juan3 Privacy Policy

1. Introduction

1.1 juan3 is committed to protecting the privacy and security of your personal information. We recognise that trust is the foundation of our relationship with every player, and we take our data protection obligations seriously.

1.2 This Policy applies to all personal data collected through the juan3 Platform, including data collected during account registration, identity verification, deposits and withdrawals, gameplay, customer support interactions, and marketing communications.

1.3 This Policy should be read together with our Terms & Conditions and our Responsible Gaming Policy.

2. Data Controller

2.1 For the purposes of the Data Privacy Act of 2012, juan3 is the personal information controller in respect of the personal data collected through the Platform.

2.2 Our designated Data Protection Officer (DPO) is responsible for overseeing compliance with this Policy and applicable data protection laws. You may contact the DPO at: support@juan3.app — please include "Data Privacy" in the subject line of your message.

3. Personal Data We Collect

juan3 collects the following categories of personal data:

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued identification number (e.g., Philippine passport, SSS, UMID, driver's licence, or PhilSys national ID number).
• Contact Data: Email address, mobile phone number, and residential address.
• Financial Data: GCash account number, PayMaya/Maya account number, bank account details (BPI, BDO, Metrobank, UnionBank, and other Philippine banks), and debit card information used for deposits and withdrawals.
• Transaction Data: Records of all deposits, withdrawals, bets placed, games played, bonuses claimed, and account balance history.
• Technical Data: IP address, device type, operating system, browser type, session duration, and login timestamps.
• Usage Data: Information about how you use the Platform, including pages visited, games accessed, features used, and click-stream data.
• Communications Data: Records of your interactions with our customer support team, including live chat transcripts and email correspondence.
• Marketing Preferences: Your preferences regarding receiving marketing communications from juan3.

4. How We Collect Your Data

juan3 collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third parties: Identity verification data from KYC service providers; fraud prevention data from anti-fraud partners; payment data from payment processors (GCash, PayMaya, banks).

5. How We Use Your Personal Data

juan3 uses your personal data for the following purposes:

• To create and manage your juan3 account;
• To verify your identity and age (21+) in compliance with PAGCOR regulations and Philippine law;
• To process deposits and withdrawals via your chosen payment method;
• To provide and improve the Platform's gaming services, including live casino, sports betting, slots, and bingo;
• To detect, investigate, and prevent fraud, money laundering, and other illegal activities;
• To comply with our legal and regulatory obligations, including reporting to PAGCOR and the Anti-Money Laundering Council (AMLC);
• To provide customer support and respond to your enquiries;
• To send you transactional communications (account confirmations, withdrawal notifications, security alerts);
• To send you marketing communications about promotions and new features, where you have consented to receive them;
• To enforce our Terms & Conditions and protect the rights of juan3 and other players;
• To support responsible gaming measures, including monitoring for problem gambling indicators and administering self-exclusion requests.

6. Legal Basis for Processing

6.1 juan3 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you (i.e., to operate your account and provide gaming services).
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements and AMLC reporting obligations.
• Legitimate interests: Processing for fraud prevention, platform security, and improving our services, where these interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications, where you have given your explicit consent. You may withdraw consent at any time.

7. Data Sharing and Disclosure

7.1 juan3 does not sell, rent, or trade your personal data to third-party marketers under any circumstances.

7.2 We may share your personal data with the following categories of recipients:

• Service providers: KYC and identity verification providers, payment processors (GCash, PayMaya, Philippine banks), IT infrastructure providers, customer support platforms, and fraud prevention services — all bound by data processing agreements.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, as required by law.
• Law enforcement: Philippine law enforcement agencies, where required by a valid legal order or where disclosure is necessary to prevent or investigate a crime.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of juan3's business, your data may be transferred to the acquiring entity, subject to equivalent privacy protections.

7.3 All third-party service providers who process personal data on behalf of juan3 are required to implement appropriate technical and organisational security measures and to process data only in accordance with our instructions.

8. Cookies and Tracking Technologies

8.1 juan3 uses cookies and similar tracking technologies (web beacons, pixel tags, local storage) to operate and improve the Platform. Cookies are small text files stored on your device that help us recognise you, maintain your session, and remember your preferences.

8.2 We use the following types of cookies:

• Strictly necessary cookies: Required for the Platform to function (e.g., session management, login authentication). These cannot be disabled.
• Performance cookies: Collect anonymised data about how players use the Platform to help us improve performance and user experience.
• Functional cookies: Remember your preferences (e.g., language, game settings) to personalise your experience.
• Marketing cookies: Used to deliver relevant promotional content. These are only set with your consent.

8.3 You can manage or disable cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. For more information on managing cookies, refer to your browser's help documentation.

9. Data Retention

9.1 juan3 retains your personal data for as long as your account is active and for a period thereafter as required by applicable Philippine law and regulation. Specifically:

• Account and identity data: Retained for a minimum of five (5) years following account closure, in accordance with PAGCOR licensing requirements and AMLC record-keeping obligations.
• Transaction data: Retained for a minimum of five (5) years from the date of each transaction.
• Customer support records: Retained for three (3) years from the date of the interaction.
• Marketing data: Retained until you withdraw your consent or opt out of marketing communications.

9.2 When personal data is no longer required for the purposes for which it was collected and no legal retention obligation applies, juan3 will securely delete or anonymise it.

10. Data Security

10.1 juan3 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers;
• Encryption of sensitive data at rest, including financial information and government ID details;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security audits and penetration testing of the Platform;
• Two-factor authentication (2FA) available for all player accounts;
• Continuous monitoring for suspicious activity and potential data breaches.

10.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, juan3 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, in accordance with the Data Privacy Act of 2012.

11. Your Rights Under the Data Privacy Act

11.1 As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by juan3:

• Right to be informed: The right to know what personal data juan3 collects about you and how it is used — which is the purpose of this Policy.
• Right of access: The right to request a copy of the personal data juan3 holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to our legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

11.2 To exercise any of these rights, please contact our Data Protection Officer at support@juan3.app with the subject line "Data Privacy Request." We will respond to your request within thirty (30) days.

12. Children's Privacy

12.1 The juan3 Platform is strictly intended for persons aged twenty-one (21) years and above. juan3 does not knowingly collect personal data from individuals under the age of 21.

12.2 If juan3 becomes aware that personal data has been collected from a person under 21 years of age, we will immediately close the relevant account, delete the personal data, and return any deposited funds to the originating payment method.

12.3 If you believe that a minor has registered an account on the juan3 Platform, please contact us immediately at support@juan3.app.

13. International Data Transfers

13.1 juan3 primarily stores and processes personal data within the Philippines. Where it is necessary to transfer personal data to service providers located outside the Philippines (for example, cloud infrastructure providers), juan3 ensures that such transfers are made only to countries or organisations that provide an adequate level of data protection, or that appropriate safeguards are in place (such as data processing agreements incorporating standard contractual clauses).

13.2 Any international transfer of personal data by juan3 is conducted in compliance with the Data Privacy Act of 2012 and the applicable NPC guidelines on cross-border data transfers.

14. Changes to This Privacy Policy

14.1 juan3 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. Material changes will be communicated to registered players via email or an in-platform notification at least seven (7) days before the changes take effect.

14.2 The date of the most recent revision is displayed at the top of this page. We encourage you to review this Policy periodically. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way juan3 handles your personal data, please contact our Data Protection Officer:

Email: support@juan3.app
Please include "Data Privacy" in the subject line. We aim to respond to all data privacy enquiries within 30 days.

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines (NPC) if you are not satisfied with our response.