juan36 Privacy Policy

juan36 ("juan36," "we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses the juan36 online gaming platform at juan36.net ("the Platform"). This Privacy Policy ("Policy") describes how we collect, use, store, share, and protect your personal information in connection with your use of the Platform and any related services.

This Policy is written in compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission ("NPC"). As a platform serving Filipino players, juan36 takes its obligations under Philippine data privacy law seriously.

This Policy should be read alongside our Terms & Conditions, which govern your use of the juan36 Platform. Capitalised terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

For the purposes of the Data Privacy Act of 2012 and this Policy, juan36 acts as the Personal Information Controller in respect of the personal data you provide when registering and using the Platform. This means juan36 determines the purposes and means of processing your personal information.

If you have any questions, concerns, or requests relating to your personal data or this Policy, you may contact our Data Protection Officer (DPO) using the contact details provided in Section 13 of this Policy. juan36 is committed to responding to all data privacy inquiries promptly and in accordance with applicable Philippine law.

juan36 collects personal data from you in several ways: directly when you register an account or interact with the Platform, automatically through your use of the Platform, and from third parties where permitted by law. The categories of personal data we collect include:

We do not collect sensitive personal information beyond what is strictly necessary for identity verification, age verification, and compliance with applicable anti-money laundering (AML) and Know Your Customer (KYC) obligations. We do not collect biometric data unless required by a specific regulatory directive.

juan36 uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and administer your juan36 account, including processing your registration, verifying your identity and age, and managing your account settings.
• Service Delivery: To provide you with access to the juan36 Platform, including all games, promotions, and features available to registered players.
• Transaction Processing: To process deposits and withdrawals via your chosen payment method (GCash, Maya, bank transfer, or debit card) and to maintain accurate records of all financial transactions on your account.
• KYC and AML Compliance: To verify your identity, conduct due diligence checks, and comply with our obligations under applicable Philippine anti-money laundering laws and PAGCOR regulatory requirements.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through our 24/7 support channels.
• Promotions and Marketing: To send you information about juan36 promotions, bonuses, and offers that may be of interest to you, where you have consented to receive such communications. You may opt out at any time.
• Responsible Gaming: To monitor gameplay patterns and identify potential signs of problem gambling, and to administer responsible gaming tools such as deposit limits and self-exclusion requests.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, cheating, multi-accounting, and other prohibited conduct on the Platform.
• Legal Compliance: To comply with applicable laws, regulations, court orders, and requests from regulatory authorities including PAGCOR and the NPC.
• Platform Improvement: To analyse usage patterns and technical data to improve the performance, features, and user experience of the juan36 Platform.

juan36 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.

Under the Data Privacy Act of 2012, juan36 processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you — specifically, to provide you with access to the juan36 Platform and its services as described in our Terms & Conditions.
• Legal Obligation: Processing is necessary to comply with our legal obligations under Philippine law, including KYC/AML requirements, age verification obligations, and PAGCOR regulatory directives.
• Legitimate Interests: Processing is necessary for our legitimate interests in operating a secure, fair, and commercially viable gaming platform, including fraud prevention, security monitoring, and Platform improvement — provided these interests are not overridden by your rights and interests.
• Consent: For certain processing activities, such as sending you marketing communications, we rely on your freely given, specific, and informed consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

juan36 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, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: We share financial data with payment service providers (such as GCash and Maya) and Philippine banks to process your deposits and withdrawals. These providers are bound by their own privacy policies and applicable Philippine financial regulations.
• Identity Verification Providers: We may share identity data with third-party KYC and AML service providers to fulfil our regulatory verification obligations.
• Game Software Providers: Game providers whose titles are available on the juan36 Platform may receive limited technical and gameplay data necessary to deliver their services.
• Regulatory Authorities: We may disclose personal data to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), or other competent Philippine authorities where required by law or regulatory directive.
• Law Enforcement: We may disclose personal data to law enforcement agencies where required by a valid legal process, court order, or where we believe disclosure is necessary to prevent fraud, protect the safety of any person, or protect the rights and property of juan36.
• Professional Advisers: We may share personal data with our legal, financial, and compliance advisers on a confidential basis where necessary for the conduct of our business.

