juan345 Privacy Policy

Juan345 ("the Platform," "we," "us," or "our") operates the online gaming and sports betting platform accessible at juan345.app. As a PAGCOR-regulated operator serving Filipino players across the Philippines — from Metro Manila to Cebu, Davao, Iloilo, Cagayan de Oro, and beyond — we process personal data in the course of providing our services.

This Privacy Policy ("Policy") describes the personal data we collect about you when you use the juan345 Platform, the purposes for which we use that data, the legal basis for processing, how long we retain data, and the rights available to you under the Philippine Data Privacy Act of 2012 ("DPA") and its Implementing Rules and Regulations ("IRR").

This Policy applies to all Players, registered users, and visitors of the juan345 Platform. It should be read together with our Terms & Conditions and our Responsible Gaming Policy, both of which are incorporated into the juan345 player agreement by reference.

By creating an account on, accessing, or using the juan345 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and processing of your personal data as described herein.

For the purposes of the Philippine Data Privacy Act of 2012, juan345 acts as the Personal Information Controller (PIC) in respect of all personal data collected from players and users of the Platform. As PIC, juan345 is responsible for determining the purposes and means of processing your personal information.

Juan345 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the DPA and this Privacy Policy, handling data subject rights requests, and liaising with the National Privacy Commission (NPC). You may contact the DPO at [email protected].

Where juan345 engages third-party service providers to process personal data on its behalf — such as payment processors (GCash, Maya), KYC verification providers, and game software providers — those parties act as Personal Information Processors (PIPs) and are contractually bound to process data only in accordance with juan345's instructions and in compliance with the DPA.

Juan345 collects the following categories of personal data in the course of operating the Platform:

Juan345 does not collect sensitive personal information as defined under Section 3(l) of the DPA (such as health or medical information, religious or political beliefs, genetic data, or criminal history) unless specifically required by PAGCOR regulations or applicable Anti-Money Laundering law and with your prior written consent where required.

4.1 Directly from You

The majority of personal data we hold about you is provided directly by you during:

• Account registration (name, email, mobile number, date of birth);
• KYC document submission (government ID, selfie photograph, proof of address);
• Payment transactions (GCash number, bank account details for withdrawals);
• Customer support interactions (live chat, email, and in-Platform messaging); and
• Completion of responsible gaming tools and preference settings.

4.2 Automatically via Platform Technology

When you access and use the juan345 Platform, we automatically collect technical and usage data through:

• Server logs that record your IP address, browser type, and access timestamps;
• Cookies and similar tracking technologies (see Section 10 for details);
• Gaming platform analytics that record your in-session activity, game choices, betting patterns, and session durations; and
• Device fingerprinting used for fraud detection and account security purposes.

4.3 From Third Parties

Juan345 may receive personal data about you from third parties in the following circumstances:

• From identity verification partners during the KYC process (e.g., verification against Philippine government ID databases where permitted);
• From payment processors (GCash, Maya, BPI, BDO) in connection with transaction processing and fraud prevention; and
• From PAGCOR or other regulatory authorities in connection with regulatory compliance obligations.

Under the Philippine Data Privacy Act of 2012, juan345 processes your personal data on the following legal bases:

• Contractual Necessity (Section 12(b), DPA): Processing is necessary for the performance of the contract between you and juan345 — specifically, to operate your account, process deposits and withdrawals, provide access to games, and deliver customer support;
• Legal Obligation (Section 12(c), DPA): Processing is required to comply with legal obligations including PAGCOR licensing conditions, the Anti-Money Laundering Act (Republic Act No. 9160 as amended), and the Data Privacy Act itself;
• Legitimate Interests (Section 12(f), DPA): Processing is necessary for juan345's legitimate interests in fraud prevention, platform security, responsible gaming monitoring, and business analytics, provided these interests are not overridden by your rights and freedoms; and
• Consent (Section 12(a), DPA): For non-essential processing activities such as direct marketing communications, we rely on your freely given, specific, and informed consent, which you may withdraw at any time.

Juan345 uses the personal data we collect for the following specific purposes:

6.1 Account Management and Service Delivery

To create and maintain your account, verify your identity through KYC, process deposits and withdrawals via GCash, Maya, and other Philippine payment channels, provide access to games and betting markets, and deliver all services offered through the Platform.

6.2 Regulatory Compliance and AML

To comply with juan345's obligations under its PAGCOR license, the Philippine Anti-Money Laundering Act (Republic Act No. 9160 as amended by RA 10365), applicable PAGCOR circulars, and any lawful direction from Philippine regulatory or law enforcement authorities. This includes monitoring transactions for suspicious activity and filing Suspicious Transaction Reports (STRs) where legally required.

6.3 Fraud Prevention and Security

To detect, investigate, and prevent unauthorized access, fraudulent activity, collusion, and other forms of misconduct on the Platform. Technical data including IP addresses, device identifiers, and session patterns are analyzed continuously for anomalies that may indicate fraudulent activity or account compromise.

6.4 Responsible Gaming

To monitor gaming behavior for indicators of problem gambling, to enforce deposit limits and self-exclusion requests, and to proactively reach out to players who may be exhibiting signs of gambling-related harm. This processing is conducted in accordance with juan345's responsibilities under its PAGCOR license and our Responsible Gaming Policy.

6.5 Customer Support

To respond to support inquiries, resolve disputes, process complaints, and improve the quality of our customer service. Live chat and email communications may be recorded and retained for quality assurance and training purposes.

6.6 Marketing and Promotions (with Consent)

To send you information about juan345 promotions, bonuses, new game launches, and sports betting offers via email or SMS, where you have opted in to receive such communications. You may unsubscribe at any time via the link in any marketing email or by contacting support.

6.7 Platform Analytics and Improvement

To analyze aggregated and anonymized usage data to understand how players interact with the Platform, identify areas for improvement, optimize game loading performance, and inform product development decisions.

Juan345 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share personal data with third parties only in the following circumstances:

7.1 Service Providers (Personal Information Processors)

We share data with carefully vetted third-party service providers who process data on our behalf, including: payment processors (GCash / Maya / BPI / BDO) for transaction processing; KYC and identity verification technology providers; cloud hosting and infrastructure providers; game software suppliers and live casino streaming providers; and customer support platform providers. All such providers are bound by data processing agreements that restrict their use of your data to the specific service they provide to juan345.

7.2 Regulatory and Law Enforcement Authorities

Juan345 is required to share data with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities when required by law, regulation, court order, or other mandatory legal process. We will notify you of any such disclosure to the extent permitted by law.

7.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or part of juan345's business assets, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer and the acquiring entity will be required to honor this Privacy Policy.

Juan345 retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulation.

The following general retention periods apply:

• Account and identity data (KYC documents): Retained for the duration of your active account and for a minimum of 5 years after account closure, in compliance with PAGCOR licensing requirements and the Philippine AMLA;
• Transaction records: Retained for a minimum of 5 years from the date of each transaction, as required by the AMLA and Bureau of Internal Revenue (BIR) regulations;
• Gaming records: Retained for a minimum of 3 years from the date of play for dispute resolution and regulatory audit purposes;
• Customer support communications: Retained for a minimum of 2 years from the date of the final communication in each support thread; and
• Marketing preferences and communication logs: Retained until you withdraw consent or request deletion, subject to applicable minimum retention obligations.

Upon expiry of the applicable retention period, juan345 will securely delete or anonymize your personal data in accordance with industry-standard data destruction protocols.

Juan345 implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption in Transit: All data transmitted between your device and the juan345 Platform is encrypted using TLS 1.2 or higher (256-bit SSL). The Platform enforces HTTPS across all pages and APIs;
• Encryption at Rest: Sensitive personal data (including KYC documents and financial records) stored on juan345 servers is encrypted at rest using AES-256 encryption;
• Password Security: Passwords are stored as salted bcrypt hashes. Juan345 never stores plain-text passwords and has no mechanism to retrieve your password — only to reset it;
• Access Controls: Access to personal data by juan345 staff is restricted on a strict need-to-know basis, with role-based access controls and comprehensive audit logging of all data access events;
• Network Security: The Platform's infrastructure is protected by Web Application Firewalls (WAF), DDoS mitigation systems, intrusion detection systems, and regular security penetration testing;
• Two-Factor Authentication: Juan345 offers optional 2FA for all accounts and mandates enhanced authentication for administrative access to player data systems; and
• Security Incident Response: Juan345 maintains a documented security incident response plan. In the event of a personal data breach that poses a risk to your rights, juan345 will notify affected Players and the National Privacy Commission within 72 hours of becoming aware of the breach, as required under NPC Circular 2016-03.

Juan345 uses cookies and similar technologies (local storage, session storage, pixel tags) to operate and improve the Platform. Cookies are small text files stored on your device by your browser when you visit the Platform.

10.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies (keeping you logged in), security cookies (CSRF tokens), and load-balancing cookies. These cannot be disabled without breaking the Platform;
• Functional Cookies: Remember your preferences such as language settings, display preferences, and responsible gaming tool configurations; and
• Analytics Cookies: Used to understand how Players use the Platform — which games are most popular, how navigation flows work, and where technical issues occur. Data collected is aggregated and used solely to improve the Platform experience.

10.2 Managing Cookies

You may manage or disable non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the Platform — in particular, disabling strictly necessary cookies will prevent you from logging in. Most modern mobile browsers (Chrome on Android, Safari on iOS) support cookie management through the browser settings menu.

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by juan345:

• Right to be Informed (Section 16(a), DPA): To be informed of how your personal data is being processed — which this Privacy Policy fulfills;
• Right to Access (Section 16(b), DPA): To obtain a copy of the personal data we hold about you and information about how it is being processed. Requests will be fulfilled within 30 days;
• Right to Rectification (Section 16(c), DPA): To have inaccurate or incomplete personal data corrected. Note that corrections to KYC-verified data require re-submission of supporting documents;
• Right to Erasure or Blocking (Section 16(d), DPA): To request deletion or blocking of your personal data in certain circumstances — for example, where the data is no longer necessary for the purpose it was collected, or where you have withdrawn consent. This right is subject to juan345's legal retention obligations under the AMLA and PAGCOR regulations;
• Right to Object (Section 16(e), DPA): To object to the processing of your personal data for direct marketing purposes at any time, without needing to provide justification;
• Right to Data Portability (Section 18, DPA): To receive a copy of your personal data in a structured, commonly used, and machine-readable format, where technically feasible; and
• Right to File a Complaint (Section 16(f), DPA): To file a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated. Contact information for the NPC is available on the official NPC website.

To exercise any of these rights, submit a written request to juan345's Data Protection Officer at [email protected]. Please include your full name, registered email address, and a clear description of the right you are exercising. We will respond within 30 calendar days of receipt of your request.

The juan345 Platform is strictly intended for individuals aged 21 years and above, as required by PAGCOR's regulations governing online gaming in the Philippines. Juan345 does not knowingly collect personal data from individuals under the age of 21.

All applicants must verify their age as part of the mandatory KYC process. Any account found to belong to an individual under 21 will be immediately suspended, all balances forfeited, and personal data deleted in accordance with this Policy and applicable PAGCOR requirements.

If you believe that juan345 has inadvertently collected personal data from an individual under 21, please notify us immediately at [email protected]. We will take immediate steps to delete the data and close the associated account.

The juan345 Platform may contain references to or integrations with third-party services, including payment providers (GCash, Maya, BPI, BDO), game software providers, and customer support tools. When you interact with these third-party services, their own privacy policies govern the processing of your personal data by those parties, not this Policy.

Juan345 is not responsible for the privacy practices, data security measures, or content of third-party services. We encourage you to review the privacy policies of any third-party service you interact with in connection with your juan345 account, particularly the privacy policies of your payment provider (e.g., GCash's or Maya's privacy policy) before initiating a transaction.

Some of juan345's service providers — including cloud hosting infrastructure providers and game software suppliers — may be located outside the Philippines. Where personal data is transferred to a country outside the Philippines, juan345 ensures that appropriate safeguards are in place to protect your data, as required by Section 21 of the DPA and NPC circular guidelines on cross-border data transfers.

These safeguards include contractual data processing agreements incorporating standard data protection clauses aligned with NPC requirements, ensuring that the receiving party provides a level of data protection at least equivalent to that provided under Philippine law.

Juan345 does not transfer personal data to countries or entities known to provide inadequate data protection without first implementing appropriate safeguards and, where required, obtaining NPC approval.

Juan345 may update this Privacy Policy from time to time to reflect changes in our data practices, new regulatory requirements, or improvements to our services. All changes will be published on this page with an updated "Last Updated" date at the top of the Policy.

For material changes — meaning changes that significantly affect your privacy rights or how we process your data — juan345 will provide prior notice via the registered email address on file or through a prominent notice on the Platform, with a minimum of 14 days' notice before the changes take effect.

Your continued use of the juan345 Platform after a Privacy Policy update constitutes your acknowledgment of and, where applicable, consent to the updated Policy. If you do not agree to a material change, you have the right to request account closure before the change takes effect.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by juan345, please contact:

• Data Protection Officer: [email protected]
• Live Chat: Available 24/7 through the Platform interface — identify your inquiry as a privacy matter to be routed to the DPO team

We aim to respond to all privacy-related inquiries within 15 business days. Complex requests such as data access or erasure requests may require up to 30 calendar days.

If you are not satisfied with our response or believe we have not handled your personal data lawfully, you have the right to lodge a complaint with the National Privacy Commission (NPC), which is the independent Philippine government authority responsible for enforcing the Data Privacy Act of 2012. Information on how to file a complaint with the NPC is available through the NPC's official government channels.