Privacy Policy —
How jua365 Handles Your Data

1 Introduction & Scope

1.1 jua365 takes the privacy of its players seriously. This Policy applies to all personal data collected through the jua365 website, mobile browser interface, customer support channels, and any other platform operated by jua365.

1.2 This Policy applies to all registered players and visitors to the jua365 platform, regardless of whether they are located in Metro Manila, Cebu, Davao, or elsewhere in the Philippines.

1.3 This Policy should be read together with the jua365 Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

1.4 jua365 is committed to compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations (IRR), and the relevant issuances of the National Privacy Commission (NPC).

2 Data Controller

2.1 For the purposes of this Policy and applicable Philippine data privacy law, jua365 is the personal information controller ("PIC") responsible for the personal data you provide to or that is collected by the platform.

2.2 jua365 has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Policy and applicable data protection law. Contact details for the DPO are set out in Section 14.

2.3 Where jua365 engages third-party service providers to process personal data on its behalf, those providers act as personal information processors ("PIP") and are bound by data processing agreements that require them to protect your data to the same standard as jua365.

3 Personal Data We Collect

3.1 jua365 collects personal data from you directly and automatically. The categories of personal data we collect include:

3.2 jua365 does not intentionally collect sensitive personal information (such as racial or ethnic origin, religious beliefs, health data, or political opinions) unless specifically required for responsible gaming assessment or regulatory compliance purposes, and only with your explicit consent.

3.3 Where jua365 requires you to submit a government-issued Philippine ID (such as a PhilSys ID, passport, UMID, or driver's licence) for identity verification, the information contained therein will be used solely for KYC and fraud prevention purposes.

4 How jua365 Uses Your Personal Data

4.1 jua365 processes your personal data for the following purposes:

• Account Management: To create, verify, and maintain your jua365 account, including authentication and the enforcement of one-account-per-person policy;
• Platform Delivery: To provide access to games, process bets, and deliver all features of the jua365 platform;
• Financial Processing: To process deposits and withdrawals via GCash, PayMaya, and Philippine banking partners;
• Regulatory Compliance: To comply with PAGCOR requirements, anti-money laundering obligations (AMLA), and instructions from relevant Philippine regulatory authorities;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, multi-accounting, money laundering, and other prohibited conduct;
• Responsible Gaming: To monitor gameplay patterns, identify potential problem gambling behaviour, and enforce self-exclusion, deposit limit, and cooling-off requests;
• Customer Support: To respond to your queries, complaints, and account-related requests through live chat, Viber, Messenger, and email;
• Marketing Communications: To send promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications;
• Platform Improvement: To analyse usage patterns and improve the performance, design, and game offering of the jua365 platform.

4.2 jua365 will not use your personal data for purposes that are incompatible with those described in this Section without first obtaining your consent or establishing a separate legal basis.

5 Legal Basis for Processing

5.1 jua365 processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contract Performance: Processing necessary to perform the Terms & Conditions governing your use of the jua365 platform, including account management and financial transaction processing;
• Legal Obligation: Processing required to comply with applicable Philippine law, including AMLA reporting requirements, PAGCOR regulatory obligations, and NPC directives;
• Legitimate Interests: Processing necessary for jua365's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where those interests are not overridden by your privacy rights;
• Consent: Where you have provided explicit, freely given, informed consent to a specific processing activity — in particular, the receipt of marketing communications. You may withdraw consent at any time without affecting prior processing.

6 Sharing Your Personal Data

6.1 jua365 may share your personal data with the following categories of recipients:

• Payment Processors: GCash (GXchange Inc.), PayMaya (Maya Philippines Inc.), and Philippine banking partners (BPI, BDO, Metrobank, UnionBank) to process your financial transactions;
• KYC & Identity Verification Providers: Accredited identity verification service providers used to conduct document and liveness checks during account verification;
• Game Studio Partners: Licensed game providers whose games are integrated into the jua365 platform, to the extent necessary to deliver the game service and resolve technical disputes;
• IT & Security Service Providers: Cloud infrastructure, cybersecurity, and fraud detection providers who process data on jua365's behalf under binding data processing agreements;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine authorities, where required by law or pursuant to a lawful request;
• Professional Advisers: Legal counsel, auditors, and compliance consultants, under duties of confidentiality.

6.2 All third-party processors engaged by jua365 are required to implement appropriate technical and organisational measures to protect personal data and to process it only in accordance with jua365's documented instructions.

7 Cookies & Tracking Technologies

7.1 jua365 uses cookies and similar tracking technologies on the platform to enable essential platform functions, improve performance, and deliver a personalised experience.

7.2 The types of cookies used by jua365 include:

• Essential Cookies: Required for the platform to function, including session management, login authentication, and security tokens. These cannot be disabled without affecting core platform functionality;
• Analytics Cookies: Used to collect aggregated, anonymised data about how players interact with jua365, to help improve platform performance and user experience;
• Preference Cookies: Store your platform settings and preferences (such as language and display options) between sessions.

7.3 You may manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the performance of the jua365 platform or limit access to certain features.

8 Data Retention

8.1 jua365 retains personal data only for as long as is necessary to fulfil the purposes outlined in this Policy, or as required by applicable Philippine law. The following retention periods apply:

• Active Account Data: Retained for the duration of your registered account's active status on the jua365 platform;
• Transaction & Financial Records: Retained for a minimum of 5 years from the date of the transaction, in compliance with Anti-Money Laundering Act (AMLA) requirements;
• KYC & Identity Documents: Retained for a minimum of 5 years from the date of account closure or the last verified transaction, whichever is later;
• Closed or Inactive Account Data: Accounts inactive for 12 consecutive months may be archived. Upon account closure, identifiable personal data is anonymised or securely deleted within 6 months, unless a longer retention period is required by law;
• Support Communications: Retained for 2 years from the date of the communication to support dispute resolution and compliance review.

8.2 Following the expiry of applicable retention periods, personal data will be securely deleted or irreversibly anonymised.

9 Data Security

9.1 jua365 implements and maintains appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction.

9.2 Security measures deployed by jua365 include:

• 256-bit SSL/TLS encryption for all data transmission;
• Bcrypt hashing for stored passwords — jua365 staff cannot access your plaintext password;
• Multi-factor authentication options for player accounts;
• Role-based access controls limiting internal staff access to personal data on a need-to-know basis;
• Intrusion detection systems and continuous security monitoring;
• Regular penetration testing and security audits by independent third parties.

9.3 In the event of a personal data breach that poses a real risk of serious harm to affected players, jua365 will notify the National Privacy Commission and the affected players within 72 hours of becoming aware of the breach, in accordance with NPC requirements. Notification will include a description of the nature of the breach, the categories and approximate number of records affected, the likely consequences, and the measures taken or proposed to address it.

10 Your Data Subject Rights

• Right to be Informed: The right to be notified of the personal data jua365 collects and the purposes for which it is processed;
• Right of Access: The right to obtain a copy of your personal data held by jua365 and information about how it is being processed;
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected;
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to jua365's legal retention obligations;
• Right to Object: The right to object to the processing of your personal data for marketing purposes or on grounds relating to your particular situation;
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format;
• Right to Damages: The right to be indemnified for damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of personal data.

10.2 jua365 will respond to verified data subject requests within 15 business days. In complex cases, this period may be extended by a further 15 business days with prior written notice to you explaining the reasons for the delay.

10.3 If you are not satisfied with jua365's response to a data privacy request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

11 Children's Privacy

11.1 The jua365 platform is not intended for, and is strictly prohibited to, individuals under the age of 21. In the Philippines, this minimum age applies to all forms of casino-style gaming.

11.2 If jua365 discovers that personal data has been collected from a person under 21, the relevant account will be immediately suspended, any funds will be subject to review, and the personal data will be deleted from jua365's systems as promptly as practicable.

11.3 If you believe jua365 has inadvertently collected personal data from an underage individual, please contact our Data Protection Officer immediately at the details in Section 14.

12 International Data Transfers

12.1 The jua365 platform primarily processes and stores personal data of Philippine players within secure infrastructure. Where personal data is processed by a third-party service provider located outside the Philippines, jua365 ensures that appropriate safeguards are in place to protect the data to a standard equivalent to that required by Philippine law.

12.2 Such safeguards may include contractual data processing agreements incorporating standard contractual clauses, adequacy determinations, or other approved transfer mechanisms recognised under the Data Privacy Act and NPC guidelines.

12.3 You may request further information about the specific safeguards applied to cross-border data transfers by contacting jua365's Data Protection Officer.

13 Changes to This Privacy Policy

13.1 jua365 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.

13.2 Material changes to this Policy will be communicated to registered players via in-platform notification or email prior to the changes taking effect. The "Last Updated" date at the top of this page will reflect the most recent revision.

13.3 Your continued use of the jua365 platform following the publication of an updated Privacy Policy constitutes your acknowledgement of the changes. If you do not agree with an amendment, you must discontinue use of the platform and may request account closure.

14 Contact & Data Protection Officer

14.1 For any questions, concerns, or requests relating to this Privacy Policy or your personal data held by jua365, you may contact us through the following channels: