Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how juan35.cam ("juan35", "we", "us", "our") collects, uses, stores, shares, and protects your personal information when you access our website, create an account, or use our gaming services. This Policy applies to all users of juan35 services, including visitors to our website, registered players, and individuals who communicate with our customer support team.

juan35 is committed to protecting your privacy and complying with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines, as well as applicable PAGCOR regulations governing online gaming operators. We process your personal data lawfully, fairly, and transparently, and we implement appropriate technical and organizational measures to ensure data security.

By using juan35 services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein. If you do not agree with this Policy, please do not use our services or provide us with your personal information.

2. Information We Collect

2.1 Personal Information You Provide

When you register for a juan35 account, we collect the following personal information directly from you:

• Identity Information: Full legal name (as it appears on government-issued ID), date of birth, gender, nationality, and government-issued identification number (for verification purposes only).
• Contact Information: Email address, mobile phone number, residential address (street, barangay, city/municipality, province, postal code).
• Account Credentials: Username, password (stored in encrypted format), and security questions and answers for account recovery.
• Financial Information: Payment method details including GCash mobile number, Maya account information, bank account numbers (BPI, BDO, Metrobank, or other Philippine banks), and transaction history for deposits and withdrawals.
• Verification Documents: Copies of government-issued photo identification (passport, driver's license, UMID card, SSS ID, PhilHealth card), proof of address documents (utility bills, bank statements), and proof of payment method ownership for KYC compliance.
• Communication Records: Content of your communications with our customer support team via live chat, email, or other communication channels, including complaint details and inquiry history.

2.2 Information We Collect Automatically

When you access juan35 services, we automatically collect certain technical and behavioral information:

• Device Information: Device type (mobile, tablet, desktop), operating system and version, browser type and version, screen resolution, and device identifiers (including mobile advertising IDs).
• Usage Data: Pages visited, time spent on each page, click patterns, game play history (games played, bets placed, outcomes, session duration), deposit and withdrawal patterns, and feature usage statistics.
• Technical Data: IP address, geolocation data (country, region, city derived from IP address), internet service provider, referring/exit pages, date and time stamps of access, and cookies and similar tracking technologies.
• Gaming Activity: Detailed records of all gaming transactions including bet amounts, game outcomes, bonus usage, tournament participation, and real-time player balances.

2.3 Information from Third Parties

We may receive information about you from third-party sources for verification, fraud prevention, and regulatory compliance purposes:

• Payment Processors: Transaction confirmation, payment method verification, and fraud screening results from GCash, Maya, InstaPay, PesoNet, and banking partners.
• Identity Verification Services: Verification status and identity authentication results from third-party KYC service providers licensed to operate in the Philippines.
• Regulatory Bodies: Information shared by PAGCOR or other Philippine regulatory authorities for compliance monitoring, self-exclusion lists, and responsible gaming enforcement.
• Game Providers: Game play data, RNG outcomes, and technical performance metrics from third-party game software providers integrated into our platform.

3. How We Use Your Information

juan35 uses your personal information for the following lawful purposes:

3.1 Service Provision and Account Management

• Create, maintain, and manage your player account and authenticate your identity when you log in.
• Process deposits, withdrawals, and other financial transactions securely and efficiently.
• Provide access to gaming services including slots, bingo, live casino, and sports betting products.
• Calculate and credit bonuses, rewards, loyalty points, and promotional offers to your account.
• Maintain accurate records of your gaming activity, transaction history, and account balance.
• Provide customer support and respond to your inquiries, complaints, and technical issues.

3.2 Legal and Regulatory Compliance

• Verify your identity and age to ensure compliance with Philippine laws requiring players to be 21 years or older.
• Conduct Know Your Customer (KYC) and Anti-Money Laundering (AML) checks as required by PAGCOR regulations and Philippine financial laws.
• Monitor transactions for suspicious activity and report to relevant authorities when legally required.
• Comply with PAGCOR audit requirements, licensing conditions, and regulatory reporting obligations.
• Enforce our Terms & Conditions, prevent fraud, detect prohibited activities, and protect the integrity of our gaming platform.
• Respond to legal processes including court orders, subpoenas, and requests from law enforcement agencies.

3.3 Responsible Gaming and Player Protection

• Implement and enforce deposit limits, loss limits, and session time restrictions you have configured.
• Process self-exclusion requests and maintain self-exclusion lists to prevent problem gambling.
• Monitor gaming behavior patterns for signs of problematic gambling and provide intervention when appropriate.
• Provide access to responsible gaming tools and resources for players who may need support.

3.4 Marketing and Communications

• Send you promotional offers, bonus notifications, new game announcements, and tournament invitations via email, SMS, or in-platform notifications (only if you have opted in to receive marketing communications).
• Personalize your gaming experience by recommending games based on your preferences and playing history.
• Conduct surveys and request feedback to improve our services and customer experience.
• Send you important service updates, account notifications, security alerts, and policy changes (these transactional communications are sent regardless of marketing preferences).

3.5 Platform Improvement and Analytics

• Analyze user behavior and gaming patterns to improve platform performance, game selection, and user interface design.
• Conduct statistical analysis and generate reports on platform usage, game popularity, and player retention.
• Test new features, games, and services before full release to ensure quality and reliability.
• Optimize payment processing, reduce transaction failures, and improve deposit and withdrawal speeds.

4. Legal Basis for Processing

Under Philippine data protection law, we process your personal information based on the following legal grounds:

• Consent: You have given explicit consent for us to process your personal data for specific purposes, such as marketing communications and personalized recommendations.
• Contract Performance: Processing is necessary to perform our contract with you (the Terms & Conditions you agreed to when creating your account) and to provide the gaming services you requested.
• Legal Obligation: Processing is necessary to comply with Philippine laws and regulations, including PAGCOR licensing requirements, AML regulations, tax laws, and data retention obligations.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security monitoring, platform improvement, and internal analytics, provided these interests do not override your fundamental rights and freedoms.

5. How We Share Your Information

juan35 does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information with the following categories of recipients for the purposes described in this Policy:

5.1 Service Providers and Business Partners

• Payment Processors: GCash, Maya, InstaPay, PesoNet, and banking partners who process your deposits and withdrawals securely.
• Game Providers: Third-party software developers who supply games available on our platform and require player data for game session management.
• Identity Verification Services: KYC and AML compliance service providers who verify your identity and screen for fraud risk.
• Customer Support Tools: Live chat software providers, ticketing systems, and email service providers used to deliver customer support.
• Cloud Hosting Providers: Secure data centers and cloud infrastructure providers who store our data and ensure platform availability.
• Analytics Providers: Web analytics and business intelligence tools that help us understand platform usage and improve services.

All service providers are bound by strict contractual obligations to keep your information confidential and use it only for the purposes we specify. We conduct due diligence on all service providers to ensure they implement appropriate security measures.

5.2 Regulatory and Legal Authorities

• PAGCOR: We share information with the Philippine Amusement and Gaming Corporation as required by our gaming license and regulatory reporting obligations.
• Law Enforcement: We may disclose information to Philippine National Police, National Bureau of Investigation, or other law enforcement agencies when required by law or in response to valid legal requests.
• Anti-Money Laundering Council (AMLC): We report suspicious transactions to AMLC as required by Philippine AML laws.
• Courts and Legal Proceedings: We may disclose information in response to court orders, subpoenas, or other legal processes.

5.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, sale of assets, or bankruptcy, your personal information may be transferred to the acquiring entity or successor company. We will notify you via email and prominent notice on our website before your information is transferred and becomes subject to a different privacy policy.

6. Data Security Measures

juan35 implements industry-standard technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction:

• Encryption: All data transmitted between your device and our servers is encrypted using SSL/TLS protocols. Sensitive data stored in our databases, including passwords and payment information, is encrypted at rest using AES-256 encryption.
• Access Controls: We implement role-based access controls and the principle of least privilege, ensuring that only authorized personnel with a legitimate business need can access personal data.
• Authentication: Player accounts are protected by strong password requirements, and we offer optional two-factor authentication (2FA) for enhanced security.
• Network Security: Our infrastructure is protected by firewalls, intrusion detection systems, DDoS protection, and regular vulnerability scanning.
• Security Monitoring: We maintain 24/7 security monitoring, logging of access to sensitive systems, and automated threat detection to identify and respond to security incidents promptly.
• Employee Training: All juan35 employees undergo mandatory data protection and security awareness training and are bound by confidentiality obligations.
• Third-Party Audits: We engage independent security firms to conduct regular penetration testing and security audits of our systems.

Despite our best efforts, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information using commercially reasonable means, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and should notify us immediately if you suspect unauthorized access to your account.

7. Data Retention

juan35 retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy and to comply with legal and regulatory obligations:

• Active Accounts: While your account is active, we retain all account information, transaction history, and gaming records to provide services and comply with regulatory requirements.
• Closed Accounts: After you close your account, we retain certain information for up to seven (7) years as required by PAGCOR regulations and Philippine tax laws. This includes transaction records, identification documents, and AML compliance documentation.
• Marketing Data: If you opt out of marketing communications, we retain a record of your opt-out preference indefinitely to ensure we do not contact you in the future.
• Legal Holds: We may retain data beyond standard retention periods when required by pending legal proceedings, regulatory investigations, or dispute resolution processes.

After the applicable retention period expires, we securely delete or anonymize your personal information in accordance with data protection best practices.

8. Your Pri vacy Rights

As a data subject under the Data Privacy Act of 2012, you have the following rights regarding your personal information:

8.1 Right to Access

You have the right to request access to the personal information we hold about you. We will provide you with a copy of your data in a commonly used electronic format upon request. You can access most of your account information directly through your player dashboard.

8.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. You can update your contact information, address, and communication preferences directly in your account settings. For changes to identity information (name, date of birth), please contact our customer support team with supporting documentation.

8.3 Right to Erasure

You have the right to request deletion of your personal information under certain circumstances. However, this right is subject to legal limitations, as we are required by PAGCOR regulations to retain certain records for seven years. We will delete or anonymize your data to the fullest extent permitted by law upon your request.

8.4 Right to Restrict Processing

You have the right to request that we restrict the processing of your personal information in certain circumstances, such as when you contest the accuracy of the data or object to processing based on legitimate interests.

8.5 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that data to another controller. We will provide your data export in CSV or JSON format upon request.

8.6 Right to Object

You have the right to object to processing of your personal information for direct marketing purposes at any time. You can opt out of marketing communications by clicking the unsubscribe link in our emails or adjusting your communication preferences in your account settings.

8.7 Right to Withdraw Consent

Where we process your personal information based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

8.8 How to Exercise Your Rights

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with your full name, account username, and a clear description of your request. We will respond to your request within fifteen (15) business days as required by Philippine law. In some cases, we may need to verify your identity before processing your request to protect your privacy and security.

9. Cookies and Tracking Technologies

juan35 uses cookies, web beacons, pixel tags, and similar tracking technologies to enhance your experience, analyze platform usage, and deliver personalized content and advertisements.

9.1 Types of Cookies We Use

Cookie Type	Purpose	Duration
Essential Cookies	Required for basic site functionality, login authentication, and security. Cannot be disabled.	Session / 1 year
Performance Cookies	Collect anonymous data on how visitors use our site to improve performance and user experience.	1-2 years
Functionality Cookies	Remember your preferences, language settings, and customization choices.	1 year
Marketing Cookies	Track your browsing activity to deliver relevant advertisements and measure campaign effectiveness.	1-2 years

9.2 Managing Cookies

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. Please note that disabling essential cookies may prevent you from accessing certain features of our platform. You can manage your cookie preferences through your browser settings or by using our cookie consent management tool available in your account settings.

10. International Data Transfers

Your personal information is primarily stored and processed within the Philippines. However, some of our service providers and technology partners may be located in other jurisdictions, including the United States, European Union, and Singapore. When we transfer personal data outside the Philippines, we ensure appropriate safeguards are in place:

• Standard contractual clauses approved by data protection authorities
• Data processing agreements with strict security and confidentiality obligations
• Regular audits of third-party data processors to ensure compliance
• Encryption of data in transit across international networks

We select service providers carefully and require them to maintain data protection standards equivalent to those required by Philippine law.

11. Children's Privacy

juan35 services are strictly intended for individuals aged 21 years or older, in compliance with Philippine gambling laws. We do not knowingly collect personal information from individuals under the age of 21. Our registration process includes age verification measures, and we require all users to confirm they meet the minimum age requirement.

If we become aware that we have inadvertently collected personal information from someone under 21 years of age, we will take immediate steps to delete that information and permanently close the account. Parents or guardians who believe their child has provided personal information to juan35 should contact us immediately at [email protected].

12. Changes to This Privacy Policy

juan35 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or business operations. When we make material changes to this Policy, we will:

• Update the "Last Updated" date at the top of this document
• Send you an email notification to the address associated with your account
• Display a prominent notice on our website homepage and player dashboard
• Require you to review and accept the updated Policy before continuing to use our services for material changes affecting your rights

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of juan35 services after changes to this Policy indicates your acceptance of the updated terms.

13. Contact Information

If you have questions, concerns, or complaints about this Privacy Policy or our data processing practices, please contact us:

For complaints regarding data protection practices, you may also contact the National Privacy Commission of the Philippines:

• Website: privacy.gov.ph
• Address: 5th Floor, Delegation Building, PICC Complex, Pasay City, Metro Manila, Philippines
• Email: [email protected]
• Hotline: (02) 8234-2228