Juan 366 Privacy Policy — How We Handle Your Personal Data in the Philippines

1. Introduction

Welcome to the Privacy Policy of juan 366, the online gaming platform operated at https://juan366.click. This policy explains how we handle the personal information of every player, visitor, and prospective member who interacts with the juan 366 platform — whether you're browsing our games, creating an account, making a deposit, or contacting customer support.

At juan 366, we take data privacy seriously — not just because Philippine law requires it, but because Filipino players deserve to know exactly what happens to their information when they use our platform. This policy is written in plain language. There are no hidden clauses or deliberately confusing terms. What you read here is what we actually do.

By using the juan 366 platform, you acknowledge that you have read and understood this Privacy Policy. If you have questions about any part of it, our Data Protection Officer is reachable at privacy@juan366.click at any time.

2. Who We Are — Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act 10173) and its Implementing Rules and Regulations, the Data Controller responsible for your personal data is:

Juan 366 is licensed by the Philippine Amusement and Gaming Corporation (PAGCOR) and is registered with the National Privacy Commission (NPC) of the Philippines as a personal information controller. Our Data Protection Officer (DPO) oversees all matters related to the collection, use, and protection of personal data at juan 366 and is your primary point of contact for any privacy-related concern.

3. Personal Data We Collect

Juan 366 collects personal data in three ways: directly from you when you register or use the Platform, automatically as you interact with the Platform, and from third parties as permitted by law. Below is a complete breakdown of the categories of data we collect and why.

3.1 Sensitive Personal Information

Juan 366 does not intentionally collect sensitive personal information as defined under RA 10173 (such as health, political opinion, or sexual orientation) unless it is strictly necessary for PAGCOR regulatory compliance — for example, information about gaming addiction in the context of self-exclusion requests. Where sensitive personal information is required, we handle it with the highest level of care and with your explicit consent.

4. How We Use Your Personal Data

Juan 366 uses the personal data we collect for specific, legitimate purposes. We do not use your data for any purpose beyond what is listed here, and we do not use it in ways that are disproportionate to the purpose for which it was collected.

4.1 Account Management

Your Identity and Contact Data is used to create and maintain your juan 366 account, verify your identity during login, process password reset requests, and communicate important account-related notifications to you via SMS and email. This processing is necessary to perform the service contract between you and juan 366.

4.2 Payment Processing

Financial Data is used to process your deposits via GCash, Maya, and Philippine bank transfers, verify that withdrawals are sent to payment methods you own (same-source withdrawal policy), and maintain auditable financial records as required by PAGCOR and Philippine anti-money laundering regulations. Juan 366 never stores full payment credentials — we work with tokenised payment references from our licensed payment service partners.

4.3 Regulatory Compliance and AML

Juan 366 is required by PAGCOR licence conditions and Philippine Republic Act 9160 (Anti-Money Laundering Act, as amended) to monitor transactions, conduct Know Your Customer (KYC) checks, and report suspicious activity to the Anti-Money Laundering Council (AMLC) where legally obligated. This processing is required by law and cannot be opted out of while you hold a juan 366 account.

4.4 Platform Improvement and Personalisation

Behavioural and Gaming Data is used to understand how players use the Platform, identify technical issues, improve game loading performance for Philippine mobile networks, and personalise your experience — for example, showing games you've recently played or promotions relevant to your activity level. This data is used in aggregated or pseudonymised form wherever possible.

4.5 Responsible Gaming Monitoring

Juan 366 uses Gaming Data and Responsible Gaming Data to monitor for indicators of problematic gambling behaviour, as required by our PAGCOR licence. This includes detecting unusually rapid or escalating bet patterns, flagging players who may be approaching self-set limits, and proactively reaching out to players showing signs of distress. This processing is in your legitimate interest and is required by our regulatory obligations.

4.6 Customer Support

Communications Data is retained to ensure continuity of support — so that when you contact juan 366, the support team has context on previous interactions. This helps us resolve issues faster and more accurately. Support records are retained for a period consistent with the Data Retention section below.

4.7 Marketing and Promotions

With your consent, juan 366 may send you promotional communications about new games, bonuses, and special offers by SMS or email. You can withdraw this consent at any time by updating your communication preferences in your account settings or contacting our support team. Withdrawing marketing consent does not affect your ability to use the Platform or receive service-related communications.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, juan 366 processes personal data on the following legal grounds:

• Contractual Necessity: Processing required to fulfil the player account services agreement — account creation, deposits, withdrawals, game access, and customer support.
• Legal Obligation: Processing required to comply with PAGCOR licence conditions, the Anti-Money Laundering Act (RA 9160), the Philippine Data Privacy Act, and other applicable Philippine statutes.
• Legitimate Interest: Processing for fraud prevention, platform security, responsible gaming monitoring, and analytics — where our legitimate interest in operating a safe platform does not override your rights.
• Consent: Processing for direct marketing communications. You provide this consent during registration and can withdraw it at any time.

6. Who We Share Your Data With

Juan 366 does not sell, rent, or trade your personal data. We share your data only in the circumstances described below, and only with parties who are contractually obligated to protect it in accordance with Philippine data privacy law.

6.1 Payment Service Providers

To process your deposits and withdrawals, juan 366 shares the minimum necessary financial data with licensed Philippine payment service providers including GCash (GXI Inc.), Maya (PayMaya Philippines Inc.), Bancnet, and other bank partners. These providers are independently regulated by the Bangko Sentral ng Pilipinas (BSP) and have their own data protection obligations.

6.2 Game Studios and Technology Partners

Game studios that supply titles to the juan 366 platform — including JILI Gaming, Pragmatic Play, PG Soft, CQ9 Gaming, and Habanero — receive anonymised session data necessary for game delivery (such as session tokens), but do not receive your personal identity or financial information. All studio partners are required to sign Data Processing Agreements before integration.

6.3 Regulatory and Law Enforcement Authorities

Juan 366 shares data with Philippine regulatory authorities — including PAGCOR and the Anti-Money Laundering Council (AMLC) — as required by our licence and Philippine law. We may also disclose data to the National Privacy Commission (NPC) during an investigation, or to law enforcement authorities where a valid legal order or warrant has been issued.

6.4 Identity Verification and KYC Providers

To fulfil our PAGCOR-mandated KYC obligations, juan 366 may use licensed third-party identity verification services to verify the authenticity of government-issued IDs. These providers are NPC-registered and contractually bound to data minimisation and security standards.

6.5 Cloud Infrastructure and Security Providers

Juan 366 uses cloud infrastructure and cybersecurity services to operate the Platform securely. Providers who access personal data as part of infrastructure management are bound by Data Processing Agreements and strict confidentiality obligations. Infrastructure providers do not have the right to use your data for their own purposes.

7. Data Retention

Juan 366 retains personal data only for as long as necessary for the purposes outlined in this policy and as required by Philippine law. The following retention periods apply:

• Account and Identity Data: Retained for the duration of your active account plus five (5) years after account closure, as required by PAGCOR licence conditions and anti-money laundering regulations.
• Financial and Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act (RA 9160, as amended by RA 10927).
• Gaming History: Retained for three (3) years from the date of each session, unless required for longer retention by a regulatory investigation.
• Customer Support Records: Retained for two (2) years from the last interaction in each support case.
• Marketing Consent Records: Retained for the period of consent plus two (2) years after consent withdrawal, as evidence that consent was validly obtained.
• Technical and Behavioural Data: Retained for twelve (12) months for analytics purposes, after which it is aggregated and anonymised.

When the retention period expires, personal data is securely deleted or anonymised so that it can no longer be linked to you as an individual. We do not keep data "just in case" — retention is driven by legal obligation and operational necessity only.

8. Data Security

Juan 366 implements technical and organisational security measures appropriate to the risk of processing personal data in an online gaming environment. Our security posture is reviewed regularly and updated to reflect evolving threats and best practices.

8.1 Technical Measures

• 256-bit SSL/TLS encryption across all Platform communications — every page, every API call, every payment request
• Encrypted data storage — personal data at rest is encrypted using AES-256
• Multi-factor authentication available for player accounts and mandatory for all administrative access
• Payment tokenisation — full card and GCash credentials are never stored on juan 366 servers
• Intrusion detection systems and 24/7 security monitoring
• Regular penetration testing by independent cybersecurity firms

8.2 Organisational Measures

• Strict role-based access controls — staff access only the data necessary for their specific function
• Mandatory data privacy training for all juan 366 employees on an annual basis
• Formal data breach response plan registered with the NPC
• Vendor due diligence process for all third-party data processors

8.3 Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, juan 366 will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, as required by NPC Circular 16-03. Affected players will be notified directly without undue delay, with information about what data was involved and steps you can take to protect yourself.

9. Cookies and Tracking Technologies

Juan 366 uses cookies and similar tracking technologies to operate the Platform, remember your preferences, and analyse usage patterns. Here is a plain-language breakdown of the cookies we use and why.

You can manage your cookie preferences through your browser settings at any time. Clearing all cookies will log you out of the Platform and reset your preferences. For detailed information on managing cookies on your specific browser or Android device, refer to your browser's help documentation.

10. Your Rights as a Data Subject Under Philippine Law

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by juan 366. These rights are real and enforceable, and juan 366 is committed to honouring every request without undue delay.

How to Exercise Your Rights

To exercise any of the above rights, contact our Data Protection Officer at privacy@juan366.click with your full name, registered email address, the specific right you wish to exercise, and a brief description of your request. We will acknowledge your request within three (3) business days and respond fully within thirty (30) calendar days. If we need additional time due to the complexity of the request, we will inform you within the initial 30-day period.

11. Children's Privacy

Juan 366 is strictly an adults-only platform. The minimum age requirement is 21 years in accordance with Philippine gaming regulations. The Platform is not directed at, and does not knowingly collect personal data from, individuals under 21 years of age.

If you are a parent or guardian and believe that a minor has registered at juan 366 or has been using your account, please contact us immediately at support@juan366.click. We will investigate the matter promptly and, if confirmed, will close the account and delete any personal data associated with the minor in accordance with our legal obligations.

Juan 366 employs age verification checks during registration and may request government-issued ID to confirm a player's age during the KYC process. Accounts where age misrepresentation is confirmed will be permanently closed and any balances forfeited in accordance with our Terms and Conditions.

12. Cross-Border Data Transfers

Juan 366 primarily processes and stores personal data within the Philippines. In limited circumstances — such as using cloud infrastructure providers or game studio technology partners whose servers are located outside the Philippines — personal data may be transferred internationally.

Where such transfers occur, juan 366 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required by Philippine law. These safeguards include:

• Data Processing Agreements with contractual clauses that require the recipient to protect data to Philippine standards
• Transfers only to parties in jurisdictions with data protection laws recognised as adequate under NPC guidance
• Limiting the data transferred to the minimum necessary for the specific operational purpose

If you would like specific information about the safeguards applied to any particular cross-border transfer, please contact our DPO at privacy@juan366.click.

13. Changes to This Privacy Policy

Juan 366 may update this Privacy Policy from time to time to reflect changes in our data practices, new regulatory requirements, or improvements to our Platform. When we make material changes, we will notify you by email and/or through a prominent notice on the Platform at least seven (7) days before the changes take effect.

For non-material changes — such as minor clarifications or corrections of typographical errors — we may update the policy without prior notice, though the "Last Updated" date at the top of the policy will always reflect the current version. You are encouraged to review this policy periodically to stay informed about how juan 366 handles your personal data.

Your continued use of the Platform after any updated Privacy Policy takes effect constitutes your acknowledgement of the updated version. If you object to any changes, you should stop using the Platform and contact our DPO to discuss your options, including account closure.

14. Contact Us & Data Protection Officer

For all matters relating to this Privacy Policy, the exercise of your data subject rights, or any concerns about how juan 366 handles personal data, you can reach us through the following channels:

We aim to acknowledge all privacy-related requests within three (3) business days and respond fully within thirty (30) calendar days. Complex requests may take longer, but we will keep you informed throughout the process.

If you are not satisfied with our response, you have the right to escalate your concern to the National Privacy Commission of the Philippines. For information about the Platform's game rules and bonus terms, please see our Terms and Conditions. For responsible gaming tools and support resources, visit our Responsible Gaming page.