juan165 Privacy Policy

This Privacy Policy (the "Policy") is issued by juan165 (the "Platform," "We," "Us," or "Our") and applies to all personal data processed in connection with your use of the online gaming platform accessible at https://juan165.club (the "Website") and any related services, applications, or communications channels operated by juan165.

This Policy explains what personal information juan165 collects from you, the purposes for which it is processed, the legal bases that justify that processing, the parties with whom it may be shared, the period for which it is retained, the security measures applied to protect it, and the rights you hold as a data subject under Philippine law.

This Policy applies to all registered players, prospective players who visit the Website without completing registration, and any individual whose personal data is processed by juan165 in connection with the Platform. It should be read together with the Terms & Conditions and the Responsible Gaming Policy.

For purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, juan165 is the personal information controller responsible for the personal data of its registered players and Website visitors.

juan165 operates the Platform in compliance with applicable Philippine online gaming regulations, including those issued by the Philippine Amusement and Gaming Corporation (PAGCOR), and in compliance with the data protection framework administered by the National Privacy Commission (NPC) of the Philippines.

All data protection inquiries, access requests, correction requests, and complaints should be directed to the juan165 Data Protection contact channel described in Section 15 of this Policy.

juan165 collects the following categories of personal data, depending on your level of interaction with the Platform:

juan165 does not intentionally collect sensitive personal information (as defined under the DPA 2012) unless specifically required for regulatory compliance purposes, in which case such collection will be explicitly disclosed at the point of collection and handled with heightened security measures.

juan165 collects personal data through the following channels:

• Direct Provision: Information you provide when registering, completing KYC verification, contacting support, completing surveys, or updating your account settings.
• Automated Technical Collection: Technical data including IP addresses, device identifiers, and session logs collected automatically via server logs, analytics systems, and session tracking when you access the Website.
• Payment Processing: Transaction reference data and payment method confirmation details received from GCash, Maya, and banking partners when you make deposits or withdrawals.
• Game Providers: Session and outcome data received from game providers (such as JILI Gaming, PG Soft, and Pragmatic Play) through their server-to-server APIs when you play games hosted on the Platform.
• Third-Party Verification Services: Identity verification data returned by KYC service providers during the document verification process.
• Cookies and Similar Technologies: Session data, preference settings, and anonymised analytics data collected through the cookie mechanisms described in Section 6.

juan165 processes your personal data for the following purposes, each supported by the legal basis indicated:

• Account Registration and Management — To create and maintain your juan165 account, verify your identity, and provide access to Platform features. Legal basis: Performance of contract; consent.
• Payment Processing — To process deposits and withdrawals in Philippine Pesos via GCash, Maya, and partner banks, and to maintain transaction records. Legal basis: Performance of contract; legal obligation.
• KYC and Anti-Money Laundering Compliance — To verify player identity, conduct age verification (21+ requirement), and comply with Philippine anti-money laundering legislation and PAGCOR requirements. Legal basis: Legal obligation; legitimate interest in regulatory compliance.
• Responsible Gaming — To administer deposit limits, loss limits, self-exclusion requests, and cooling-off periods; to identify at-risk gaming behaviour patterns. Legal basis: Legal obligation; legitimate interest in player protection.
• Customer Support — To investigate, respond to, and resolve player support requests, disputes, and complaints. Legal basis: Performance of contract; legitimate interest.
• Fraud Prevention and Security — To detect, prevent, and investigate fraudulent activity, account takeover attempts, and prohibited conduct. Legal basis: Legitimate interest; legal obligation.
• Platform Improvement — To analyse aggregated, anonymised usage data to improve Platform performance, game selection, and user experience. Legal basis: Legitimate interest.
• Marketing Communications — To send you promotional offers, bonus notifications, and Platform news, where you have provided consent to receive such communications. Legal basis: Consent (withdrawable at any time).

juan165 uses cookies and similar tracking technologies to ensure proper Platform functionality, maintain your login session, and collect anonymised analytics data. The following cookie categories are in use:

• Essential Cookies: Required for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. They cannot be disabled without breaking core Platform functionality.
• Functional Cookies: Remember your Platform preferences, such as your preferred language, last-selected game category, and responsible gaming notification settings.
• Analytics Cookies: Collect anonymised data about how you interact with the Platform — which pages you visit, how long you spend on each section, and which game categories are most accessed. This data is aggregated and does not identify you personally.
• Security Cookies: Help juan165 detect and prevent fraudulent login attempts, account takeover activity, and unusual access patterns.

You may configure cookie preferences through your browser settings. Disabling essential cookies will impair your ability to log in and use the Platform. juan165 does not use third-party advertising cookies or behavioural targeting cookies.

juan165 does not sell, rent, or trade your personal data to any third party for commercial purposes. Personal data is shared only in the following circumstances and only to the extent necessary for the stated purpose:

• Payment Service Providers: GCash, Maya, BPI, BDO, UnionBank, and other payment partners receive transaction data necessary to process your deposits and withdrawals. These providers are bound by their own data protection obligations under Philippine law.
• Game Providers: JILI Gaming, PG Soft, Pragmatic Play, and other integrated game studios receive the minimum player session data required to deliver game functionality, validate fair play, and return outcome results to the Platform.
• KYC and Identity Verification Services: Third-party KYC service providers process identity document images and verification data on juan165's behalf under data processing agreements that bind them to equivalent data protection standards.
• Regulatory and Law Enforcement Authorities: juan165 will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other Philippine government agencies where required to do so by law, court order, or valid legal process.
• Fraud Prevention Services: Where necessary to detect or prevent fraud, data may be shared with industry fraud prevention networks or law enforcement agencies.
• Professional Advisers: Legal, accounting, and compliance advisers may access personal data under professional confidentiality obligations where necessary to provide their services to juan165.

