Privacy Policy — How juan135 Protects Your Personal Data

1. Who We Are

juan135 operates the online casino and sports betting platform accessible at juan135.net, serving Filipino players across Metro Manila, Cebu, Davao, Quezon City, Makati, and the broader Philippine archipelago. The platform offers real-money slots, live dealer games, sports betting, e-sabong, bingo, and crash games.

As the operator of juan135, we act as the Personal Information Controller (PIC) under RA 10173 — meaning we determine the purposes and means by which your personal data is processed. We have appointed a registered Data Protection Officer (DPO) to oversee compliance with the Data Privacy Act and to serve as your point of contact for all privacy-related matters.

2. Personal Data We Collect

juan135 collects personal data across several categories. The specific data points collected from any individual player will depend on the services they access and the verification stage of their account.

3. How We Collect Your Data

juan135 collects personal data through the following channels and mechanisms:

• Direct Provision: Information you provide directly during account registration, KYC document submission, cashier transactions, responsible gaming tool configuration, and support interactions.
• Automated Technical Collection: Data collected automatically when you access the platform — including IP address, device identifiers, session logs, and click-stream data — through server logs, cookies, and similar tracking technologies.
• Payment Processors: Transaction confirmation data received from GCash, Maya, GrabPay, InstaPay, and Philippine banking partners when you make deposits or request withdrawals.
• Identity Verification Partners: Where juan135 uses a third-party KYC verification service to cross-reference government ID data, that service may return verification results (pass/fail status and identity match scores) to juan135.
• PAGCOR & Regulatory Bodies: In limited circumstances, juan135 may receive information about a player from PAGCOR — for example, in relation to self-exclusion register checks or regulatory compliance notifications.

4. Why We Process Your Data — Purposes

juan135 processes personal data only for specific, declared, and legitimate purposes. The following table sets out each processing purpose and its justification:

5. Legal Bases for Processing

Under RA 10173, personal data must be processed on a recognised legal basis. juan135 relies on the following bases depending on the processing activity:

• Contractual Necessity: Processing required to fulfil the Terms and Conditions contract between juan135 and the player — including account management, gameplay, and financial transactions.
• Legal Obligation: Processing required to comply with applicable Philippine law — including KYC obligations under PAGCOR regulations, AML reporting under RA 9160, and data protection compliance under RA 10173.
• Legitimate Interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and service improvement — where these interests are not overridden by the data subject's rights and freedoms.
• Consent: For non-essential data processing — such as marketing communications and personalised game recommendations — juan135 relies on your freely given, informed, specific, and unambiguous consent. You may withdraw this consent at any time through your account settings without affecting the lawfulness of prior processing.

6. Data Sharing & Third-Party Disclosure

juan135 does not sell or rent personal player data. Data is shared only in the following limited, controlled circumstances:

• Payment Service Providers: GCash, Maya, GrabPay, BPI, BDO, Metrobank, InstaPay, and QR Ph — to process deposits and withdrawals. These providers operate under their own privacy policies and are bound by contractual data processing agreements with juan135.
• KYC / Identity Verification Partners: Third-party identity verification platforms engaged by juan135 to perform automated age and identity checks. These partners process only the minimum data required and are prohibited from using player data for any other purpose.
• Game Content Providers: Licensed game studios whose content is hosted on the juan135 platform may receive anonymised session data (game ID, bet amount, round outcome) for game integrity auditing purposes. They do not receive your personally identifiable information.
• PAGCOR and Government Authorities: juan135 is legally obligated to share player data with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other competent Philippine government bodies upon lawful request or as required by our operating licence.
• Law Enforcement: Where required by a valid court order, subpoena, or lawful request from Philippine law enforcement agencies investigating criminal activity.
• Corporate Transactions: In the event of a merger, acquisition, or restructuring of juan135's operating entity, player data may be transferred to the successor entity, subject to equivalent privacy protections being maintained.

