juanph Privacy Policy

1. Introduction

juanph ("we", "us", "our") is committed to protecting the privacy and personal data of all players and visitors who interact with the juanph platform. This Privacy Policy has been prepared in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations, which are administered by the National Privacy Commission (NPC).

juanph also processes personal data in accordance with the requirements of the Anti-Money Laundering Act (RA 9160, as amended) and directives issued by PAGCOR — the Philippine Amusement and Gaming Corporation — as part of its licensing obligations. Certain data collection and retention obligations arise directly from these regulatory frameworks and are non-negotiable from a compliance standpoint.

This policy explains our practices in plain, straightforward language. We want every Filipino player using juanph to understand exactly what happens to their personal information — because trust is built on transparency, not fine print.

2. Data Controller

For the purposes of the Data Privacy Act of 2012, juanph is the Personal Information Controller (PIC) in respect of all personal data collected through the platform. This means juanph determines the purposes and means of processing your personal data. Third-party service providers engaged by juanph (payment processors, game providers, KYC verification services) act as Personal Information Processors (PIPs) and process data only as directed by juanph under written data processing agreements.

juanph has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act and this policy. Contact details for the DPO are provided in Section 15 of this policy.

3. Personal Data We Collect

juanph collects the following categories of personal data in the course of providing the platform and complying with our regulatory obligations.

3.1 Identity and Contact Data

3.2 Financial Data

juanph collects financial data necessary for processing deposits, withdrawals, and fulfilling AML reporting obligations. This includes: GCash account numbers, PayMaya account details, BPI/BDO/Metrobank account numbers used for transactions, transaction amounts and timestamps, and the complete history of deposits and withdrawals on your juanph account. Full payment card numbers are never stored by juanph — card transactions (if applicable) are tokenized by the payment processor.

3.3 Gameplay and Betting Data

The juanph platform records a complete log of all gaming activity associated with your account, including: game titles played, wager amounts, game outcomes, session start and end times, bonus activations and wagering progress, and sports bets placed with odds and results. This data is required for dispute resolution, regulatory auditing, and responsible gaming monitoring.

3.4 Technical and Device Data

juanph automatically collects technical data when you access the platform, including: IP address, device type and model, operating system and version, browser type, screen resolution, session timestamps, and approximate geographic location derived from IP. This data is used for fraud prevention, security monitoring, and platform optimization.

4. How We Collect Personal Data

juanph collects personal data through the following means:

• Direct submission: Data you provide during account registration, the KYC verification process, deposit and withdrawal requests, customer support interactions, and survey or feedback submissions.
• Automated collection: Technical data collected automatically when you access the juanph platform through cookies, session logs, and server-side analytics. See Section 10 for full cookie details.
• Third-party sources: Identity verification data from KYC service providers used to validate government ID documents; fraud risk scores from fraud prevention partners; transaction confirmation data from payment processors including GCash and PayMaya.
• Public sources: Publicly available information that may be used as part of AML screening processes, including sanctions list checks required by Philippine law.

5. Purposes of Processing

juanph processes your personal data for the following purposes:

• Account creation and management: Registering your juanph account, verifying your identity, maintaining your account profile, and processing login and authentication.
• Service delivery: Enabling access to all game categories on juanph, processing deposits and withdrawals, crediting promotional bonuses, and resolving game disputes.
• Regulatory compliance: Fulfilling PAGCOR licensing requirements, conducting AML screening and transaction monitoring, fulfilling mandatory reporting obligations, and retaining records required by Philippine law.
• Age verification: Verifying that all players are 21 years of age or older as required by PAGCOR regulations.
• Security and fraud prevention: Detecting and preventing unauthorized account access, fraudulent transactions, bonus abuse, and money laundering activity.
• Responsible gaming: Monitoring account activity to identify indicators of problem gambling behavior and providing proactive outreach where warranted; implementing player-requested responsible gaming tools.
• Customer support: Responding to your inquiries, complaints, and dispute submissions through live chat and email support channels.
• Platform improvement: Analyzing aggregated, anonymized usage data to improve juanph's game library, interface design, and service quality.
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates to players who have not opted out of such communications. You may opt out at any time via account settings or by contacting support.

6. Legal Basis for Processing

Under the Data Privacy Act of 2012, juanph processes your personal data on the following legal grounds, depending on the purpose:

• Contractual necessity: Processing required to perform our obligations under the juanph Terms & Conditions, including account creation, game delivery, and payment processing.
• Legal obligation: Processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act, the Data Privacy Act, and other applicable Philippine laws — including mandatory AML record-keeping and regulatory reporting.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your privacy rights.
• Consent: Processing for optional marketing communications, which you may withdraw at any time without affecting your account or gaming access.

7. Data Sharing and Disclosure

juanph does not sell or commercially trade your personal data. We share personal data only with the following categories of recipients, and only to the extent necessary for the stated purpose:

7.1 Service Providers (Personal Information Processors)

juanph engages third-party service providers who process personal data on our behalf under written data processing agreements. These include: payment processors (GCash, PayMaya, BancNet-connected banks), KYC and identity verification providers, live dealer studio operators, game software providers (including JILI Games), cloud hosting and infrastructure providers, and fraud prevention and AML screening services. All PIPs are contractually bound to process data only as directed by juanph and in compliance with the Data Privacy Act.

7.2 Regulatory and Law Enforcement Authorities

juanph is required by law to disclose personal data and transaction records to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent government authorities in the Philippines when required by regulation, court order, or lawful request. These disclosures are mandatory and cannot be refused.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of the juanph business or its assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer that materially affects this Privacy Policy, and the acquiring entity will be required to honor the commitments made in this policy.

