Privacy Policy – Juan 365 | Your Data, Protected

1. Who We Are

Juan 365 is an online gaming and sports betting platform operated under a valid gaming licence and designed specifically for Filipino players. Our website is accessible at https://juan365.wine. When this privacy policy refers to "Juan 365," "we," "us," or "our," it means the entity responsible for operating this platform and processing your personal data.

As a data controller, Juan 365 is responsible for deciding how and why your personal information is processed. We are committed to upholding the rights of every registered member and visitor in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules enforced by the National Privacy Commission (NPC) of the Philippines.

2. Data We Collect

When you use Juan 365, we may collect the following categories of personal information:

2.1 Information You Provide Directly

• Registration details: full name, date of birth, email address, mobile number, and username.
• Identity verification (KYC): government-issued ID (e.g., PhilSys ID, passport, driver's licence), selfie photos, and proof of billing address — required to verify your identity and comply with anti-money laundering regulations.
• Financial information: your preferred payment method details (GCash mobile number, Maya account, bank account number for BDO, BPI, or UnionBank transfers, or Visa/Mastercard card details) for processing deposits and withdrawals. We do not store full card numbers on our servers.
• Communications: messages you send to our customer support team via live chat or email.

2.2 Information Collected Automatically

• Device and technical data: IP address, browser type and version, operating system, device model, and screen resolution.
• Usage data: pages visited, games played, session durations, click patterns, referal source, and betting history.
• Location data: approximate geographic location derived from your IP address, used to ensure you are accessing the platform from an eligible jurisdiction.
• Cookies and similar technologies: see Section 6 for full details.

2.3 Information From Third Parties

• Identity verification providers and fraud-screening services.
• Payment processors (GCash, Maya, GrabPay, Coins.ph, InstaPay/PESONet, and card payment networks) who confirm transaction statuses.
• Analytics partners who help us understand how players interact with the platform — always in anonymised or aggregated form.

3. How We Use Your Data

Juan 365 only uses your personal information for legitimate, necessary purposes. Specifically, we use it to:

• Create and manage your player account and provide access to all Juan 365 games and features.
• Process deposits and withdrawals through your chosen payment method, whether that's GCash, Maya, GrabPay, or bank transfer.
• Verify your identity and age (you must be at least 21 years old to register), as required by Philippine gaming regulations.
• Detect, prevent, and investigate fraudulent activity, money laundering, and unauthorised access to accounts.
• Provide customer support and respond to your enquiries or complaints promptly.
• Send you account-related notifications such as deposit confirmations, bonus alerts, and security updates.
• Comply with legal and regulatory obligations including anti-money laundering (AML) laws and responsible gaming requirements.
• Improve our platform, games, and services based on aggregated usage analytics.
• Send you promotional communications about bonuses, new games, and events — but only if you have opted in to receive these.

4. Legal Basis for Processing

Juan 365 processes your personal data based on one or more of the following legal grounds:

• Contractual necessity: Processing is needed to fulfil the terms of your account agreement — for example, to process your bets or pay out winnings.
• Legal obligation: Certain data must be collected and retained to comply with Philippine AML laws, gaming regulations, and NPC requirements.
• Legitimate interests: We process some data (like IP addresses and usage logs) to maintain platform security and prevent fraud, balanced against your privacy rights.
• Consent: For marketing communications and non-essential cookies, we only process your data with your explicit consent, which you can withdraw at any time.

5. Data Sharing and Disclosure

We do not sell your personal information. Period. However, there are limited circumstances where we share data with trusted third parties:

• Payment processors: GCash, Maya, GrabPay, Coins.ph, InstaPay/PESONet, BDO, BPI, UnionBank, and Visa/Mastercard networks — only to complete transactions you authorise.
• Identity verification partners: To confirm your identity and run legally required KYC and AML checks.
• IT and infrastructure providers: Cloud hosting and security service providers who process data on our behalf under strict data processing agreements.
• Regulatory authorities: We may disclose your data to PAGCOR, the NPC, the AMLC, or law enforcement agencies when legally required or when we reasonably believe disclosure is necessary to protect rights, property, or safety.
• Business transfers: In the event of a merger, acquisition, or asset sale, your data may be transferred to the acquiring entity, who will be bound by this privacy policy.

