juan367 Privacy Policy

1. Who We Are and How to Contact Us

juan367 ("we," "us," "our") is a PAGCOR-authorized online gaming platform operated in the Republic of the Philippines and accessible at juan367.org. In the context of the Philippine Data Privacy Act of 2012 (RA 10173), juan367 acts as the Personal Information Controller with respect to personal data collected from players and site visitors.

For any privacy-related query, access request, correction request, or complaint, you may contact our Data Protection Officer at: [email protected] (plain text — not a clickable link). Please include "Privacy Request" in the subject line along with your registered account username. We aim to respond to all data subject requests within fifteen (15) business days.

2. Personal Data We Collect

juan367 collects the following categories of personal data in connection with the provision of its online gaming services:

• Identity data: Full legal name, date of birth, nationality, government-issued ID type and number (e.g., PhilSys, UMID, SSS, passport), and selfie photograph for KYC verification.
• Contact data: Philippine mobile number, email address, and residential address.
• Account data: Username, encrypted password hash, account creation date, and account status.
• Financial data: GCash account reference, Maya account reference, BPI/BDO account details (last four digits only), transaction history, deposit amounts, withdrawal amounts, and gaming balance history. Full payment instrument numbers are never stored by juan367 — these are handled by our PCI-DSS compliant payment processors.
• Gaming data: Game history, wagers placed, game outcomes, session durations, bonus utilization, and responsible gaming tool usage.
• Technical data: IP address, device type, browser type and version, operating system, and time zone setting.
• Usage data: Pages visited, features used, clickstream data, session timestamps, and navigation patterns within juan367.org.
• Communications data: Records of your communications with juan367 customer support, including chat logs and support ticket content.

3. How We Collect Your Data

juan367 collects personal data through the following means:

• Direct collection: Information you provide during account registration, KYC verification, deposit and withdrawal requests, form submissions, and support interactions.
• Automated collection: Technical and usage data collected automatically through cookies, server logs, and similar tracking technologies when you access juan367.org.
• Third-party sources: Identity verification services engaged for KYC purposes; payment processors (GCash, Maya, BPI, BDO) who provide transaction confirmation data; PAGCOR databases where applicable for self-exclusion status verification.

4. Purposes and Legal Bases for Processing

juan367 processes personal data for the following purposes, each supported by a lawful basis under the Data Privacy Act:

• Account creation and management — Contractual necessity (to provide the gaming service you have registered for).
• Identity and age verification (KYC) — Legal obligation (PAGCOR licensing conditions require identity verification and confirmation that players are 21 or older).
• Processing deposits and withdrawals — Contractual necessity.
• Anti-money laundering (AML) compliance — Legal obligation under Republic Act No. 9160 (Anti-Money Laundering Act) as amended, and PAGCOR AML guidelines.
• Game delivery and platform operation — Contractual necessity.
• Responsible gaming monitoring — Legal obligation (PAGCOR responsible gaming framework); legitimate interest (player protection).
• Customer support — Contractual necessity; legitimate interest.
• Platform security and fraud prevention — Legitimate interest.
• Promotional communications — Consent (you may withdraw consent at any time via account settings or by contacting our DPO).
• Analytics and platform improvement — Legitimate interest (processed on aggregated/anonymized basis where possible).
• Tax withholding and reporting to BIR — Legal obligation.

5. Sharing and Disclosure of Personal Data

juan367 does not sell your personal data. We may share personal data with third parties only in the following circumstances:

• Payment processors: GCash, Maya, GrabPay, BPI, BDO, and other payment service providers receive the minimum data necessary to process your transactions.
• KYC and identity verification providers: Third-party services engaged to verify government-issued IDs and perform liveness checks during account verification.
• Game providers: JILI and other game software providers may receive your player ID and session data necessary to deliver their games within the juan367 platform. They do not receive your name, contact details, or financial data.
• Regulatory authorities: PAGCOR, the Bureau of Internal Revenue (BIR), the Anti-Money Laundering Council (AMLC), and the National Privacy Commission (NPC) as required by law.
• Law enforcement: Philippine law enforcement agencies upon receipt of a valid legal process (court order, subpoena, or written request under applicable law).
• Professional advisors: Legal counsel, auditors, and accountants, bound by professional confidentiality obligations.