8. Data Retention Periods

juanph retains personal data only for as long as necessary to fulfill the purposes for which it was collected, including compliance with legal retention obligations. The following retention periods apply:

• Account and identity data: Retained for the duration of the account relationship plus five (5) years after account closure, in accordance with AML retention requirements under RA 9160.
• Transaction records: Retained for five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act and PAGCOR regulations.
• Gameplay and betting logs: Retained for three (3) years from the date of each session, for dispute resolution and responsible gaming purposes.
• KYC documents: Retained for five (5) years after account closure or the last transaction date, whichever is later.
• Customer support records: Retained for two (2) years from the date of the interaction.
• Marketing communication records (consent logs): Retained for the duration of the account relationship to demonstrate compliance with consent obligations.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with juanph's data disposal procedures. Anonymized data may be retained indefinitely for aggregated statistical and analytical purposes.

9. Security Measures

juanph implements technical and organizational security measures designed to protect your personal data against unauthorized access, loss, destruction, or alteration. These measures include:

• Encryption in transit: All data transmitted between your device and the juanph platform is protected by 256-bit TLS/SSL encryption. Unencrypted connections are rejected.
• Encryption at rest: Personal data stored in juanph's infrastructure is encrypted at rest using AES-256 standard encryption.
• Access controls: Access to personal data within juanph's systems is restricted to authorized personnel on a need-to-know basis. All internal access is logged and auditable.
• Two-factor authentication: Player accounts are protected by SMS-based 2FA for new device logins. juanph employees accessing internal systems are required to use multi-factor authentication.
• Penetration testing and security audits: juanph's platform and infrastructure undergo regular security assessments by qualified security professionals.
• Incident response plan: juanph maintains a documented data breach response procedure aligned with NPC notification requirements under the Data Privacy Act.

Notwithstanding these measures, no internet-based platform can guarantee absolute security. You are responsible for keeping your account credentials confidential and for reporting any suspected unauthorized access to juanph support immediately.

10. Cookies and Tracking Technologies

10.1 What Are Cookies

Cookies are small text files placed on your device when you access the juanph platform. They allow the platform to recognize your device, maintain your session, remember your preferences, and collect analytics data. juanph uses both first-party cookies (set by juanph directly) and third-party cookies (set by service providers acting on our behalf).

10.2 Types of Cookies Used

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies that keep you logged in during your visit. These cookies cannot be disabled without breaking core platform functionality.
• Functional Cookies: Used to remember your language, display, and game preferences to improve your experience on repeat visits.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players navigate the juanph platform — which pages are visited, how long sessions last, and which features are used most. This data helps juanph improve the platform.
• Security Cookies: Used to support fraud detection, anomalous behavior detection, and CAPTCHA functionality to protect accounts from automated attacks.

10.3 Cookie Management

You may manage non-essential cookies through your browser settings. Most modern browsers allow you to block or delete cookies. Note that disabling certain cookies may affect the functionality of the juanph platform, including the ability to remain logged in during a session. Instructions for managing cookies are available in your browser's help documentation.

11. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by juanph. To exercise any of these rights, contact the juanph Data Protection Officer using the details in Section 15. juanph will respond to all verified data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

12. Minors and Age Restrictions

The juanph platform is strictly restricted to individuals aged 21 years or older — the minimum age for casino-style gambling under PAGCOR regulations. juanph does not knowingly collect personal data from individuals under the age of 21.

Age verification is a mandatory step during the juanph KYC process. Where juanph discovers that personal data has been collected from a minor — whether through registration under a false date of birth or access through a third party's account — the relevant account will be immediately suspended, all personal data associated with the minor will be deleted, and any funds deposited will be returned to the originating payment method.

If you believe a minor has accessed a juanph account, please contact support immediately so the appropriate steps can be taken without delay.

13. Cross-Border Data Transfers

Some of juanph's third-party service providers — including cloud infrastructure providers, game studios, and fraud prevention partners — may be located outside the Philippines. Where personal data is transferred to recipients in other countries, juanph ensures that such transfers are subject to appropriate safeguards consistent with the Data Privacy Act, including:

• Data processing agreements with contractual data protection obligations equivalent to Philippine DPA requirements;
• Transfers only to countries or organizations that provide an adequate level of data protection;
• Implementation of Standard Contractual Clauses where required by the National Privacy Commission.

juanph does not transfer personal data to recipients outside the Philippines for purposes beyond those described in this Privacy Policy.

14. Amendments to This Privacy Policy

juanph may update this Privacy Policy from time to time to reflect changes in our data processing practices, platform features, or applicable law. Material changes — including changes that expand the categories of data collected, introduce new purposes for processing, or affect your rights — will be communicated to registered players via SMS notification to the registered mobile number and/or prominent in-platform notice at least seven (7) days before taking effect.

Non-material changes (such as clarifications, formatting updates, or corrections to typographical errors) may be made without advance notice. The current version and effective date of this policy are always displayed at the top of this page and in the juanph platform's legal documentation section. Your continued use of juanph following the effective date of any amendment constitutes acceptance of the updated policy.

15. Contact & Data Protection Officer

For all data privacy matters — including data subject rights requests, privacy concerns, or questions about this Privacy Policy — please contact the juanph Data Protection Officer using the channels below. juanph aims to acknowledge all privacy requests within two (2) business days and resolve them within fifteen (15) business days of receipt.