Privacy Policy — juan136

1 Introduction

juan136 ("juan136," "we," "us," or "our") operates the online casino and sports betting platform accessible at juan136.org (the "Platform"). As a platform serving players across the Philippines — from Manila and Makati to Cebu, Davao, and Quezon City — we understand that the privacy and security of your personal information is of the utmost importance.

This Privacy Policy describes how juan136 collects, uses, stores, shares, and protects personal data in connection with your use of the Platform. It applies to all registered players, visitors to the Platform, and any individual whose personal data is processed by juan136 in connection with the provision of our services.

This Policy should be read alongside our Terms and Conditions, which govern your use of the Platform. Capitalised terms not defined in this Policy have the meanings given to them in the Terms and Conditions.

2 Data We Collect

juan136 collects personal data that is necessary to provide the Platform's services, comply with legal and regulatory obligations, and maintain the security and integrity of the Platform. The categories of personal data we collect include:

2.1 Registration & Identity Data

• Full legal name
• Date of birth (for age verification — players must be 21 or older)
• Nationality and country of residence
• Email address and mobile number
• Username and encrypted password

2.2 Identity Verification (KYC) Data

• Government-issued photo ID (Philippine passport, SSS ID, UMID, driver's license, or equivalent)
• Proof of address (utility bill, bank statement, or equivalent)
• Proof of payment method ownership (screenshot or statement from GCash, PayMaya, BPI, BDO, or Metrobank account)
• Selfie or live photo for identity confirmation where required

2.3 Financial & Transaction Data

• Deposit and withdrawal amounts and timestamps
• Payment method details (e-wallet account numbers, bank account details — stored in tokenised form)
• Transaction history and account balance records

2.4 Gaming & Betting Activity Data

• Game sessions, bet history, and wagering records
• Bonus and promotion usage
• Responsible gaming tool settings (deposit limits, loss limits, self-exclusion status)

2.5 Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session duration, pages visited, and features used
• Login timestamps and access logs

2.6 Communications Data

• Records of live chat conversations with our support team
• Email correspondence with juan136
• Feedback, complaints, and dispute records

3 How We Use Your Data

juan136 uses the personal data we collect for the following purposes:

juan136 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

4 Legal Basis for Processing

juan136 processes your personal data on the following legal bases under applicable Philippine data protection law (Republic Act No. 10173, the Data Privacy Act of 2012, and its Implementing Rules and Regulations):

• Contractual necessity — processing required to perform our contract with you, including account registration, payment processing, and the provision of gaming services;
• Legal obligation — processing required to comply with applicable laws and regulations, including KYC/AML obligations, age verification requirements, and reporting obligations to regulatory authorities such as PAGCOR and the Anti-Money Laundering Council (AMLC);
• Legitimate interests — processing necessary for juan136's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and improving our services, where such interests are not overridden by your rights and interests;
• Consent — where you have given us your explicit consent to process your data for a specific purpose, such as receiving marketing communications. You may withdraw your consent at any time by contacting our support team or updating your account preferences.

5 Data Sharing & Disclosure

juan136 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

5.1 Service Providers

We engage trusted third-party service providers to assist in operating the Platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), KYC and identity verification providers, fraud detection and security services, cloud hosting and infrastructure providers, and customer support platform providers. All service providers are contractually bound to process your data only on our instructions and in accordance with applicable data protection law.

5.2 Regulatory & Law Enforcement Authorities

juan136 may disclose personal data to PAGCOR, the AMLC, the National Privacy Commission (NPC), law enforcement agencies, or other competent authorities where required by law, court order, or regulatory directive. This includes mandatory reporting of suspicious transactions under the Anti-Money Laundering Act.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of juan136's business, your personal data may be transferred to the relevant successor entity. You will be notified of any such transfer and the privacy practices of the successor entity prior to the transfer taking effect.

6 Cookies & Tracking Technologies

juan136 uses cookies and similar tracking technologies on the Platform to ensure the Platform functions correctly, to remember your preferences, and to analyse how the Platform is used. The types of cookies we use include:

• Strictly necessary cookies — essential for the Platform to operate, including session management, login authentication, and security features. These cannot be disabled.
• Functional cookies — used to remember your preferences such as language settings, preferred payment method, and responsible gaming tool configurations.
• Analytics cookies — used to collect aggregated, anonymised data about how players use the Platform, helping us identify areas for improvement. No personally identifiable information is included in analytics reports.
• Security cookies — used to detect and prevent fraudulent activity, bot access, and unauthorised account access attempts.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. juan136 does not use third-party advertising or behavioural tracking cookies.

7 Data Retention

juan136 retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, to comply with legal and regulatory obligations, and to resolve disputes or enforce our agreements. Specific retention periods include:

• Account and identity data — retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with Philippine AML regulations;
• Financial and transaction records — retained for a minimum of five (5) years from the date of each transaction;
• KYC documentation — retained for a minimum of five (5) years following the completion of the verification process or account closure, whichever is later;
• Customer support communications — retained for two (2) years from the date of the last interaction;
• Technical and usage logs — retained for up to twelve (12) months for security and fraud prevention purposes.

When personal data is no longer required for any of the above purposes, juan136 will securely delete or anonymise it in accordance with our data disposal procedures.

8 Data Security

juan136 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption — all data transmitted between your device and the Platform is encrypted using TLS (Transport Layer Security). Sensitive data at rest, including payment details and identity documents, is encrypted using AES-256 encryption;
• Access controls — access to personal data is restricted to authorised juan136 personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations;
• Two-factor authentication (2FA) — available to all players and required for all internal administrative access to player data;
• Regular security audits — juan136 conducts periodic security assessments and penetration testing to identify and remediate vulnerabilities;
• Incident response — juan136 maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission (NPC) and affected players in accordance with applicable law.

9 Your Rights

Under the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by juan136:

• Right to be informed — you have the right to be informed about how your personal data is collected and processed, as set out in this Policy;
• Right of access — you have the right to request a copy of the personal data juan136 holds about you;
• Right to rectification — you have the right to request the correction of inaccurate or incomplete personal data;
• Right to erasure — you have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to juan136's legal retention obligations;
• Right to object — you have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to data portability — you have the right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to lodge a complaint — you have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of the above rights, please contact the juan136 Data Protection Officer via our 24/7 live chat support or by email at [email protected]. We will respond to all verified requests within thirty (30) days.

10 Children's Privacy

If you believe that a person under the age of 21 has registered an account on the Platform, please notify us immediately via our 24/7 live chat support so that we can take appropriate action.

11 International Data Transfers

juan136 primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data to service providers or infrastructure located outside the Philippines — for example, cloud hosting or fraud detection services — juan136 ensures that such transfers are subject to appropriate safeguards, including:

• Contractual data processing agreements that impose data protection obligations equivalent to those under Philippine law;
• Transfers only to jurisdictions that provide an adequate level of data protection as recognised by the National Privacy Commission;
• Implementation of additional technical safeguards such as encryption where required.

By using the Platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines in accordance with the safeguards described above.

12 Changes to This Privacy Policy

juan136 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered players via the email address associated with their account and by displaying a prominent notice on the Platform.

The "Last Updated" date at the top of this Policy indicates when the most recent changes were made. Your continued use of the Platform following the publication of any amendments constitutes your acknowledgment of the revised Policy. We encourage you to review this Policy periodically.

13 Contact & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or juan136's data processing practices, please contact our Data Protection Officer through the following channels:

• Live Chat: Available 24/7 via the Platform (Philippine Standard Time)
• Email: [email protected]

juan136 will acknowledge all privacy-related enquiries within two (2) business days and will endeavour to resolve complaints within thirty (30) days. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph.