1Introduction
This Privacy Policy ("Policy") describes how juan35 ("juan35," "we," "us," "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "Player," "User") who access or use the juan35 online gaming platform at juan35.net, including all associated products and services such as live casino, slots, online bingo, sports betting, esports wagering, arcade games, and any promotional programmes operated by juan35.
juan35 is committed to protecting the privacy and personal data of all Filipino players who trust us with their information. We recognise that when you share your personal details with us — whether to register an account, process a transaction, or contact our support team — you are placing real trust in juan35. We do not take that trust lightly.
This Policy is designed to be consistent with the requirements of Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations. By using the juan35 platform, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy.
2Data We Collect
juan35 collects personal data that is necessary to provide a safe, compliant, and fully functional online gaming experience. The categories of personal data we collect include the following:
| Category | Examples |
|---|---|
| Identity Data | Full legal name, date of birth, government-issued ID number (e.g., passport, LTO driver's licence, UMID), nationality, photograph where provided for KYC purposes |
| Contact Data | Email address, mobile number, home or billing address (city, province, postal code), region (e.g., Metro Manila, Cebu, Davao) |
| Account Data | Username, encrypted password, account registration date, account status, preferences and settings |
| Financial Data | Deposit and withdrawal history, transaction amounts in Philippine Peso (₱), payment method type (GCash, PayMaya, BPI, BDO, Metrobank), partial payment identifiers as required for KYC |
| Gaming Activity Data | Game history, bet amounts, wagering patterns, session durations, responsible gaming tool usage (deposit limits, self-exclusion elections) |
| Technical Data | IP address, device type, operating system, browser type and version, screen resolution, time zone, session identifiers, cookies |
| Communications Data | Records of live chat conversations, email correspondence, support ticket content, and promotional communication responses |
juan35 does not collect sensitive personal information beyond what is strictly necessary for identity verification, regulatory compliance, fraud prevention, and responsible gaming obligations. We do not collect racial or ethnic origin, political opinions, religious beliefs, health records, or biometric data unless expressly required by law or regulatory authority.
3How We Collect Data
juan35 collects personal data through the following means:
- Direct Submission: Information you provide when registering a player account, completing KYC verification, making a deposit or withdrawal, contacting our support team, or participating in a promotion.
- Automated Collection: Technical data such as your IP address, device identifiers, browser type, and session information collected automatically when you access the juan35 platform, primarily through cookies and server logs.
- Payment Providers: Transaction confirmation data received from payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank when you initiate a deposit or withdrawal. juan35 does not receive or store your full payment credentials from these providers.
- Identity Verification Services: Where required for KYC compliance, juan35 may engage third-party identity verification providers who process your submitted documents and return a verification result to juan35.
- Fraud Prevention Partners: Technical and behavioural signals shared with anti-fraud service providers to detect and prevent unauthorised account access, payment fraud, and bonus abuse.
- Game Providers: Aggregated gameplay and session data from our third-party game content providers to support dispute resolution, bonus validation, and platform analytics.
4How We Use Your Data
juan35 uses the personal data we collect for the following specific purposes:
- Account Management: To create, maintain, and administer your juan35 player account, including verifying your identity and age (21+), authenticating your login sessions, and managing account preferences.
- Transaction Processing: To process deposits and withdrawals in Philippine Peso (₱) via your chosen payment method, reconcile transaction records, and issue receipts or confirmations.
- Regulatory Compliance: To fulfil our obligations under applicable Philippine laws and regulations, including KYC verification, anti-money laundering (AML) checks, and reporting requirements to relevant regulatory authorities.
- Responsible Gaming: To monitor player gaming activity for signs of problem gambling, enforce self-imposed limits and self-exclusion elections, and administer responsible gaming tools in accordance with our Responsible Gaming Policy.
- Fraud and Security: To detect, investigate, and prevent fraudulent activity, unauthorised account access, bonus abuse, collusion, and other conduct that violates our Terms & Conditions.
- Customer Support: To respond to your enquiries, resolve disputes, process complaints, and maintain records of support interactions for quality assurance purposes.
- Platform Improvement: To analyse aggregated usage patterns and technical data to improve the juan35 platform's performance, stability, and user experience.
- Promotional Communications: To send you information about juan35 bonuses, promotions, and new game releases where you have consented to receive such communications. You may withdraw this consent at any time by contacting support.
- Legal Proceedings: To establish, exercise, or defend legal claims in the event of a dispute between you and juan35.
juan35 does not use your personal data for automated decision-making that produces legal or similarly significant effects on you without providing a means for human review of such decisions upon request.
5Legal Basis for Processing
juan35 processes your personal data on the following legal grounds under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:
- Contractual Necessity: Processing your identity, contact, account, and financial data is necessary to perform our contractual obligations to you under the juan35 Terms & Conditions — including creating your account, processing transactions, and providing gaming services.
- Legal Obligation: Processing your data for KYC, AML, age verification, and regulatory reporting is required to comply with applicable Philippine laws and any conditions imposed by relevant regulatory authorities.
- Legitimate Interests: Processing technical and gaming activity data for fraud prevention, platform security, responsible gaming monitoring, and platform improvement is carried out on the basis of juan35's legitimate interests, provided those interests are not overridden by your rights and freedoms.
- Consent: Where juan35 relies on your consent to process your data — for example, for sending promotional communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal.
6Sharing Your Data
juan35 does not sell, rent, or otherwise disclose your personal data to unaffiliated third parties for their own commercial 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:
- Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other licensed payment service providers, strictly for the purpose of processing your deposits and withdrawals.
- Identity Verification Providers: Third-party KYC service providers engaged to verify the authenticity of identity documents submitted during account registration or ongoing compliance reviews.
- Game Content Providers: Licensed third-party game studios and platform providers that supply slot games, live casino tables, bingo engines, and other gaming content available on juan35. These providers may receive session and gameplay data necessary to operate the games.
- Fraud Prevention Services: Specialist anti-fraud technology providers that analyse technical and behavioural data to identify and prevent fraudulent activity on the platform.
- Regulatory and Law Enforcement Authorities: Where required by law, court order, or regulatory directive, juan35 may disclose personal data to the appropriate Philippine government authority, including PAGCOR or law enforcement agencies.
- Professional Advisers: Lawyers, auditors, accountants, and other professional advisers engaged by juan35 on a confidential basis where access to your data is necessary for the provision of professional services.
7Cookies & Tracking
juan35 uses cookies and similar tracking technologies to operate the platform effectively, maintain your login session, and understand how players interact with the site. Below is a summary of the cookie types used on juan35:
| Cookie Type | Purpose | Duration |
|---|---|---|
| Essential | Maintain your login session, remember language preferences, enable platform security features | Session / up to 30 days |
| Functional | Remember your game preferences, responsible gaming settings, and display choices | Up to 12 months |
| Analytics | Collect aggregated, anonymised data about how players navigate and use the juan35 platform to guide platform improvements | Up to 24 months |
| Security | Detect and prevent fraudulent logins, bot activity, and suspicious session behaviour | Session / up to 90 days |
You can manage or disable cookies through your browser settings at any time. Please note that disabling essential cookies may prevent certain core features of the juan35 platform from functioning correctly, including the ability to log in and maintain an active session.
juan35 does not use third-party advertising cookies or tracking pixels that share your browsing behaviour with external advertising networks.
8Data Retention
juan35 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 and regulatory obligations. The following general retention principles apply:
- Active Accounts: Personal data associated with an active juan35 account is retained for the duration of the account relationship plus any additional period required by law.
- Closed Accounts: Following the closure of a juan35 account — whether voluntary or otherwise — we retain identity, transaction, and gaming activity records for a minimum of five (5) years in accordance with AML and regulatory record-keeping requirements applicable in the Philippines.
- KYC Documents: Copies of identity documents submitted for KYC verification are retained for the period required by applicable Philippine regulations, typically five (5) years from the date of submission or the date of account closure, whichever is later.
- Support Records: Records of customer support interactions are retained for up to three (3) years from the date of the last interaction, to support dispute resolution and quality assurance.
- Marketing Consent: Records of your marketing consent or opt-out status are retained for as long as necessary to honour your preference and for a reasonable period thereafter to demonstrate compliance.
Once the applicable retention period has expired and there is no longer a legitimate legal or business basis for retaining your data, juan35 will securely delete or anonymise the relevant records in accordance with our internal data lifecycle procedures.
9Security Measures
juan35 implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include, but are not limited to:
- Encryption of all data transmitted between your device and the juan35 platform using Transport Layer Security (TLS).
- Encryption of sensitive data stored at rest, including account credentials and financial records.
- Strict access controls ensuring that juan35 personnel can only access player data where there is a documented operational need to do so.
- Regular security assessments and vulnerability reviews of the juan35 platform and its supporting infrastructure.
- Incident response procedures to detect, contain, and respond to data security incidents in a timely manner.
- Staff training on data protection obligations and information security best practices.
10Your Rights
Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, Filipino players have the following rights with respect to their personal data held by juan35:
- Right to Be Informed: You have the right to be informed about how your personal data is being collected and processed by juan35. This Privacy Policy fulfils that obligation.
- Right of Access: You have the right to request a copy of the personal data juan35 holds about you and to receive information about how it is being used.
- Right to Rectification: You have the right to request the correction of inaccurate or incomplete personal data held by juan35 about you.
- Right to Erasure: In certain circumstances, you have the right to request the deletion of your personal data. This right is subject to overriding legal obligations, such as regulatory record-keeping requirements, that may require juan35 to retain certain data notwithstanding your erasure request.
- Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes. You may also object to other processing carried out on the basis of legitimate interests, subject to juan35's ability to demonstrate compelling legitimate grounds that override your interests.
- Right to Data Portability: Where technically feasible, you may request that juan35 provide you with a copy of your personal data in a structured, commonly used, and machine-readable format.
- Right to Lodge a Complaint: If you believe that juan35 has processed your personal data in a manner that is inconsistent with the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.
To exercise any of the rights listed above, please contact the juan35 support team via live chat or at [email protected]. We will respond to all valid requests within a reasonable timeframe and in accordance with applicable law. We may need to verify your identity before processing certain requests.
11Minors
juan35 is strictly intended for use by adults aged 21 years and above, in accordance with PAGCOR regulations governing online gaming participation in the Philippines. juan35 does not knowingly collect, use, or retain the personal data of individuals under the age of 21.
If juan35 discovers or has reasonable grounds to believe that personal data has been collected from a person under the age of 21, we will immediately suspend the associated account, investigate the matter, and take appropriate steps to delete the data concerned in accordance with applicable law.
Parents and guardians who believe their child may have registered an account on juan35 are encouraged to contact our support team immediately so that the matter can be investigated and resolved without delay.
12Policy Changes
juan35 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, we will update the "Last Updated" date at the top of this page and, where practicable, provide notice to registered players via a platform notification or communication to your registered contact details.
We encourage you to review this Privacy Policy periodically to stay informed about how juan35 is protecting your personal data. Your continued use of the juan35 platform following the publication of any updated Policy constitutes your acknowledgment of the changes.
If you disagree with any changes made to this Policy, you should discontinue use of the juan35 platform and, if you wish to close your account, contact the support team to request account closure and discuss the handling of any remaining account balance.
13Contact Us
If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by juan35, please reach out to us through any of the following channels:
- Live Chat: Available 24 hours a day, 7 days a week, directly through the juan35 platform. This is the fastest way to reach our support team.
- Email: [email protected] — please include "Privacy Request" in the subject line of your message so it can be directed to the appropriate team promptly.
We are committed to resolving all privacy-related enquiries in a fair, transparent, and timely manner. Where your request involves the exercise of a data subject right under the Data Privacy Act of 2012, we will endeavour to respond within thirty (30) calendar days of receiving your request. In cases of particular complexity, this period may be extended and we will notify you accordingly.