juan165 Privacy Policy

1. Who We Are

juan165 ("the Company," "we," "us," or "our") operates the online gaming platform accessible at juan165.net (the "Platform"), which provides casino games, live dealer tables, bingo, slot titles, and related services to eligible players in the Philippines.

For purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules, juan165 acts as the Personal Information Controller (PIC) in respect of personal data collected through the Platform. We are responsible for ensuring that personal data under our control is processed in compliance with applicable Philippine data privacy legislation and, where relevant, internationally recognized data protection standards.

Inquiries relating to this Privacy Policy or your personal data may be directed to the juan165 Data Privacy Officer (DPO) via the support channels available on the Platform.

2. Data We Collect

juan165 collects the following categories of personal data in connection with your registration, use of the Platform, and compliance with legal obligations:

We collect personal data directly from you at registration, through your use of the Platform, and via KYC verification procedures. We may also receive data from payment processors (e.g., GCash, PayMaya) and fraud prevention service providers in connection with transaction verification.

3. How We Use Your Data

juan165 processes your personal data for the following purposes:

• Account Management — Creating, maintaining, and securing your juan165 account, including authenticating your identity at login and processing password recovery requests.
• Service Delivery — Enabling access to games, processing deposits and withdrawals, crediting bonuses, and providing customer support.
• Legal and Regulatory Compliance — Fulfilling obligations under Philippine law, including age verification (21+ requirement), Know Your Customer (KYC) procedures, Anti-Money Laundering Act (AMLA) reporting, and PAGCOR-mandated compliance requirements.
• Fraud Prevention and Security — Detecting, investigating, and preventing fraudulent transactions, unauthorized account access, and other prohibited activities as described in our Terms and Conditions.
• Responsible Gaming — Monitoring usage patterns to identify indicators of problem gambling and administering responsible gaming tools including deposit limits, session alerts, and self-exclusion.
• Platform Improvement — Analyzing aggregated, anonymized usage data to improve game performance, user interface design, and customer support processes.
• Marketing Communications — Sending promotional offers, bonus notifications, and platform updates to users who have opted in to receive such communications. You may opt out at any time.

juan165 does not use your personal data to make fully automated decisions that produce significant legal effects on you without human oversight, except where required by law.

4. Legal Basis for Processing

All personal data processing by juan165 is conducted on one or more of the following lawful bases as recognized under the Data Privacy Act of 2012 and its implementing rules and regulations:

• Contractual Necessity — Processing is necessary to perform the contract between you and juan165 (i.e., to provide the gaming services you have registered to access).
• Legal Obligation — Processing is required to comply with applicable law, including PAGCOR licensing requirements, KYC obligations, AMLA reporting duties, and age verification mandates.
• Legitimate Interest — Processing is necessary for the legitimate interests of juan165, including fraud prevention, platform security, and responsible gaming monitoring, provided those interests are not overridden by your rights and freedoms.
• Consent — Where processing is based on your consent (such as for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.

5. Data Sharing & Disclosure

juan165 does not sell, rent, or trade your personal data to third parties for their independent marketing purposes. We may share your personal data with the following categories of recipients, strictly as necessary and subject to appropriate data protection measures:

• Payment Processors — GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other payment service providers, for the purpose of processing deposits and withdrawals.
• Identity Verification Providers — Third-party KYC and identity verification services that assist in verifying user identity and age as required by regulation.
• Game Software Providers — Licensed game providers who supply the games available on the juan165 Platform and who may receive limited usage data necessary to operate their games correctly.
• Regulatory Authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other government bodies as required by Philippine law or pursuant to a lawful order.
• Fraud Prevention Services — Third-party security and fraud prevention providers engaged to protect the integrity of the Platform and its users.
• Professional Advisors — Legal, accounting, and audit professionals engaged by juan165 in connection with regulatory compliance or dispute resolution, subject to confidentiality obligations.

6. Cookies & Tracking Technologies

juan165 uses cookies and similar tracking technologies on the Platform to support essential functionality, improve user experience, and maintain security. The following categories of cookies may be in use:

• Strictly Necessary Cookies — Required for the Platform to function. These include session authentication cookies and security tokens. They cannot be disabled without impairing Platform functionality.
• Functional Cookies — Remember your preferences such as language settings, game lobby layout preferences, and responsible gaming tool configurations.
• Analytics Cookies — Collect anonymized, aggregated information about how users interact with the Platform, used to identify areas for improvement. No personally identifiable information is included in analytics data.
• Security Cookies — Support fraud detection, login verification, and brute-force protection systems.

