Privacy Policy – How 365 Juan Protects Your Personal Data

1. Who We Are

365 Juan is an online gaming and sports betting platform operated for Filipino adult players. When this Privacy Policy refers to "we," "us," or "365 Juan," it means the entity responsible for operating the platform at 365juan.xyz. We are the data controller in respect of all personal information collected through the platform, our mobile web interface, and any direct communications with our support team.

If you have questions about this policy or wish to exercise your data rights, you may contact our Data Privacy Officer at support@365juan.xyz. We aim to respond to all privacy-related enquiries within five business days.

2. Data We Collect

365 Juan collects personal data across three broad categories depending on how you interact with the platform:

2.1 Information you provide directly. When you register for a 365 Juan account, you supply your full legal name, date of birth, home address, mobile number, and email address. During the Know Your Customer verification process you may also upload copies of a valid government-issued ID such as a Philippine passport, driver's licence, national ID, or SSS/GSIS card, as well as a proof of residential address such as a utility bill or bank statement.

2.2 Payment and transaction data. When you make a deposit or request a withdrawal, 365 Juan receives transaction reference numbers, e-wallet identifiers, partial card numbers, bank account names, and transaction amounts. We do not store full card numbers. Payment processor APIs transmit only the data required for transaction verification and reconciliation.

2.3 Technical and device data. The platform automatically logs your IP address, device type, operating system, browser type, session timestamps, pages visited, game activity records, bet histories, and platform interaction data. This information is used for security monitoring, fraud prevention, platform performance, and regulatory reporting.

2.4 Communications data. If you contact 365 Juan support by email, live chat, or any other channel, the content of that communication is stored and associated with your account record for quality assurance, dispute resolution, and regulatory purposes.

3. How We Use Your Data

365 Juan uses the personal data we hold about you for the following specific purposes:

• Account creation and management: Processing your registration, maintaining your account, authenticating your identity, and enabling access to all 365 Juan features.
• Payment processing: Facilitating deposits, processing withdrawal requests, and reconciling transactions with our payment processing partners.
• Identity and age verification: Confirming that you meet the legal age requirement of 18 years and that your account is operated by the person who registered it.
• Fraud prevention and security: Detecting and preventing unauthorised account access, fraudulent transactions, money laundering, and other prohibited conduct.
• Regulatory compliance: Fulfilling reporting obligations required by applicable Philippine gaming and anti-money laundering regulations.
• Customer support: Responding to queries, resolving disputes, investigating complaints, and maintaining records of customer interactions.
• Responsible gaming: Monitoring play patterns to identify players who may be experiencing problem gambling and implementing protective measures where appropriate.
• Marketing communications: Sending promotional offers, platform news, and personalised recommendations – only where you have consented to receive them or where we have a legitimate interest in communicating with you as an existing customer.
• Platform improvement: Analysing aggregated and anonymised usage data to improve game performance, interface design, payment flows, and support processes.

4. Legal Bases for Processing

Under the Philippine Data Privacy Act of 2012, 365 Juan processes your personal data on the following legal bases:

• Contractual necessity: Processing required to create and manage your account, process transactions, and deliver the services you have signed up for.
• Legal obligation: Processing required for 365 Juan to comply with applicable Philippine law, including gaming regulations, anti-money laundering requirements, and tax reporting obligations.
• Legitimate interest: Processing for fraud prevention, platform security, responsible gaming monitoring, and improvement of our services, where these interests are not overridden by your individual privacy rights.
• Consent: Processing for optional marketing communications and non-essential cookies, which you may withdraw at any time without affecting the operation of your account.

5. Sharing Your Information

365 Juan does not sell or commercially transfer your personal data to third parties. We share your information only in the following limited circumstances:

• Payment processors: We share transaction data with our payment partners – including GCash, Maya, GrabPay, Coins.ph, and banking institutions – solely for the purpose of processing deposits and withdrawals. These partners are bound by their own data privacy obligations and applicable Philippine financial regulations.
• Identity verification services: We use accredited identity verification providers to assist with KYC checks. Only the data strictly necessary for verification is shared, and these providers are contractually prohibited from using your data for any other purpose.
• Game software providers: Third-party game studios whose titles are hosted on the 365 Juan platform may receive anonymised session and outcome data necessary to operate the games. Individual player identity is not shared with game providers.
• Regulatory and law enforcement authorities: 365 Juan will disclose personal data to the National Privacy Commission, relevant gaming regulators, law enforcement agencies, or courts where required to do so by Philippine law or by a valid legal order.
• Professional advisers: Legal counsel, auditors, and compliance consultants may access personal data under strict confidentiality obligations in the course of their professional engagement with 365 Juan.

6. Data Retention

365 Juan retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Active account data: Retained for the duration of your account and for a period of five years following account closure, in line with Philippine anti-money laundering record-keeping requirements.
• Transaction records: Retained for at least five years from the date of the transaction as required by applicable financial regulations.
• KYC documents: Retained for a minimum of five years following account closure or the last transaction date, whichever is later.
• Support communications: Retained for three years from the date of the interaction, or longer where the communication relates to an open dispute or regulatory matter.
• Marketing consent records: Retained for the period of your active consent and for one year following any withdrawal of consent, as evidence of your preference history.
• Technical logs: Session and access logs are retained for 90 days unless they are relevant to an ongoing security or fraud investigation, in which case they may be retained for longer.

When personal data is no longer required, it is deleted or anonymised using secure data destruction processes.

7. Data Security

365 Juan implements technical and organisational security measures appropriate to the sensitivity of the personal data we hold. These measures include:

• TLS encryption for all data in transit between your device and our servers.
• AES-256 encryption for sensitive data stored in our databases.
• Multi-factor authentication options for player account access.
• Role-based access controls limiting staff access to personal data on a need-to-know basis.
• Regular security audits and penetration testing by independent specialists.
• Intrusion detection systems and real-time anomaly monitoring.
• Staff training on data privacy obligations and secure handling procedures.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 365 Juan will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected players without undue delay where required by law.

8. Cookies and Tracking Technologies

365 Juan uses cookies and similar technologies including local storage and session tokens on its web platform. Below is a summary of the cookie categories we use: