🔐 juan465 Privacy Policy

Data Controller

1.1 For purposes of the Philippine Data Privacy Act of 2012 (RA 10173), juan465 ("Company," "we," "us," "our") acts as the Personal Information Controller (PIC) with respect to all personal data collected from users ("Players," "you") of the juan465.app platform and associated services.

1.2 As PIC, juan465 determines the purposes for which and the means by which personal data is processed, and is responsible for ensuring that processing complies with RA 10173, its Implementing Rules and Regulations (IRR), and applicable PAGCOR regulatory requirements.

1.3 Juan465 has appointed a Data Protection Officer (DPO). Questions, concerns, or formal data subject rights requests may be directed to the DPO via the contact details provided in Section 14 of this Policy.

Personal Data We Collect

2.1 Juan465 collects the following categories of personal data in connection with the operation of the Platform:

Identity Data:

• Full legal name as it appears on a Philippine government-issued ID;
• Date of birth (for mandatory age verification — 21+ requirement under PAGCOR rules);
• Nationality and country of residence;
• Government-issued ID number and document scans (submitted during KYC verification).

Contact Data:

• Philippine mobile number (Smart, Globe, or DITO network);
• Email address;
• Residential address (for KYC and AML compliance purposes).

Financial Data:

• GCash account number or registered mobile number;
• Maya account details;
• Bank account details (BPI, BDO, UnionBank) where used for deposits or withdrawals;
• Transaction history including deposit amounts, withdrawal amounts, and dates;
• Source of funds information where required under AML regulations.

Gaming Data:

• Game session records including games played, bets placed, wins, losses, and session duration;
• Bonus and promotion usage history;
• Responsible gaming settings and self-exclusion requests.

Technical Data:

• IP address and approximate geolocation;
• Device type, operating system, and browser type;
• Login timestamps and session activity logs;
• Cookies and similar tracking data (see Section 8).

How We Use Your Personal Data

3.1 Juan465 uses your personal data for the following purposes:

• Account Management: Creating and maintaining your juan465 account, verifying your identity, and managing your profile settings;
• Age Verification: Confirming that you meet the mandatory 21-year minimum age requirement under PAGCOR regulations;
• Payment Processing: Processing deposits via GCash, Maya, BPI, BDO, and other accepted methods, and executing withdrawal requests;
• Regulatory Compliance: Meeting our obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), and RA 10173;
• Customer Support: Responding to inquiries, resolving disputes, and providing technical assistance via live chat and email;
• Fraud & Security: Detecting, investigating, and preventing fraudulent activity, bonus abuse, money laundering, and unauthorized account access;
• Responsible Gaming: Monitoring gaming patterns for signs of problem gambling and administering deposit limits, loss limits, and self-exclusion requests;
• Platform Improvement: Analysing aggregate usage data to improve game selection, user interface performance, and payment processing reliability;
• Marketing Communications: Sending promotional offers and bonus notifications to Players who have consented to receive such communications. Players may withdraw consent at any time.

Legal Basis for Processing

4.1 Juan465 processes your personal data on the following legal bases as recognised under RA 10173:

• Contractual Necessity: Processing necessary to perform the contract between juan465 and the Player, including account operation and payment processing;
• Legal Obligation: Processing required to comply with PAGCOR licensing conditions, AMLA reporting obligations, NPC directives, and court orders;
• Legitimate Interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by the Player's data protection rights;
• Consent: Processing for marketing communications, where specific prior consent has been obtained and may be withdrawn at any time without affecting the legality of prior processing.

Data Sharing & Disclosure

5.1 Juan465 may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash (Mynt/G-Xchange), Maya Philippines, BPI, BDO, UnionBank, and other payment service providers — solely for the purpose of processing your deposits and withdrawals;
• Game Software Providers: JILI, Evolution Gaming, Pragmatic Play, PG Soft, and other certified providers — limited to session data necessary for game operation and RTP certification;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and Philippine law enforcement agencies — where disclosure is required by law, regulation, or lawful order;
• Identity Verification Partners: Third-party KYC service providers used to verify identity documents submitted by Players;
• Technology Service Providers: Cloud hosting, cybersecurity, customer support platform, and analytics vendors operating under contractual data processing agreements.

5.2 Juan465 does not sell, rent, disclose, or transfer your personal data to third-party advertisers, data brokers, or any entity for commercial marketing purposes not directly related to juan465 services.

International Data Transfers

6.1 Some of juan465's third-party service providers (including cloud infrastructure and certain game software providers) may process personal data outside of the Philippines. Where such transfers occur, juan465 ensures that appropriate safeguards are in place, including contractual clauses that impose data protection obligations equivalent to those required under RA 10173.

6.2 Juan465 will not transfer personal data to jurisdictions that do not provide an adequate level of data protection without first implementing appropriate contractual safeguards and, where required, notifying the National Privacy Commission.

Data Retention

7.1 Juan465 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account and KYC Data: Retained for a minimum of five (5) years from account closure, as required by PAGCOR licensing conditions and AMLA record-keeping obligations;
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction;
• Gaming Activity Logs: Retained for a minimum of three (3) years from the date of the relevant gaming session;
• Customer Support Records: Retained for two (2) years from the date of the support interaction;
• Marketing Consent Records: Retained for as long as the relevant marketing consent is active, plus two (2) years thereafter.

7.2 Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with juan465 data disposal procedures.

Cookies & Tracking Technologies

8.1 Juan465 uses cookies and similar tracking technologies (including local storage and session tokens) to operate and improve the Platform. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for Platform operation, user authentication, and session management. These cannot be disabled;
• Functional Cookies: Remember your preferences such as language settings and game lobby filters;
• Analytics Cookies: Collect aggregated, anonymised data about how Players use the Platform, used to improve performance and user experience.

8.2 You may configure your browser to refuse or delete cookies; however, disabling strictly necessary cookies will prevent you from logging into your juan465 account and using core Platform features.

Your Rights as a Data Subject

9.1 Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by juan465:

• Right to be Informed: The right to know how your personal data is being collected, used, and shared;
• Right of Access: The right to obtain a copy of your personal data held by juan465;
• Right to Rectification: The right to correct inaccurate or incomplete personal data;
• Right to Erasure / Blocking: The right to request deletion or blocking of personal data where it is no longer necessary for the purpose it was collected, subject to overriding legal obligations;
• Right to Object: The right to object to the processing of your personal data for marketing purposes or on grounds of legitimate interest;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format for transfer to another controller;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

9.2 To exercise any of the above rights, please contact the juan465 Data Protection Officer using the contact details in Section 14. We will respond within fifteen (15) business days. We may request verification of your identity before processing rights requests.

Children's Privacy

10.1 The juan465 Platform is strictly restricted to persons aged 21 years and above. Juan465 does not knowingly collect personal data from individuals under 21 years of age. If we become aware that personal data has been collected from an underage individual, we will immediately close the relevant account, delete the associated personal data, and may report the matter to PAGCOR.

10.2 Parents or guardians who have reason to believe that their child may have registered an account on juan465 are urged to contact our support team immediately via Live Chat or at [email protected].

Security Measures

11.1 Juan465 implements the following technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction:

• TLS 1.3 encryption for all data in transit between your device and juan465 servers;
• AES-256 encryption for personal data stored in juan465 databases;
• Bcrypt or equivalent hashing for all stored passwords;
• Multi-factor authentication (MFA) for all juan465 staff with access to personal data systems;
• Role-based access control (RBAC) limiting employee access to personal data on a strict need-to-know basis;
• Regular third-party penetration testing and security audits;
• 24/7 security monitoring and intrusion detection systems;
• Regular staff training on data privacy obligations under RA 10173.

11.2 While juan465 employs industry-standard security measures, no online platform can guarantee absolute security. Players are responsible for maintaining the confidentiality of their own account credentials and for enabling two-factor authentication on their juan465 account.

Third-Party Links

12.1 The juan465 Platform does not contain links to external third-party websites or services. In the event that future Platform updates include links to third-party resources, this Policy will be updated accordingly. Juan465 is not responsible for the privacy practices of any third-party websites that you may access independently.

Changes to This Privacy Policy

13.1 Juan465 reserves the right to update or amend this Privacy Policy at any time to reflect changes in law, regulatory requirements, or Platform operations. Material changes will be communicated to registered Players via email and/or a prominent notice on the Platform at least seven (7) days before the amended Policy takes effect.

13.2 The "Last updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of the juan465 Platform after the effective date of any amendment constitutes your acknowledgment of the updated Policy.

Contact & Complaints

14.1 For any questions, concerns, or formal data subject rights requests relating to this Privacy Policy or the processing of your personal data by juan465, please contact our Data Protection Officer:

14.2 If you are not satisfied with our response to a data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, the regulatory body responsible for enforcing RA 10173.

14.3 This Privacy Policy is governed by the laws of the Republic of the Philippines and is to be read in conjunction with the juan465 Terms & Conditions.