Privacy Policy — juan265

1. Introduction

juan265 ("we," "us," "our," or "juan265") operates the online gaming platform accessible at https://juan265.app ("Platform"). We are committed to protecting the privacy and personal data of every individual who uses our Platform. This Privacy Policy ("Policy") describes our practices regarding the collection, use, storage, disclosure, and protection of personal information in accordance with Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), the issuances of the National Privacy Commission ("NPC"), and applicable PAGCOR regulatory requirements.

By creating an Account on juan265 or by continuing to use the Platform, you acknowledge that you have read, understood, and consent to the data processing practices described in this Policy. This Policy is incorporated by reference into the juan265 Terms and Conditions.

2. Data Controller

For purposes of the DPA, juan265 acts as the Personal Information Controller with respect to the personal data of its registered Players and website visitors. All inquiries regarding data privacy matters, including requests to exercise data subject rights, should be directed to the juan265 Data Protection Officer (DPO) via the contact details in Section 14 of this Policy.

3. Personal Data We Collect

3.1 Registration and Account Data

When you create a juan265 Account, we collect:

• Full legal name as it appears on a Philippine government-issued ID;
• Date of birth (to verify the 21+ age requirement);
• Email address and mobile phone number;
• Username and encrypted password hash;
• Residential address in the Philippines.

3.2 Identity Verification (KYC) Data

To comply with PAGCOR licensing conditions and Republic Act No. 9160 (Anti-Money Laundering Act), we collect:

• Copies of Philippine government-issued identification documents (e.g., PhilSys ID, Passport, Driver's License, SSS/GSIS ID, Voter's ID, PRC ID);
• Selfie or liveness verification images where required;
• Source-of-funds documentation for high-value players as required by AMLC rules.

3.3 Financial Transaction Data

• GCash account references, Maya account references, and other payment method identifiers;
• Deposit amounts, withdrawal amounts, dates, and transaction reference numbers;
• Bank account details where bank transfers are used.

3.4 Gaming Activity Data

• Game history, wager amounts, win/loss records, session duration, and bonus usage;
• Responsible gaming settings, including deposit limits and self-exclusion records.

3.5 Technical and Device Data

• IP address and approximate geolocation;
• Device type, operating system, browser type and version;
• Login timestamps, session identifiers, and access logs;
• Cookie and tracking data as described in Section 7.

3.6 Communications Data

Records of your communications with juan265 customer support, including live chat transcripts and email correspondence.

4. How We Use Your Personal Data

juan265 uses collected personal data for the following purposes:

• Account creation and management: To register, verify, and administer your juan265 Account;
• Age and identity verification: To confirm you are 21 years of age or older and to fulfill KYC obligations;
• Payment processing: To process deposits and withdrawals via GCash, Maya, and other supported Philippine payment methods;
• Gaming and platform services: To operate games, calculate results, process wagers, and deliver platform features;
• Regulatory compliance: To meet PAGCOR licensing conditions, AMLC reporting obligations, and NPC requirements;
• Fraud prevention and security: To detect, investigate, and prevent fraud, money laundering, multiple accounts, and prohibited conduct;
• Responsible gaming: To operate self-exclusion programs, enforce player-set limits, and identify patterns consistent with problem gambling;
• Customer support: To respond to inquiries, resolve disputes, and provide account assistance;
• Marketing communications: To send you promotional offers and bonus notifications where you have opted in (you may opt out at any time);
• Platform improvement: To analyze usage patterns and improve the juan265 Platform, game selection, and user experience.

5. Legal Basis for Processing

juan265 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform the Terms and Conditions agreement between you and juan265, including account management, payment processing, and game operation;
• Legal obligation: Processing required to comply with PAGCOR regulations, AMLC reporting requirements, and other applicable Philippine law;
• Legitimate interest: Processing for fraud prevention, security monitoring, and platform improvement, where such interests are not overridden by your rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, freely given consent.

6. Data Sharing and Disclosure

juan265 does not sell your personal data. We may share personal data with the following categories of recipients only to the extent necessary for the stated purpose:

• PAGCOR: As required by our gaming license, including player registration data and gaming activity reports;
• Anti-Money Laundering Council (AMLC): Suspicious transaction reports and covered transaction reports as required by RA 9160;
• Payment service providers: GCash (G-Xchange, Inc.), Maya (PayMaya Philippines, Inc.), and other authorized Philippine payment processors, for the sole purpose of processing your transactions;
• Game providers: Technical game data necessary for game operation is shared with licensed game providers (e.g., JILI Gaming, Pragmatic Play) under strict data processing agreements;
• KYC and fraud prevention providers: Identity verification and fraud screening service providers operating under data processing agreements;
• Law enforcement and courts: Where required by a valid legal order, warrant, or court direction from a competent Philippine authority.

All third-party service providers with whom juan265 shares personal data are bound by contractual data processing obligations that require them to process data only for the specified purpose and to maintain appropriate security standards.

7. Cookies and Tracking Technologies

juan265 uses cookies and similar tracking technologies to operate the Platform and improve your experience. Categories of cookies used include:

• Strictly necessary cookies: Required for Platform operation, including session authentication, load balancing, and security functions. These cannot be disabled;
• Functional cookies: Remember your preferences such as language settings, game lobby filters, and responsible gaming configurations;
• Analytics cookies: Collect aggregated, anonymized data about Platform usage to help us identify performance issues and improve features. Used only with your consent;
• Marketing cookies: Track your activity to deliver relevant promotional content. Used only with your explicit consent.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not affect your ability to use the core Platform features.

8. Data Retention

juan265 retains personal data for as long as necessary to fulfill the purposes described in this Policy, subject to the following minimum retention periods mandated by Philippine law:

• KYC and identity records: Minimum 5 years from Account closure, as required by AMLC regulations under RA 9160;
• Financial transaction records: Minimum 5 years from the date of each transaction;
• Gaming activity logs: Minimum 3 years, as required by PAGCOR;
• Support communications: 2 years from the date of the communication, unless relevant to an ongoing dispute;
• Marketing consent records: Until consent is withdrawn, plus 1 year for evidence of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized using industry-standard data destruction methods.

9. Data Security

juan265 implements organizational and technical security measures appropriate to the risk level of the personal data we process, including:

• 256-bit TLS/SSL encryption for all data transmitted between your device and the Platform;
• Encryption of sensitive data at rest, including password hashes using one-way cryptographic algorithms;
• Multi-factor authentication options for Account access;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security audits and penetration testing of the Platform infrastructure;
• Intrusion detection systems and real-time security monitoring;
• A documented data breach response procedure in accordance with NPC Circular 16-03 requirements.

In the event of a personal data breach that poses a real risk of serious harm, juan265 will notify the NPC within 72 hours of becoming aware of the breach, and will notify affected Players without undue delay.

10. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by juan265:

• Right to be informed: The right to know what personal data we hold about you, how it is processed, and with whom it is shared;
• Right of access: The right to request a copy of your personal data held by juan265;
• 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 processing is no longer necessary, subject to legal retention obligations;
• Right to object: The right to object to processing based on legitimate interests or for direct marketing purposes;
• Right to data portability: The right to receive your personal data in a structured, commonly used format;
• Right to file a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, contact the juan265 DPO at [email protected] with a clear description of your request. We will respond within 15 business days as required by the DPA IRR.

11. Children's Privacy

juan265 does not knowingly collect personal data from individuals under the age of 21. The Platform is intended for adults only, and registration requires age verification through KYC. If we become aware that personal data of a person under 21 has been collected, we will immediately close the relevant Account, forfeit any winnings in accordance with our Terms, return deposits where appropriate, and delete the associated personal data. If you believe a minor has created a juan265 Account, please contact us immediately at [email protected].

12. Cross-Border Data Transfers

Some of juan265's technology service providers and game suppliers may be located outside the Philippines. Where personal data is transferred to a jurisdiction that does not provide an equivalent level of data protection to the DPA, juan265 ensures that appropriate safeguards are in place, including contractual data processing clauses that bind the recipient to equivalent data protection standards. Juan265 will not transfer personal data to a foreign country unless such transfer is compliant with the DPA and its IRR.

13. Changes to This Policy

juan265 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Material changes will be communicated to registered Players via email and through a prominent notice on the Platform at least 14 days before taking effect. The "Last Updated" date at the top of this Policy will be revised accordingly. Continued use of the Platform after the effective date of any revision constitutes acceptance of the updated Policy.

14. Contact and Data Protection Officer

For all privacy-related inquiries, data subject rights requests, and data breach notifications, please contact the juan265 Data Protection Officer:

• Email: [email protected] (subject line: "Data Privacy Inquiry")
• Live Chat: Available 24/7 within your Account dashboard

If you are not satisfied with our response to a privacy complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines through the NPC's official channels.