect aggregated, anonymised data about how players use the Platform — which pages are visited most, where errors occur, and how navigation flows work. This data helps juan356 improve the platform without identifying individual players.
• Preference Cookies: Store your Platform preferences such as language settings, responsible gaming limits, and display configurations so they persist between sessions.
• Security Cookies: Support fraud detection and account security functions, including identifying devices associated with previous logins.

juan356 does not use third-party advertising cookies or behavioural profiling cookies for the purpose of selling advertising space. You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to your juan356 account.

juan356 does not sell, rent, or trade your personal data to any third party for commercial purposes. Personal data is shared with third parties only in the following circumstances and with the minimum data necessary for each purpose:

• Payment Processors: GCash (G-Xchange Inc.), Maya Philippines (Voyager Innovations), BPI, BDO, Metrobank, UnionBank, and other Philippine financial institutions receive transaction data necessary to execute deposits and withdrawals.
• Game Providers: Certified gaming studios (such as Pragmatic Play, PG Soft, and Evolution Gaming) may receive a session token and your anonymised player ID to load games within your juan356 session. Full personal identity data is not transmitted to game providers.
• Identity Verification Services: Third-party KYC platforms may receive your identity documents for automated document verification and liveness checks. These providers operate under data processing agreements with juan356 and are bound by Philippine data protection standards.
• PAGCOR: juan356 submits mandatory regulatory reports to PAGCOR including player activity summaries and suspicious transaction reports as required under its operating license.
• Anti-Money Laundering Council (AMLC): juan356 is required to file covered transaction reports (CTRs) and suspicious transaction reports (STRs) with the AMLC as required under RA 9160 and its amendments.
• Law Enforcement: juan356 will disclose personal data to Philippine law enforcement authorities, courts, or government agencies where required to do so by a lawful order, warrant, or legal obligation.

Some of juan356's game providers and technology vendors operate data processing infrastructure outside the Philippines. Where personal data is transferred to a country that does not have a comparable level of data protection legislation, juan356 implements appropriate safeguards as required by NPC Advisory Opinion and the Data Privacy Act, including:

• Standard contractual clauses approved by the National Privacy Commission;
• Adequacy determinations where applicable; or
• The recipient's binding corporate rules or equivalent compliance framework.

International transfers are limited to the data necessary for the specific purpose (e.g., game session tokens for game providers) and do not include full identity documents unless required for a specific cross-border compliance purpose. juan356 does not transfer your full KYC documents outside the Philippines without your explicit consent except where required by law.

juan356 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by applicable Philippine law and PAGCOR licensing conditions:

• Account and Identity Data: Retained for a minimum of five (5) years after account closure, as required by PAGCOR and AMLC regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years as required under the Anti-Money Laundering Act.
• Game Session Logs: Retained for a minimum of twelve (12) months for dispute resolution and platform integrity purposes.
• Customer Support Records: Retained for a minimum of three (3) years from the date of the last interaction.
• Technical and Access Logs: Retained for twelve (12) months and then deleted or anonymised.
• Marketing Consent Records: Retained until consent is withdrawn and for one (1) year thereafter as evidence of the consent record.

Upon expiry of the applicable retention period, personal data will be securely deleted or irreversibly anonymised. Where anonymisation is applied, the resulting data (which is no longer personal data) may be retained for statistical and analytical purposes without time limit.

juan356 implements a multi-layer security framework to protect your personal data against unauthorised access, disclosure, alteration, and destruction. The following technical and organisational measures are in place:

• Encryption in Transit: All data transmitted between your device and juan356 servers is encrypted using Transport Layer Security (TLS) 1.3. Connections over HTTP are automatically redirected to HTTPS.
• Encryption at Rest: Sensitive data fields including identity document references and financial account details are encrypted at rest using AES-256 encryption within juan356's database infrastructure.
• Password Hashing: Account passwords are stored as salted cryptographic hashes using bcrypt. juan356 does not store plaintext passwords. The actual password value is never accessible to any juan356 employee.
• Access Controls: Access to player personal data within juan356's internal systems is restricted by role-based access controls (RBAC). Only authorised personnel with a documented business need may access player records, and all such access is logged.
• Two-Factor Authentication: Optional 2FA is available to all players for account login. Internal juan356 staff access to production systems requires mandatory multi-factor authentication.
• Intrusion Detection: juan356's infrastructure is monitored 24/7 for anomalous activity indicative of breach attempts, including brute-force login attacks, SQL injection, and DDoS events.
• Data Breach Response: juan356 maintains a documented data breach response plan. In the event of a personal data breach that poses a real risk to player rights, juan356 will notify the National Privacy Commission within 72 hours of discovery and affected players without undue delay, in accordance with NPC Circular No. 16-03.

As a data subject under Republic Act No. 10173, you have the following rights with respect to your personal data held by juan356:

• Right to Be Informed: You have the right to be informed of how your personal data is collected and processed, including the purposes, legal basis, and retention periods. This Policy fulfils that obligation.
• Right to Access: You may request a copy of the personal data juan356 holds about you, including the categories of data processed, the purposes, and details of any third-party disclosures.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data. For identity data, corrections may require re-submission of KYC documents.
• Right to Erasure / "Right to be Forgotten": You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent (and no other legal basis applies), or where processing is unlawful. Note that juan356 is legally required to retain certain data categories for regulatory periods even after account closure — erasure requests will be fulfilled to the extent legally permissible.
• Right to Object: You have the right to object to processing of your personal data on the basis of legitimate interest, including profiling for marketing purposes. Objections will be considered and responded to within thirty (30) days.
• Right to Data Portability: You may request that juan356 provide your personal data in a structured, commonly used, machine-readable format (such as CSV) for portability purposes.
• Right to Lodge a Complaint: If you believe juan356 has violated your privacy rights, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC).

To exercise any of the above rights, contact juan356's Data Protection Officer via the contact details in Section 15. juan356 will respond to verified data subject requests within thirty (30) calendar days. Identity verification will be required before any data access, correction, or erasure is processed.

The juan356 Platform is strictly restricted to individuals aged 21 years and above, in accordance with PAGCOR regulations and Philippine gambling law. juan356 does not knowingly collect or process personal data from persons under the age of 21.

If juan356 becomes aware or has reasonable grounds to believe that a registered player is under 21 years of age, juan356 will immediately suspend the account, withhold all funds pending investigation, notify PAGCOR as required, and initiate data deletion procedures for all personal data collected from the underage individual (except for records required to be retained for legal compliance purposes).

Parents or guardians who believe that a minor has registered on juan356 should contact our support team or DPO immediately. We take all such reports seriously and will act promptly.

The juan356 Platform does not include links to third-party websites for commercial or advertising purposes. Where any reference to a third party is made within the Platform (for example, references to PAGCOR or payment providers in informational content), such references are informational only.

juan356 is not responsible for the privacy practices or content of any third-party websites, applications, or services. If you access any third-party site through a link encountered outside the juan356 Platform (for example, through an online advertisement or third-party review site), we strongly recommend reviewing that site's privacy policy independently.

juan356 reserves the right to amend, update, or replace this Privacy Policy at any time to reflect changes in applicable law, NPC guidance, PAGCOR requirements, or our data processing practices. When material changes are made, registered players will be notified by email to their registered address at least seven (7) days prior to the changes taking effect.

The "Last Updated" date displayed at the top of this Policy reflects when it was most recently revised. Minor, non-material updates (such as typographical corrections or formatting adjustments) may be made without prior notice. The current version of the Policy is always accessible at juan356.one/privacy-policy.

Your continued use of the juan356 Platform following the effective date of any amended Policy constitutes your acceptance of the revised terms. If you do not accept the amended Policy, you must cease using juan356 and contact support to request account closure.

For any questions, requests, or concerns relating to this Privacy Policy or juan356's data processing practices, you may contact the juan356 Data Protection Officer (DPO) through the following channels: