1. Data Controller
juan375 (referred to herein as "we", "us", or "the Company") is the data controller responsible for the personal information collected through the juan375.club platform and all associated services. As a PAGCOR-regulated online gaming operator, juan375 is bound by both the requirements of RA 10173 and the data governance standards set by the Philippine Amusement and Gaming Corporation.
Any queries regarding this Privacy Policy or the exercise of your data subject rights may be directed to the juan375 Data Protection Officer via the support contact details provided on this platform. We will respond to verified data subject requests within the period prescribed by applicable law.
2. Personal Data We Collect
juan375 collects personal data in the following categories, depending on the nature of your interaction with the platform:
2.1 Registration Data
- Full legal name, date of birth, and nationality;
- Email address and mobile phone number;
- Residential address (city, province, and country);
- Username and encrypted password credential.
2.2 Identity Verification (KYC) Data
- Government-issued photo identification (e.g., Philippine passport, PhilSys National ID, SSS card, driver's licence, or UMID);
- Proof of address documentation;
- Source of funds declaration where required under anti-money laundering obligations.
2.3 Financial Data
- Payment method details (e.g., GCash mobile number, PayMaya account reference, bank account details for BPI, BDO, or Metrobank transfers);
- Transaction history including deposits, withdrawals, and gaming activity records.
2.4 Technical & Usage Data
- IP address, device type, browser type, and operating system;
- Session data including login timestamps, pages visited, and game activity logs;
- Cookies and similar tracking technologies (see Section 8).
2.5 Communications Data
- Records of customer support interactions, including live chat transcripts and support ticket history;
- Records of any correspondence submitted through account dispute or complaint processes.
We do not collect sensitive personal information (as defined under RA 10173, such as health, racial, political, or religious data) unless specifically required for responsible gaming assessments or regulatory compliance, and only with your explicit consent.
3. Purpose of Processing
juan375 processes your personal data for the following specific, legitimate purposes:
- Account Management: Creating, maintaining, and securing your juan375 member account;
- Identity & Age Verification: Confirming that you are at least 21 years of age and eligible to access the platform under Philippine law;
- Payment Processing: Facilitating deposits and withdrawals through your chosen payment method and maintaining accurate transaction records;
- Regulatory Compliance: Meeting PAGCOR's reporting obligations, the Anti-Money Laundering Act (RA 9160 as amended), and the Data Privacy Act of 2012;
- Fraud Prevention & Security: Detecting and preventing fraudulent transactions, multiple account creation, and unauthorised access;
- Customer Support: Responding to your queries, resolving disputes, and processing responsible gaming requests;
- Marketing Communications: Sending you promotional offers, bonus notifications, and service updates — only where you have provided consent or where we have a legitimate interest, and subject always to your right to opt out;
- Platform Improvement: Analysing aggregated usage data to improve the performance, security, and game offering of the juan375 platform.
4. Legal Basis for Processing
Processing of your personal data by juan375 is carried out on the following legal bases as recognised under the Data Privacy Act of 2012:
- Contractual Necessity: Processing required to perform our obligations under the Member Account Terms & Conditions you accepted at registration;
- Legal Obligation: Processing required to comply with applicable Philippine laws, including PAGCOR licensing conditions and anti-money laundering regulations;
- Legitimate Interests: Processing carried out for fraud prevention, platform security, and service improvement where these interests are not overridden by your privacy rights;
- Consent: Processing for direct marketing communications and optional features, where you have provided explicit and freely given consent which you may withdraw at any time.
5. Data Sharing & Third Parties
juan375 does not sell, rent, or trade your personal data. We share personal data only in the following limited circumstances:
- Payment Service Providers: GCash, PayMaya, and partner banking institutions receive the minimum data necessary to process your transactions securely;
- KYC & Fraud Prevention Partners: Identity verification service providers who assist in age verification and fraud detection, operating under strict data processing agreements;
- Game Content Providers: Third-party game software providers may receive pseudonymised session data required to deliver and log game results. No directly identifiable personal data is shared for this purpose;
- Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), and other competent Philippine government authorities, where disclosure is required by law or regulatory obligation;
- Legal & Professional Advisers: Lawyers, auditors, and insurers where disclosure is necessary and subject to professional confidentiality obligations.
Where personal data is processed by third-party service providers on our behalf, juan375 ensures that appropriate data processing agreements incorporating adequate protection standards are in place.
6. Data Retention
juan375 retains your personal data for as long as is necessary to fulfil the purposes described in this Policy and to comply with our legal and regulatory obligations. The following general retention guidelines apply:
- Active Account Data: Retained for the duration of your active membership on juan375;
- KYC and Transaction Records: Retained for a minimum of five (5) years following account closure, in compliance with the Anti-Money Laundering Act;
- Marketing Consent Records: Retained for the period of consent and for up to one (1) year thereafter for evidentiary purposes;
- Technical Logs: Typically retained for 12 months, except where longer retention is required for fraud investigation or legal proceedings.
Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with a specific individual.
7. Security Measures
juan375 implements technical and organisational security measures appropriate to the risks associated with processing your personal data. These include:
- 256-bit SSL/TLS encryption for all data transmitted between your device and the juan375 platform;
- Encrypted storage of passwords using industry-standard hashing algorithms;
- Role-based access controls limiting employee access to personal data on a need-to-know basis;
- Regular security assessments and penetration testing of platform infrastructure;
- Two-factor authentication available to all juan375 members for enhanced account protection;
- Incident response procedures in place to address potential data breaches, including notification obligations under RA 10173.
While juan375 takes all reasonable precautions, no transmission over the internet or electronic storage system is completely secure. We encourage all members to use strong, unique passwords and to enable two-factor authentication on their juan375 account.
8. Cookies & Tracking Technologies
juan375 uses cookies and similar technologies to operate the platform, remember your preferences, and analyse usage patterns. The categories of cookies used are:
- Essential Cookies: Required for the platform to function correctly, including session management and security tokens. These cannot be disabled without impairing platform functionality;
- Functional Cookies: Store your preferences such as language settings and game lobby configuration;
- Analytics Cookies: Collect aggregated, anonymised data about how members navigate the platform, used solely to improve the user experience;
- Marketing Cookies: Used to deliver relevant promotional content based on your activity on juan375, where you have consented to receive marketing communications.
You may manage your cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from using the core juan375 platform.
9. Your Rights as a Data Subject
Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by juan375:
- Right to Be Informed: The right to know how your personal data is collected, used, and shared — as set out in this Privacy Policy;
- Right of Access: The right to obtain a copy of the personal data juan375 holds about you;
- Right to Rectification: The right to have inaccurate or incomplete personal data corrected;
- Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to applicable retention obligations;
- Right to Object: The right to object to processing based on legitimate interests, including direct marketing;
- Right to Data Portability: The right to receive your personal data in a structured, commonly used format;
- Right to File a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.
To exercise any of these rights, please contact the juan375 Data Protection Officer through the support channel available on the platform. We will process all verified requests within the timeframe required by law.
10. Minors
The juan375 platform is strictly restricted to individuals who are 21 years of age or older in accordance with Philippine gaming law and PAGCOR regulations. juan375 does not knowingly collect personal data from individuals under 21 years of age. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account. Any person who believes that a minor has registered an account on juan375 should notify us immediately through the platform's support channel.
11. Changes to This Policy
juan375 reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, or PAGCOR regulatory requirements. Material changes will be communicated to registered members via email or through a notice displayed upon login at least seven (7) days before the updated Policy takes effect. The date of the most recent revision is displayed at the top of this page. Your continued use of the juan375 platform following the effective date of any revision constitutes your acknowledgment of the updated Policy.