You may configure your browser to refuse or delete cookies. However, disabling certain cookies may affect your ability to use Platform features, including account login. juan165 does not use third-party advertising or behavioral tracking cookies.

7. Data Retention

juan165 retains personal data for no longer than is necessary to fulfill the purposes for which it was collected, subject to the following retention standards:

• Active Account Data — Retained for the duration of your account registration plus a minimum of five (5) years following account closure, as required by Philippine AML regulations.
• KYC and Verification Documents — Retained for a minimum of five (5) years from the date of submission or from the date of account closure, whichever is later.
• Transaction Records — Retained for a minimum of five (5) years to meet PAGCOR and AMLC reporting and audit requirements.
• Support Communications — Retained for a minimum of two (2) years following the resolution of the relevant issue.
• Marketing Consent Records — Retained for the duration of the marketing relationship and for a reasonable period thereafter to demonstrate compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with juan165's data disposal procedures.

8. Data Security

juan165 implements a range of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform.
• Encryption of sensitive data at rest, including identity documents and payment method details.
• Role-based access controls limiting internal access to personal data to authorized personnel with a legitimate need.
• Multi-factor authentication requirements for administrative access to systems holding personal data.
• Continuous monitoring for unauthorized access attempts, anomalous activity, and security vulnerabilities.
• Regular third-party security audits and penetration testing of Platform infrastructure.

In the event of a personal data breach that is likely to affect your rights and freedoms, juan165 will notify the National Privacy Commission and, where required, affected data subjects within the timeframes prescribed by the Data Privacy Act of 2012.

9. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by juan165:

• Right to be Informed — The right to know that your personal data is being collected and the purposes for which it will be used, as detailed in this Privacy Policy.
• Right of Access — The right to obtain a copy of the personal data we hold about you and information about how it is being processed.
• Right to Rectification — The right to have inaccurate or incomplete personal data corrected. You may update certain information directly via your juan165 account settings.
• Right to Erasure — The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations.
• Right to Data Portability — The right to receive a structured, commonly used copy of the personal data you provided to us, in a machine-readable format where technically feasible.
• Right to Object — The right to object to processing based on legitimate interests, including direct marketing. Where marketing is concerned, we will stop processing immediately upon receipt of a valid objection.
• Right to Lodge a Complaint — The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of the above rights, please contact the juan165 Data Privacy Officer through the Platform's live chat or support email. We will respond within the timeframes required by applicable law.

10. Cross-Border Data Transfers

Some of the third-party service providers used by juan165 — including game software providers and identity verification services — may be located outside the Philippines. Where personal data is transferred internationally, juan165 ensures that appropriate safeguards are in place in accordance with Section 21 of the Data Privacy Act of 2012, including contractual clauses that require recipient organizations to maintain equivalent data protection standards.

Such transfers are conducted only where necessary to fulfill the purposes outlined in this Privacy Policy and are limited to the minimum data required for those purposes.

11. Children's Privacy

The juan165 Platform is strictly intended for adults aged 21 years and older. We do not knowingly collect, use, or store personal data from any individual under the age of 21. Age verification is enforced at registration and at the KYC verification stage for all accounts.

If juan165 becomes aware that personal data has been collected from a person under 21 years of age, that account will be immediately closed, all associated data will be deleted, and any funds deposited will be returned to the originating payment method after appropriate verification. If you believe a minor has registered on the Platform, please contact us immediately.

12. Contact & Policy Updates

juan165 reserves the right to update this Privacy Policy at any time. Material changes will be communicated via a prominent notice on the Platform or via email to registered users before the changes take effect. The "Last Updated" date at the top of this Policy reflects the most recent revision.

For all privacy-related inquiries, requests to exercise your data subject rights, or to contact the juan165 Data Privacy Officer, please use the Platform's 24/7 live chat support or send an email to the address displayed in the Platform footer. We are committed to responding to all privacy inquiries within the timeframes required under Philippine data protection law.

This Privacy Policy is governed by and construed in accordance with the laws of the Republic of the Philippines. Any disputes relating to data protection matters shall be subject to the jurisdiction of the National Privacy Commission in the first instance.