6. International Transfers

Some of juan367's technology infrastructure and game providers may be located outside the Philippines. Where personal data is transferred internationally, juan367 ensures that appropriate safeguards are in place — including contractual data protection clauses equivalent to Philippine Data Privacy Act standards — and that such transfers are limited to data strictly necessary for the contracted service. No international transfers of KYC identity documents or financial transaction records are made except where required by PAGCOR-supervised compliance processes.

7. Data Retention

juan367 retains personal data for the following periods:

• Active account data: For the duration of your active juan367 account.
• Post-closure account and transaction data: Five (5) years following account closure, as required by PAGCOR licensing conditions and AMLA retention obligations.
• KYC documents: Five (5) years post-closure or as required by PAGCOR, whichever is longer.
• Tax records: Ten (10) years as required by BIR regulations.
• Support communications: Two (2) years from the date of the last interaction.
• Technical and usage data: Twelve (12) months on a rolling basis, unless required longer for security investigations.

Data that has exceeded its retention period and is no longer required for any legal, regulatory, or legitimate business purpose is securely deleted or anonymized.

8. Cookies and Tracking Technologies

juan367.org uses cookies and similar technologies to operate the platform and improve your experience. The categories of cookies used include:

• Strictly necessary cookies: Required for the platform to function — session authentication, security tokens, and load balancing. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and login state. Can be disabled, but some platform features may not work as expected.
• Analytics cookies: Collect aggregated data about how visitors use juan367.org to help us improve the platform. No personally identifiable data leaves our systems through these cookies.

juan367 does not use third-party advertising cookies or behavioral targeting cookies. You can manage cookie preferences through your browser settings. Disabling strictly necessary cookies will prevent access to the juan367 platform.

9. Security Measures

juan367 implements the following technical and organizational security measures to protect your personal data:

• TLS 1.3 encryption for all data in transit between your device and juan367 servers.
• AES-256 encryption for sensitive data at rest.
• One-way cryptographic hashing (bcrypt) for all stored passwords.
• SMS OTP two-factor authentication available for all player accounts.
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis.
• Regular third-party security assessments and penetration testing.
• Incident response procedures aligned with NPC Circular No. 16-03 breach notification requirements.

While juan367 implements industry-standard security measures, no online platform can guarantee absolute security. We encourage all players to use strong, unique passwords and to enable two-factor authentication on their juan367 accounts.

10. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by juan367:

• Right to be informed: To know what personal data juan367 holds about you and how it is processed — the purpose of this Privacy Policy.
• Right to access: To request a copy of the personal data juan367 holds about you.
• Right to correction: To request correction of inaccurate or incomplete personal data.
• Right to erasure or blocking: To request deletion of personal data that is no longer necessary, unlawfully processed, or collected without your consent — subject to juan367's legal retention obligations.
• Right to object: To object to processing based on legitimate interest, including processing for direct marketing purposes.
• Right to data portability: To receive your personal data in a structured, commonly used format for transfer to another controller.
• Right to damages: To claim compensation for damages suffered as a result of inaccurate, incomplete, or unlawfully processed data.
• Right to complain: To lodge a complaint with the National Privacy Commission (NPC) at privacy.gov.ph if you believe your data rights have been violated.

To exercise any of these rights, contact our Data Protection Officer at [email protected] with the subject line "Data Subject Request." We will respond within fifteen (15) business days. Some requests may require identity verification before we can action them.

11. Children and Minors

juan367 does not knowingly collect personal data from individuals under the age of 21. The juan367 platform is strictly for adults aged 21 and above as mandated by PAGCOR. If we become aware that personal data has been collected from a person under 21, we will immediately close the associated account, delete the data in accordance with our retention policy, and report the matter to PAGCOR as required. If you believe a minor has registered on juan367, please contact our Data Protection Officer immediately.

12. Amendments to This Policy

juan367 may update this Privacy Policy to reflect changes in our data practices, platform features, or applicable law. Material changes will be communicated to registered players via SMS or in-platform notification at least seven (7) days before taking effect. The "Last Updated" date at the top of this Policy reflects the most recent revision. Continued use of juan367 after the effective date of an updated Policy constitutes acceptance of the revised terms.

13. Complaints and Data Protection Officer

If you have a concern or complaint about how juan367 handles your personal data, we encourage you to contact our Data Protection Officer first so that we can attempt to resolve the matter directly. If your concern remains unresolved, you may lodge a formal complaint with the National Privacy Commission (NPC) of the Philippines. Information about the NPC complaint process is available at the NPC's official website.

Data Protection Officer contact: [email protected] (plain text — not a clickable link). Please include "Privacy Complaint" in the subject line.