7. Data Retention

juan135 retains personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required by Philippine law or PAGCOR regulations.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with juan135's data disposal procedures.

8. Cookies & Tracking Technologies

juan135 uses cookies and similar tracking technologies to operate the platform, maintain your session, detect fraud, and improve service quality. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for platform operation — including session authentication, security tokens, and fraud prevention signals. These cannot be disabled without impairing core platform functionality.
• Functional Cookies: Enable personalisation features such as language preferences, game lobby layout settings, and responsible gaming reminder configurations.
• Analytics Cookies: Collect aggregated, anonymised data about how players navigate the platform. This information is used to improve user experience and platform performance.
• Marketing / Preference Cookies: Used where you have consented to receive personalised game and promotion recommendations. These can be disabled through your account cookie preferences settings.

9. Your Data Subject Rights

Under Republic Act 10173, all Filipino data subjects hold the following rights with respect to their personal information. juan135 respects and upholds these rights in full:

10. Data Security Measures

juan135 employs a multi-layered security framework to protect player personal data against unauthorised access, disclosure, alteration, or destruction. Key security measures include:

• 256-Bit SSL/TLS Encryption: All data in transit between your device and juan135 servers is encrypted using industry-standard TLS protocols.
• Data Encryption at Rest: Sensitive personal data — including KYC documents and financial records — is encrypted at rest using AES-256 encryption on juan135's storage infrastructure.
• Access Controls: Access to personal data is strictly limited to authorised personnel who require it to perform their specific job functions. Role-based access controls and audit logging are enforced throughout our internal systems.
• Two-Factor Authentication (2FA): Internal system access by juan135 staff requires multi-factor authentication. Players are strongly encouraged to enable 2FA on their player accounts through the security settings page.
• Penetration Testing: juan135 commissions regular independent security assessments and penetration tests of its platform infrastructure.
• Incident Response Plan: juan135 maintains a documented data breach response plan aligned with the notification requirements of RA 10173 and NPC regulations.

11. Children & Minors — Strict 21+ Policy

juan135 is strictly a platform for adults. The minimum legal age for casino-style gambling in the Philippines under PAGCOR regulations is 21 years of age. juan135 does not knowingly collect personal data from individuals under 21, and registration by anyone under 21 is expressly prohibited.

All registration attempts are subject to mandatory age verification as part of the KYC process. If juan135 discovers that personal data has been collected from an individual under 21, the following steps will be taken immediately:

• The account will be permanently suspended and all access revoked.
• Any real-money balance will be frozen pending investigation.
• All personal data associated with the underage account will be securely deleted, except where retention is required for regulatory reporting purposes.
• The incident will be reported to PAGCOR and, where appropriate, referred to Philippine law enforcement.

12. Updates to This Privacy Policy

juan135 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, PAGCOR regulatory requirements, or operational changes to the platform.

When material changes are made to this Privacy Policy, juan135 will:

• Update the "Last Updated" date at the top of this page.
• Notify registered players via the email address on file or through a prominent in-platform notification upon their next login.
• Where required by RA 10173, obtain fresh consent for any new processing activities that were not covered by a player's original consent.

Continued use of the juan135 platform following notification of material changes constitutes acceptance of the revised Privacy Policy. If you do not accept the revised terms, you must discontinue use of the platform and may request account closure through the support channel.

13. Contact Us & Data Protection Officer

For all privacy-related enquiries, data subject rights requests, or concerns about how juan135 processes your personal data, please contact us through the following channels:

• Data Protection Officer (DPO): Address correspondence to the DPO via email at [email protected], clearly marking your message as a "Data Privacy Matter" in the subject line.
• 24/7 Live Chat: Available from your account dashboard — suitable for urgent account-related privacy matters.
• Written Correspondence: For formal legal notices, written requests should be addressed to the Compliance and Data Privacy Team via email with full details of the request and supporting identification.

If you are not satisfied with juan135's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the competent supervisory authority under RA 10173.