Privacy Policy

1. Overview & Scope

This Privacy Policy ("Policy") is issued by 365juan ("365juan," "we," "us," or "our"), the operator of the online gaming platform accessible at https://365juan.com and through the 365juan mobile application. This Policy applies to all personal information collected from registered players, visitors, and any individual who interacts with any part of the 365juan platform, including our website, mobile app, customer support channels, and promotional communications.

This Policy should be read alongside our Terms & Conditions and our Responsible Gaming Policy. Together, these documents form the complete framework governing your relationship with 365juan. If you do not agree with the terms of this Privacy Policy, please discontinue your use of the 365juan platform immediately.

365juan acts as the personal information controller in respect of all personal data collected through the platform. We are responsible for ensuring that your data is processed lawfully, fairly, and transparently in accordance with the Data Privacy Act of 2012 and all applicable Philippine regulations.

2. Data We Collect

365juan collects personal information that is necessary to provide our gaming services, comply with regulatory obligations, and deliver a safe and personalised experience to every Filipino player on our platform. The categories of personal data we collect include:

Category	Examples
Identity Data	Full legal name, date of birth, government-issued ID number, nationality
Contact Data	Email address, Philippine mobile number, residential address (city, province)
Financial Data	GCash number, PayMaya account, BPI/BDO/Metrobank account details, transaction history
Gaming Data	Bet history, game activity, session duration, win/loss records, bonus usage
Technical Data	IP address, device type, browser type, operating system, login timestamps
Usage Data	Pages visited, features used, click patterns, referral source
Communications Data	Support chat logs, email correspondence, feedback submissions
KYC Documents	Scanned government ID, proof of address, selfie verification images

We do not intentionally collect sensitive personal information beyond what is strictly required for identity verification and regulatory compliance. Where sensitive data is collected — such as government ID numbers — it is handled with the highest level of security and access controls within the 365juan platform.

3. How We Collect Your Data

365juan collects personal data through the following means:

• Direct registration: Information you provide when creating your 365juan account, including your name, email, mobile number, and date of birth.
• KYC verification: Identity documents and selfie images submitted during the account verification process.
• Deposits and withdrawals: Payment details provided when funding your account or requesting a withdrawal via GCash, PayMaya, BPI, BDO, or Metrobank.
• Platform activity: Data generated automatically as you use the 365juan website or mobile app, including bets placed, games played, and session activity.
• Customer support: Information shared when you contact our support team via live chat, email, or other channels.
• Cookies and tracking technologies: Technical and usage data collected automatically through cookies, web beacons, and similar technologies when you visit the 365juan platform.
• Promotions and surveys: Information provided when you participate in 365juan promotions, competitions, or feedback surveys.

4. Purpose of Processing

365juan processes your personal data for the following specific, legitimate purposes:

• Account creation and management: To register your 365juan account, verify your identity, and manage your player profile.
• Service delivery: To provide access to all gaming products on the 365juan platform, including sports betting, esports, sabong, and casino-style games.
• Payment processing: To process deposits and withdrawals through your chosen Philippine payment method.
• Regulatory compliance: To fulfil our obligations under Philippine gaming regulations, anti-money laundering (AML) laws, and the Data Privacy Act of 2012.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, cheating, and unauthorised access to the platform.
• Responsible gaming: To monitor gaming behaviour and provide responsible gaming tools, including deposit limits and self-exclusion options, to protect vulnerable players.
• Customer support: To respond to your enquiries, resolve disputes, and improve our support services.
• Marketing and promotions: To send you relevant offers, bonuses, and promotional communications from 365juan, where you have provided consent to receive such communications.
• Platform improvement: To analyse usage patterns and improve the features, performance, and user experience of the 365juan platform.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012 (RA 10173), 365juan processes your personal data on the following legal bases:

• Consent: Where you have given explicit consent to the processing of your personal data, such as for marketing communications or optional features.
• Contractual necessity: Where processing is necessary to perform our contract with you — specifically, to provide the gaming services you have registered for on 365juan.
• Legal obligation: Where processing is required to comply with applicable Philippine laws and regulations, including AML obligations and gaming regulatory requirements.
• Legitimate interests: Where processing is necessary for the legitimate interests of 365juan, such as fraud prevention, platform security, and service improvement, provided those interests are not overridden by your rights and freedoms.

6. Data Sharing & Disclosure

365juan does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal information only in the following limited circumstances:

• Payment processors: We share necessary financial data with payment service providers (such as GCash, PayMaya, and partner banks) solely to process your transactions.
• Identity verification providers: We may share identity documents with accredited KYC verification partners to fulfil our regulatory obligations.
• Regulatory authorities: We may disclose personal data to Philippine regulatory bodies, law enforcement agencies, or courts where required by law or in response to a valid legal order.
• Technology service providers: We engage trusted third-party technology providers (such as cloud hosting and analytics services) who process data on our behalf under strict data processing agreements.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of 365juan's business, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

7. Data Retention

365juan 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 Philippine law. Our general retention periods are as follows:

• Active account data: Retained for the duration of your active account on 365juan, plus a minimum of five (5) years after account closure, in compliance with AML and gaming regulatory requirements.
• Transaction records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction.
• KYC documents: Identity verification documents are retained for a minimum of five (5) years after account closure.
• Support communications: Customer support records are retained for three (3) years from the date of the interaction.
• Marketing data: Retained until you withdraw your consent or request deletion, whichever is earlier.

Upon expiry of the applicable retention period, your personal data will be securely deleted or anonymised in accordance with our internal data disposal procedures.

8. Data Security

365juan implements robust technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Our security measures include:

• SSL/TLS encryption: All data transmitted between your device and the 365juan platform is encrypted using industry-standard SSL/TLS protocols.
• Data encryption at rest: Sensitive personal data stored on our servers is encrypted using AES-256 encryption.
• Access controls: Access to personal data is restricted to authorised 365juan personnel on a strict need-to-know basis.
• Two-factor authentication: Players are encouraged to enable two-factor authentication (2FA) on their 365juan accounts for additional security.
• Regular security audits: We conduct regular security assessments and penetration testing to identify and address potential vulnerabilities.
• Incident response: We maintain a data breach response plan and will notify affected players and the National Privacy Commission (NPC) in the event of a reportable data breach, in accordance with RA 10173.

While 365juan takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect any unauthorised access to your 365juan account.

9. Cookies & Tracking Technologies

365juan uses cookies and similar tracking technologies to enhance your experience on our platform, analyse usage patterns, and deliver relevant content. The types of cookies we use include:

• Essential cookies: Necessary for the basic functioning of the 365juan platform, including maintaining your login session and remembering your preferences. These cannot be disabled.
• Analytics cookies: Used to collect anonymised data about how players use the 365juan platform, helping us improve performance and user experience.
• Functional cookies: Used to remember your settings and personalise your experience on 365juan, such as your preferred language or display settings.
• Marketing cookies: Used to deliver relevant promotional content and measure the effectiveness of our marketing campaigns. These are only activated with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 365juan platform.

10. Your Data Rights

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by 365juan:

• Right to be informed: You have the right to be informed about how your personal data is collected and processed by 365juan — which is the purpose of this Privacy Policy.
• Right of access: You have the right to request a copy of the personal data that 365juan holds about you.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data held by 365juan.
• Right to erasure: You have the right to request deletion of your personal data, 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.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used format.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at the details provided in Section 14 of this Policy. We will respond to all verified requests within thirty (30) days in accordance with RA 10173.

11. Minors & Age Policy

Parents and guardians who believe that a minor may have registered on 365juan are encouraged to contact our support team immediately at [email protected] so that we can take prompt action.

12. Cross-Border Data Transfers

In certain circumstances, 365juan may transfer your personal data to service providers or partners located outside the Philippines — for example, cloud infrastructure providers or technology partners. Where such transfers occur, we ensure that appropriate safeguards are in place to protect your personal data, including contractual data protection clauses that meet the standards required by the Data Privacy Act of 2012 and the National Privacy Commission.

We will not transfer your personal data to any jurisdiction that does not provide an adequate level of data protection without first obtaining your explicit consent or implementing appropriate contractual safeguards.

13. Policy Amendments

365juan reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable Philippine law, or regulatory requirements. When material changes are made, we will notify registered players via email or through a prominent notice on the 365juan platform prior to the changes taking effect.

Your continued use of the 365juan platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically. The "Last Updated" date at the top of this page reflects the most recent revision.

14. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by 365juan, please contact our Data Protection Officer (DPO). Our DPO is responsible for overseeing compliance with the Data Privacy Act of 2012 and ensuring that your data rights are respected.

You also have the right to escalate any unresolved privacy concerns to the National Privacy Commission (NPC) of the Philippines, the independent authority responsible for administering and implementing the Data Privacy Act of 2012.