Privacy Policy — juan375

1.1  Juan375 is committed to protecting the privacy and personal data of all individuals who use the juan375.app platform. This Privacy Policy has been drafted in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines, its Implementing Rules and Regulations, and the data protection requirements imposed on PAGCOR-licensed online gaming operators.

1.2  This Policy sets out the types of personal data juan375 collects, the purposes for which that data is processed, the legal bases for processing, your rights as a data subject under Philippine law, how long data is retained, and how you can contact us regarding any data privacy concern.

1.3  This Policy applies to all personal data collected through juan375.app, including data provided directly by you during registration, data collected automatically through your use of the platform, and data received from third-party service providers in connection with payment processing, identity verification, and game delivery.

2.1  For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, the Data Controller of personal data collected through juan375.app is the operator of the juan375 platform, a company operating under a license issued by the Philippine Amusement and Gaming Corporation (PAGCOR).

2.2  As a PAGCOR-licensed operator, juan375 is subject to regulatory oversight that includes data handling requirements specific to the Philippine gaming industry. PAGCOR may require juan375 to submit certain player data reports as part of its ongoing regulatory supervision — this constitutes a legal obligation and is not a discretionary disclosure.

2.3  Juan375 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with RA 10173 and this Privacy Policy. You may contact the DPO via the support channels listed in Section 14 of this Policy.

3.1  Juan375 collects personal data through three primary channels: information you provide directly, information collected automatically during your use of the platform, and information received from third-party service providers.

• Philippine mobile number (primary account identifier and OTP verification channel);
• Password (stored in hashed form — juan375 does not have access to your plaintext password);
• Full legal name (required for KYC verification prior to first withdrawal);
• Date of birth (required to verify minimum age of 21 years pursuant to PAGCOR requirements);
• Government-issued ID information — ID type, ID number, and ID images (for KYC verification);
• Bank account or e-wallet details (for processing withdrawals to GCash, Maya, BPI, BDO, or Metrobank);
• Communications sent to juan375's support team via live chat or email, including content and metadata.

• IP address and approximate geographic location;
• Device type, operating system, and browser version;
• Session start and end times, session duration, and game activity during each session;
• Pages viewed and navigation paths within the platform;
• Deposit and withdrawal transaction records, including amounts, timestamps, and payment method used;
• Wagering history — games played, wager amounts, outcomes, and net win/loss per session;
• Responsible gaming tool usage — deposit limits set, session reminders activated, cooling-off periods taken.

• Identity verification results from KYC service providers — confirming whether submitted ID documents are valid and match your provided details;
• Payment confirmation data from GCash, Maya, BPI, BDO, and Metrobank — transaction reference numbers and confirmation statuses;
• Fraud and anti-money laundering screening results from compliance service providers.

4.1  Juan375 processes your personal data only for specified, explicit, and legitimate purposes. The table below sets out the primary purposes for which your data is used, together with the data categories involved and the legal basis for each purpose:

4.2  Juan375 does not use your personal data for automated decision-making that produces legal or similarly significant effects without human oversight. Fraud detection algorithms that flag accounts for review trigger a human-led review process before any account action is taken.

5.1  Under the Data Privacy Act of 2012, juan375 relies on the following legal bases for processing personal data:

• Contractual necessity: Processing required to fulfil the account agreement between you and juan375 — including account access, game delivery, payment processing, and customer support;
• Legal obligation: Processing required to comply with Philippine laws and PAGCOR licensing conditions — including KYC identity verification, Anti-Money Laundering Act (RA 9160) reporting, age verification, and PAGCOR regulatory reporting;
• Legitimate interest: Processing necessary for fraud detection, platform security, responsible gaming monitoring, and aggregate analytics — where these interests are not overridden by your privacy rights;
• Consent: Where juan375 relies on your consent for specific processing activities (such as optional marketing communications), you will be asked to provide explicit consent and may withdraw it at any time without affecting other processing activities.

6.1  Juan375 does not sell, rent, or share personal data with third parties for their independent marketing use. Personal data is shared only in the following specific and controlled circumstances:

Juan375 engages third-party service providers who process personal data on our behalf under data processing agreements that require them to maintain confidentiality and comply with RA 10173 standards. These include:

• Payment processors — GCash, Maya, BPI, BDO, Metrobank — receiving payment account and transaction data necessary to process deposits and withdrawals;
• KYC identity verification providers — receiving submitted government ID images and personal details to perform identity verification checks;
• Cloud hosting and infrastructure providers — who store platform data in secure, access-controlled environments;
• Customer support platform providers — who may process communications content in the course of delivering support services;
• Game studio providers — receiving pseudonymised player session identifiers necessary to deliver and authenticate game sessions.

Juan375 may disclose personal data to Philippine government authorities, PAGCOR, law enforcement agencies, or courts in the following circumstances:

• When required by PAGCOR as part of regular licensee reporting obligations;
• When required by the Anti-Money Laundering Council (AMLC) under the provisions of RA 9160 and its amendments;
• When required by a valid court order or lawful request from Philippine law enforcement;
• When disclosure is necessary to protect the vital interests of a person or to prevent fraud, money laundering, or other criminal activity.