juan36 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our general data retention principles are as follows:

• Active Account Data: Personal data associated with your active juan36 account is retained for the duration of your account's existence and for a period thereafter as required by law.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years following the date of the transaction, in compliance with Philippine AML regulations.
• KYC Documents: Identity verification documents are retained for a minimum of five (5) years following account closure or the end of the business relationship, as required by applicable law.
• Support Communications: Customer support records are retained for a period of three (3) years following the resolution of the relevant inquiry or dispute.
• Marketing Data: Where you have consented to receive marketing communications, we retain your contact details for this purpose until you withdraw your consent or request deletion.

When personal data is no longer required for any lawful purpose, juan36 will securely delete or anonymise it in accordance with our internal data retention and disposal procedures. Anonymised data that can no longer identify you may be retained indefinitely for statistical and analytical purposes.

juan36 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Encryption: All data transmitted between your device and the juan36 Platform is encrypted using industry-standard Transport Layer Security (TLS) protocols. Sensitive data stored on our systems is encrypted at rest.
• Access Controls: Access to personal data is restricted to authorised juan36 personnel and service providers who require it to perform their duties. All staff with access to personal data are subject to confidentiality obligations.
• Secure Infrastructure: The juan36 Platform is hosted on secure servers with firewall protection, intrusion detection systems, and regular security audits.
• Password Security: Account passwords are stored using one-way cryptographic hashing. juan36 staff cannot view your password in plain text.
• Fraud Monitoring: We employ automated fraud detection and monitoring systems to identify and respond to suspicious activity on the Platform in real time.

While juan36 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security, and you use the Platform at your own risk in this regard. You are responsible for maintaining the confidentiality of your own account credentials.

juan36 uses cookies and similar tracking technologies on the Platform to enhance your user experience, maintain your session, and collect analytical data about how the Platform is used. A cookie is a small text file placed on your device by a website you visit.

The types of cookies we use include:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function correctly. They enable core features such as account login, session management, and security. These cookies cannot be disabled.
• Functional Cookies: These cookies remember your preferences and settings — such as your preferred language and display options — to provide a more personalised experience on the Platform.
• Analytical Cookies: These cookies collect anonymised information about how visitors use the Platform, including which pages are visited most frequently and how users navigate between sections. This data helps us improve the Platform's performance and content.
• Marketing Cookies: Where you have consented, these cookies track your activity on the Platform to help us deliver relevant promotional content and measure the effectiveness of our marketing campaigns.

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the juan36 Platform. By continuing to use the Platform after being informed of our cookie use, you consent to our use of cookies as described in this Policy.

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by juan36:

• Right to Be Informed: You have the right to be informed about how your personal data is collected and processed. This Privacy Policy fulfils that obligation.
• Right of Access: You have the right to request a copy of the personal data juan36 holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You may update certain account details directly through your juan36 account settings.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests where you have grounds relating to your particular situation.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated. The NPC can be reached through its official channels.

The juan36 Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. juan36 does not knowingly collect personal data from individuals under the age of 21.

If we become aware that we have inadvertently collected personal data from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the juan36 Platform, please contact us immediately at the details provided in Section 13.

Parents and guardians are encouraged to monitor the online activities of minors in their care and to make use of available parental control tools to prevent access to online gaming platforms.

juan36 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes to this Policy, we will update the "Last Updated" date at the top of this page and, where appropriate, notify registered players via the contact information associated with their account.

We encourage you to review this Privacy Policy periodically to stay informed about how juan36 is protecting your personal data. Your continued use of the Platform following the posting of any changes constitutes your acknowledgment of the updated Policy.

If you have any questions, concerns, or requests regarding this Privacy Policy or the way juan36 handles your personal data, please contact our Data Protection Officer:

Data Protection Officer — juan36

Email: [email protected]

General Support: [email protected]

juan36 is committed to resolving all data privacy concerns in a fair, transparent, and timely manner. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.