Some of the third-party service providers engaged by juan165 — including game providers and cloud infrastructure partners — may process personal data outside the Philippines. Where such transfers occur, juan165 ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under Philippine law.

These safeguards include contractual data protection clauses, adequacy assessments of the recipient country's data protection framework, and, where applicable, binding corporate rules. juan165 does not transfer personal data to jurisdictions that do not offer an adequate level of data protection without implementing the contractual and technical safeguards described above.

juan165 retains personal data only for as long as necessary to fulfil the purposes described in this Policy or as required by applicable law. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of your active account relationship with juan165, plus a minimum of five (5) years following account closure, as required by Philippine anti-money laundering regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with the Anti-Money Laundering Act (AMLA) and related PAGCOR recordkeeping requirements.
• Gaming Activity Logs: Retained for a minimum of three (3) years to support dispute resolution, responsible gaming monitoring, and regulatory reporting obligations.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, to support ongoing dispute resolution and quality improvement.
• Technical and Session Data: Retained for up to twelve (12) months for security monitoring, fraud detection, and Platform performance analysis.
• Marketing Consent Records: Retained for the duration of your consent to receive marketing communications plus three (3) years, to demonstrate compliance with consent requirements.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be associated with any identified or identifiable individual.

As a data subject under the Philippine Data Privacy Act of 2012, you hold the following rights with respect to personal data held by juan165. You may exercise any of these rights by contacting us through the channels described in Section 15.

juan165 will respond to data subject rights requests within thirty (30) calendar days of receipt. Where a request is complex or involves a large volume of data, the response period may be extended by a further sixty (60) days, with notice provided to you before the initial 30-day period expires.

juan165 implements a comprehensive set of technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: Personal data is encrypted at rest using AES-256 encryption and in transit using TLS 1.2 or higher. Financial data and identity documents receive additional encryption layers.
• Access Controls: Access to personal data within juan165's systems is restricted to personnel with a legitimate operational need, enforced through role-based access controls and multi-factor authentication requirements.
• Network Security: The Platform is protected by enterprise-grade firewalls, intrusion detection systems, and regular penetration testing by independent security professionals.
• Data Minimisation: Systems are designed to minimise the personal data accessible to any single team member or operational process, reducing the blast radius of any potential internal data incident.
• Security Monitoring: Automated systems monitor for anomalous access patterns, unusual login behaviour, and potential data exfiltration indicators on a continuous basis.
• Incident Response: juan165 maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, juan165 will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected individuals without undue delay.
• Staff Training: All juan165 staff who handle personal data receive data protection training covering their obligations under the DPA 2012 and this Policy.

juan165 is strictly an adults-only platform. Registration and use of the Platform is prohibited for individuals under twenty-one (21) years of age, in accordance with PAGCOR regulations applicable to online gaming in the Philippines.

juan165 does not knowingly collect personal data from individuals under 21 years of age. If juan165 becomes aware that personal data has been collected from a minor — whether through misrepresentation of age during registration or any other means — the relevant account will be immediately suspended, all transactions will be reviewed and potentially voided, and the personal data of the minor will be deleted from juan165's systems without undue delay.

If you believe that a person under 21 years of age has registered or is using a juan165 account, please contact juan165 immediately via the support channels described in Section 15.

The juan165 Platform may contain references to third-party payment service providers (GCash, Maya, BPI, BDO, UnionBank) and integrated game provider platforms. When you interact with these third-party services, you are subject to their own privacy policies and data practices.

juan165 is not responsible for the privacy practices, security measures, or data handling of third-party platforms or services accessed in connection with your use of juan165. We encourage you to review the privacy policies of any third-party service with which you interact in connection with your juan165 account — particularly those of your chosen payment method provider.

juan165 reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, data processing practices, or Platform features. Where amendments are material — meaning they significantly change how your personal data is processed or your rights as a data subject — juan165 will provide at least fourteen (14) days' advance notice via email to your registered address or via a prominent in-Platform notification.

Minor amendments (such as clarifications, formatting updates, or corrections that do not change the substance of data processing) may be made without advance notice. The "Effective Date" and "Last Updated" dates at the top of this Policy will be updated to reflect the current version.

Your continued use of the juan165 Platform after any amendment's effective date constitutes your acknowledgement of the updated Policy. If you do not accept an amended Policy, you may request account closure before the amendment takes effect.

For all privacy-related inquiries, data subject rights requests, and data protection complaints, please contact juan165 through the following channels:

• Data Protection Inquiries Email: [email protected] — use the subject line "Data Privacy Request" for all formal DPA-related matters
• Customer Support (24/7 Live Chat): Available through the Platform interface for general account and privacy questions
• Response Time: juan165 will acknowledge all data subject rights requests within five (5) business days and will provide a substantive response within thirty (30) calendar days

Complaints to the National Privacy Commission. If you are not satisfied with how juan165 has handled your personal data or responded to your data subject rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information on how to file a complaint with the NPC is available on the NPC's official website.