7.1  Juan375 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, comply with legal obligations, or resolve disputes. The following retention periods apply:

7.2  Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in such a manner that it can no longer be linked to any identifiable individual. Anonymised aggregated data may be retained indefinitely for statistical analysis.

8.1  Juan375 implements the following technical and organisational security measures to protect personal data against unauthorized access, disclosure, alteration, and destruction:

• 256-bit SSL/TLS encryption on all data transmitted between your device and juan375 servers — ensuring that login credentials, payment data, and personal information cannot be intercepted in transit;
• Password hashing using industry-standard algorithms — juan375 does not store plaintext passwords and cannot retrieve your password, only reset it;
• Encryption at rest for sensitive personal data including KYC documents and payment account information;
• Role-based access controls ensuring that employee access to personal data is limited to what is strictly necessary for their job function;
• Two-factor authentication (2FA) available to all players — and required for all internal administrative access to systems holding personal data;
• Regular security audits and penetration testing of the juan375 platform infrastructure;
• Incident response procedures including a defined data breach notification process aligned with NPC (National Privacy Commission) requirements.

8.2  In the event of a personal data breach that poses a real risk to the rights and freedoms of affected individuals, juan375 will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected individuals as required by law and NPC guidelines.

9.1  Juan375 uses cookies and similar tracking technologies to operate the platform, maintain your session, remember your preferences, and analyse usage patterns. The following categories of cookies are used:

• Strictly necessary cookies: Required for the platform to function. These include session authentication cookies that keep you logged in during a session. They cannot be disabled without affecting core platform functionality;
• Functional cookies: Remember your preferences such as language settings, display options, and preferred payment method for a smoother return visit experience;
• Analytics cookies: Collect aggregated, anonymised data about how players navigate and use the platform. Used to improve game lobby design, identify technical issues, and improve the mobile experience for Filipino players on Android devices;
• Security cookies: Help detect and prevent fraudulent login attempts, bot activity, and other security threats by tracking session patterns.

9.2  Juan375 does not use third-party advertising cookies or behavioural tracking for the purpose of targeting players across other websites. No cookie data from juan375 is shared with advertising networks.

9.3  You may configure your browser to reject or delete cookies. However, disabling strictly necessary cookies will prevent the juan375 platform from functioning correctly — including the ability to log in and maintain a session.

10.1  As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by juan375:

10.2  To exercise any of these rights, contact juan375's support team or Data Protection Officer via the channels in Section 14. Juan375 will respond to data subject requests within fifteen (15) business days. Complex requests may require up to thirty (30) business days with prior notification of the extension.

10.3  If you believe juan375 has not adequately addressed your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11.1  Age verification is conducted at registration through date of birth declaration and, upon first withdrawal, through government-issued ID verification. If juan375 discovers or has reasonable grounds to believe that personal data has been collected from a person under 21 years of age, the following steps will be taken immediately:

• The account will be suspended and access blocked pending investigation;
• The collected personal data will be assessed and any account balance handled per PAGCOR guidelines;
• The personal data of the underage individual will be deleted as soon as it is no longer required for the purposes of PAGCOR reporting and incident documentation;
• The incident will be reported to PAGCOR as required by our license conditions.

11.2  If you believe an individual under 21 has registered an account on juan375, please contact our support team immediately. We will investigate and take appropriate action within twenty-four (24) hours of receiving the report.

12.1  Juan375 uses player data — including wagering history, deposit frequency, session duration, and responsible gaming tool usage — to monitor for indicators of problematic gambling behaviour. This processing is carried out on the legal basis of PAGCOR regulatory obligation and legitimate interest in player welfare.

12.2  When juan375's systems or support team identify behavioural patterns consistent with problem gambling, we may proactively contact the player and provide information about responsible gaming tools. This outreach is a player protection measure, not a marketing communication, and cannot be opted out of while maintaining an active Account.

12.3  Self-exclusion requests and responsible gaming tool settings are recorded and retained for the duration of the exclusion or limitation period plus an additional period required by PAGCOR, to prevent circumvention through account re-registration. This retention is a legal obligation, not a discretionary choice.

12.4  If you submit a self-exclusion request, juan375 will process your exclusion information in a manner that prevents you from creating a new account during the exclusion period, even if you contact us requesting re-registration. Your wellbeing takes precedence over account activity.

13.1  Juan375 may update this Privacy Policy periodically to reflect changes in our data processing activities, new legal obligations, or guidance from the National Privacy Commission or PAGCOR. The "Last Updated" date at the top of this document will be revised whenever material changes are made.

13.2  For material changes that affect your rights or our processing purposes, juan375 will notify registered Players via their registered mobile number or by on-platform notification at least fourteen (14) days before the revised Policy takes effect, except where immediate changes are required by law.

13.3  The current version of this Privacy Policy is always accessible at juan375.app/privacy-policy. Continued use of the platform after the effective date of any revision constitutes acceptance of the updated Policy.

14.1  For any question, concern, or request relating to this Privacy Policy or juan375's data processing activities, you may contact our Data Protection Officer or support team through the following channels:

14.2  If your concern relates to a potential data breach or urgent security matter, please flag it as urgent in your message. Juan375 will prioritise security-related reports and respond within twenty-four (24) hours.

14.3  If you are not satisfied with juan375's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines — the government body responsible for enforcing RA 10173.