juan36 Privacy Policy

For the purposes of the Philippine Data Privacy Act (Republic Act No. 10173, as amended) and its Implementing Rules and Regulations, the data controller responsible for your personal information is juan36, operating the online gaming platform accessible at juan36.vip ("Platform").

juan36 is a PAGCOR-licensed gaming operator. As a regulated entity, juan36 is registered with the National Privacy Commission (NPC) of the Philippines as a personal information controller and complies with all applicable NPC circulars and advisories.

Questions and requests relating to this Privacy Policy or the processing of your personal data should be directed to our Data Protection Officer (DPO) — see Section 12 for contact details.

juan36 collects personal data from you directly (when you register, deposit, play, or contact us) and automatically (through the Platform itself). The categories of personal data we process are set out below.

juan36 uses the personal data described in Section 2 for the following purposes:

• Account Registration and KYC Verification: To create and manage your juan36 account, verify your identity and age (21+), and fulfil PAGCOR-mandated Know Your Customer requirements.
• Service Delivery: To provide access to gaming services, process bets, calculate and credit winnings, and operate the juan36 Platform in accordance with applicable game rules and these Terms.
• Payment Processing: To process deposits via GCash, PayMaya, BPI, BDO, Metrobank, and other available payment channels, and to process your withdrawal requests to verified payment accounts.
• Customer Support: To respond to your inquiries, resolve disputes, process complaints, and maintain records of our communications with you.
• Responsible Gaming: To administer self-exclusion requests, deposit limits, and other responsible gaming tools; to monitor for problem gambling indicators and take proactive responsible gaming measures as required by PAGCOR.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, money laundering, account takeovers, bonus abuse, and other prohibited conduct on the juan36 Platform.
• Legal and Regulatory Compliance: To comply with PAGCOR licensing conditions, AMLC reporting obligations, NPC data processing requirements, and any court or government authority orders.
• Platform Improvement: To analyse aggregate usage patterns, improve platform performance, and personalise the gaming experience — using anonymised or pseudonymised data where possible.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided consent. You may withdraw marketing consent at any time via your account settings.

Under the Philippine Data Privacy Act, juan36 processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform the contract between you and juan36 — including account creation, game operation, payment processing, and customer support.
• Legal Obligation: Processing required to comply with PAGCOR licensing conditions, AMLC anti-money laundering obligations, NPC registration requirements, and any applicable Philippine law or court order.
• Legitimate Interest: Processing for fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided freely given, informed, and specific consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

juan36 does not sell, rent, or trade your personal data to any third party for commercial purposes. We share personal data only in the following circumstances and only to the minimum extent necessary:

• Game Providers: We share limited technical session data with our game provider partners (such as JILI Games, Pragmatic Play, Evolution, and SA Gaming) solely to enable game functionality. Game providers do not receive your full identity or financial data.
• Payment Processors: Transaction-specific data is shared with GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors solely to execute deposit and withdrawal instructions.
• KYC/Identity Verification Providers: Identity document images and verification data may be processed by accredited KYC technology partners operating under data processing agreements that comply with RA 10173.
• PAGCOR: As our licensing authority, PAGCOR may require access to certain player records, transaction histories, and responsible gaming data as part of its regulatory oversight functions.
• AMLC and Law Enforcement: juan36 is legally required to report suspicious transactions to the Philippine Anti-Money Laundering Council (AMLC) and to cooperate with law enforcement authorities where required by Philippine law.
• IT and Infrastructure Providers: Cloud hosting, cybersecurity, and technical infrastructure providers may process technical and operational data strictly under confidentiality and data processing agreements.

The juan36 Platform uses cookies and similar tracking technologies to operate correctly and to enhance your user experience. We use the following categories of cookies:

• Strictly Necessary Cookies: Required for the Platform to function, including session authentication, login state management, and security tokens. These cannot be disabled without preventing Platform access.
• Performance Cookies: Used to collect anonymised analytics on how Filipino players use the Platform — page load times, navigation patterns, and error rates — to improve Platform performance.
• Functional Cookies: Remember your preferences such as language settings and responsible gaming limit configurations between sessions.
• Marketing Cookies: Used only where you have provided explicit consent, to personalise promotional communications and measure their effectiveness.

You may manage non-essential cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the juan36 Platform. juan36 does not use cross-site tracking cookies to follow your activity on third-party websites.

juan36 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 required by Philippine law and PAGCOR regulations:

• KYC and Identity Documents: Retained for a minimum of five (5) years following account closure, as required by PAGCOR and AMLC anti-money laundering regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years, in compliance with AMLC record-keeping requirements under RA 9160 (as amended).
• Gaming History: Retained for a minimum of two (2) years to support dispute resolution and responsible gaming monitoring.
• Customer Support Records: Retained for two (2) years following resolution of the relevant inquiry or complaint.
• Marketing Consent Records: Retained for the duration of your account plus one (1) year following account closure, to evidence your consent history.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised using industry-standard data destruction methods.

Under the Philippine Data Privacy Act, you have the following rights in relation to your personal data held by juan36. These rights may be exercised by submitting a written request to our Data Protection Officer (see Section 12):

• Right to be Informed: The right to be informed about the collection, use, and processing of your personal data — which this Privacy Policy fulfils.
• Right of Access: The right to request a copy of all personal data juan36 holds about you, and information about how it is being used.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected. You may update basic profile information directly in your account settings; for KYC data corrections, please contact support.
• Right to Erasure: The right to request deletion of your personal data, subject to overriding legal retention obligations (such as AMLC requirements that prevent immediate deletion of certain transaction records).
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes. All marketing emails from juan36 include an unsubscribe option.
• Right to Lodge a Complaint: If you believe juan36 has processed your personal data unlawfully, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

juan36 will respond to all data rights requests within thirty (30) days of receipt. Where a request is complex or numerous, we may extend this period by a further thirty (30) days and will inform you of the extension within the initial period.

juan36 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and juan36 servers.
• Encryption of sensitive data at rest, including KYC documents and financial account references.
• Role-based access controls ensuring that only authorised juan36 personnel with a legitimate business need can access personal data.
• Regular security assessments, penetration testing, and vulnerability scanning of Platform infrastructure.
• Two-factor authentication (2FA) available to all players and mandatory for internal administrative access.
• Secure deletion procedures for data that has reached the end of its retention period.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, juan36 will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, as required under RA 10173 and NPC Circular 16-03.

The juan36 Platform is strictly intended for individuals aged 21 years and older, as mandated by PAGCOR for casino-style gaming in the Philippines. juan36 does not knowingly collect personal data from persons under the age of 21.

If juan36 discovers that personal data has been collected from a person under 21 years of age, we will immediately close the associated account, delete the personal data, and report the matter to PAGCOR as required by applicable regulations.

juan36 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or PAGCOR and NPC regulatory requirements. When we make material changes, we will notify you by posting a prominent notice on the juan36 Platform and, where practicable, by sending a notification to your registered mobile number or email address.

The effective date at the top of this page will always reflect when the Policy was last updated. We encourage you to review this Privacy Policy periodically. Your continued use of the juan36 Platform after the effective date of any updated Privacy Policy constitutes your acknowledgment of the changes.

For all privacy-related inquiries, data rights requests, or concerns about how juan36 processes your personal information, please contact our Data Protection Officer:

• Data Protection Officer (DPO): juan36 Data Privacy Team
• Email: [email protected] (subject line: "Data Privacy Request")
• Live Chat: Available 24/7 via your logged-in juan36 account — ask to be connected to the privacy team
• Response Time: Within 10 business days for initial acknowledgment; full response within 30 days

If you are not satisfied with juan36's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines through their official government portal.