All third-party service providers are contractually obligated to handle your data securely and only for the specific purpose for which it was shared.

6. Cookies and Tracking Technologies

Juan 365 uses cookies and similar technologies to make the platform work properly and improve your experience. Here's a breakdown:

• Essential cookies: These are required for core platform functions like keeping you logged in and remembering your preferences. You cannot opt out of these without losing platform functionality.
• Analytics cookies: Help us understand which pages and games are most popular so we can improve the platform. We use anonymised data for this.
• Preference cookies: Remember settings like your chosen language or display preferences.
• Marketing cookies: Used only with your consent to show you relevant promotions. You can manage these through your browser settings or our cookie preferences panel.

Most browsers let you control cookies through their settings. Disabling all cookies may limit some features of Juan 365.

7. Data Retention

Juan 365 keeps your personal data for as long as necessary to fulfil the purposes outlined in this policy, including legal, accounting, and regulatory requirements. Specifically:

• Active account data: Retained for the duration of your account and for five (5) years after account closure, in line with AML obligations under Philippine law.
• Transaction records: Kept for a minimum of five (5) years as required by the Anti-Money Laundering Act.
• KYC documents: Retained for five (5) years after your last transaction or account closure.
• Customer support communications: Retained for up to two (2) years to help resolve disputes or recurring issues.
• Marketing preferences: Kept until you withdraw consent or request deletion.

When data is no longer needed, we securely delete or anonymise it so it can no longer be linked to you.

8. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights over your personal information held by Juan 365:

• Right to be informed: You have the right to know what data we collect and how we use it — that's exactly what this policy is for.
• Right of access: You can request a copy of the personal data we hold about you.
• Right to rectification: If any of your data is inaccurate or incomplete, you can ask us to correct it.
• Right to erasure: You can request deletion of your personal data, subject to our legal obligations to retain certain records.
• Right to object: You can object to the processing of your data for direct marketing purposes at any time.
• Right to data portability: You may request your data in a structured, commonly used format.
• Right to file a complaint: If you believe your rights have been violated, you may file a complaint with the National Privacy Commission (NPC) of the Philippines at privacy.gov.ph.

To exercise any of these rights, email us at privacy@juan365.wine. We will respond within 15 working days.

9. How We Protect Your Data

Juan 365 employs industry-standard technical and organisational measures to protect your personal information from unauthorised access, alteration, disclosure, or destruction:

• TLS/SSL encryption on all data in transit between your browser and our servers.
• AES-256 encryption for sensitive data stored in our databases.
• Two-factor authentication (2FA) available for all player accounts — we strongly encourage you to enable it.
• Regular security audits and penetration testing conducted by independent cybersecurity professionals.
• Access controls: Strict role-based access ensures only authorised staff can view sensitive data, and all access is logged and auditable.
• Incident response plan: In the unlikely event of a data breach affecting your rights, Juan 365 will notify affected users and the NPC within 72 hours of discovery.

While we do everything we can to keep your data safe, no online platform can guarantee100% security. Please also do your part — use a strong, unique password and never share your login credentials with anyone.

10. Children and Minors

Juan 365 is strictly an18+ (and in the Philippines, 21+) platform in accordance with PAGCOR regulations. We do not knowingly collect personal information from anyone under the legal gambling age. If we discover that a minor has registered an account, we will immediately suspend the account, delete the personal data, and refund any funds in accordance with our terms.

If you believe a minor has accessed our platform, please contact us immediately at privacy@juan365.wine.

11. Changes to This Privacy Policy

Juan 365 may update this privacy policy from time to time to reflect changes in our practices, technology, legal requirements, or business operations. When we make material changes, we will:

• Update the "Last updated" date at the top of this page.
• Post a notice on the Juan 365 homepage or send you an email notification if the changes significantly affect your rights.

We encourage you to review this policy periodically. Your continued use of Juan 365 after any changes are posted constitutes your acceptance of the updated policy.

12. Contact Us

If you have any questions, concerns, or requests related to this privacy policy or how Juan 365 handles your personal data, don't hesitate to get in touch:

• Email: privacy@juan365.wine
• Data Protection Officer: Available via the same email address.
• Website: https://juan365.wine

For complaints that aren't resolved to your satisfaction, you may escalate to the National Privacy Commission of the Philippines.