millon88 Privacy Policy

This Privacy Policy ("Policy") describes how millon88 ("millon88," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of individuals ("you," "your," or "Member") who access or use the millon88 online casino platform, including the website at millon88.club and any associated mobile applications or services (collectively, the "Platform").

millon88 is committed to protecting the privacy and security of your personal data in accordance with the Republic Act No. 10173 (Data Privacy Act of 2012), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines. We also observe applicable international data protection standards where relevant to our operations.

By registering an account on the millon88 Platform or by continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must discontinue use of the millon88 Platform immediately.

This Policy should be read together with the millon88 Terms and Conditions, which govern your use of the Platform and are incorporated herein by reference.

For the purposes of the Data Privacy Act of 2012 and this Policy, millon88 acts as the Personal Information Controller (PIC) with respect to the personal data of its Members. As PIC, millon88 determines the purposes and means of processing your personal data.

millon88 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data privacy laws. You may contact the millon88 DPO at any time using the contact details provided in Section 14 of this Policy.

Where millon88 engages third-party service providers to process personal data on its behalf, such providers act as Personal Information Processors (PIPs) and are contractually bound to process data only in accordance with millon88's instructions and applicable law.

millon88 collects the following categories of personal data from Members and Platform users:

millon88 does not collect sensitive personal information (as defined under the DPA) beyond what is strictly necessary for identity verification and regulatory compliance purposes.

millon88 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access and interact with the millon88 Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud screening data from anti-fraud partners; payment data from payment processors (GCash, Maya, banks); and publicly available information where permitted by law.
• Regulatory sources: Information received from PAGCOR or other Philippine regulatory authorities in connection with licensing, compliance, or investigation requirements.

millon88 uses your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your millon88 account; verifying your identity and age (21+ requirement); processing login and authentication requests.
• Payment processing: Facilitating deposits and withdrawals via GCash, Maya, bank transfer, and debit card; verifying payment method ownership; maintaining transaction records.
• Legal and regulatory compliance: Meeting KYC and Anti-Money Laundering (AML) obligations; reporting to PAGCOR and other Philippine authorities as required; responding to lawful requests from law enforcement.
• Fraud prevention and security: Detecting and preventing unauthorized access, fraudulent transactions, bonus abuse, and other prohibited conduct; monitoring for suspicious activity.
• Responsible gaming: Monitoring gaming patterns to identify at-risk behavior; enforcing self-exclusion requests; applying deposit limits and cooling-off periods set by Members.
• Customer support: Responding to inquiries, resolving disputes, and improving support quality through interaction records.
• Marketing and promotions: Sending promotional offers, bonus notifications, and platform updates — only where you have provided consent or where permitted by law. You may opt out at any time.
• Platform improvement: Analyzing usage patterns to improve game offerings, platform performance, and user experience.

millon88 will not use your personal data for any purpose incompatible with those listed above without first obtaining your consent or establishing another lawful basis for processing.

millon88 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Consent: Where you have given clear, informed consent to the processing of your data for a specific purpose (e.g., marketing communications). You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Contractual necessity: Processing necessary to perform the contract between you and millon88 — including account registration, game access, and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including KYC, AML, and PAGCOR reporting obligations.
• Legitimate interests: Processing necessary for millon88's legitimate business interests, including fraud prevention, platform security, and service improvement, provided such interests are not overridden by your rights and freedoms.

millon88 does not sell your personal data to third parties. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment processors: GCash, Maya, BPI, BDO, Metrobank, UnionBank, and other Philippine payment providers, for the purpose of processing your financial transactions.
• KYC and identity verification providers: Third-party services that assist millon88 in verifying your identity and age in compliance with regulatory requirements.
• Game providers and software licensors: Third-party game studios whose games are available on the millon88 Platform, to the extent necessary for game operation and fairness auditing.
• IT and cloud service providers: Hosting, infrastructure, and security service providers who process data on millon88's behalf under strict contractual obligations.
• Regulatory and law enforcement authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies, where disclosure is required by law or court order.
• Professional advisors: Lawyers, auditors, and accountants, where necessary for legal compliance or business operations, subject to professional confidentiality obligations.

Any third party receiving your personal data is required to handle it in accordance with applicable data privacy laws and millon88's data protection standards. millon88 remains responsible for ensuring that such third parties provide adequate protection for your data.

8.1 What Are Cookies. Cookies are small text files placed on your device when you visit the millon88 Platform. They help us recognize your device, remember your preferences, and improve your experience.

8.2 Types of Cookies We Use.

• Strictly necessary cookies: Required for the Platform to function — including session management, login authentication, and security features. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and game display options to personalize your experience.
• Analytics cookies: Help us understand how Members use the Platform so we can improve performance and content. Data collected is aggregated and anonymized where possible.
• Security cookies: Used to detect and prevent fraudulent activity, unauthorized access, and bot traffic.

8.3 Managing Cookies. You can control non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the millon88 Platform. millon88 does not use third-party advertising or tracking cookies for cross-site behavioral advertising.

millon88 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account data: Retained for the duration of your active account, plus a minimum of five (5) years after account closure, in compliance with AML and PAGCOR record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• KYC documents: Retained for a minimum of five (5) years after the end of the business relationship, or longer if required by a regulatory investigation.
• Support communications: Retained for two (2) years from the date of the last interaction, unless a longer period is required for dispute resolution.
• Technical and usage data: Retained for up to twelve (12) months, after which it is aggregated or anonymized.

Upon expiry of the applicable retention period, millon88 will securely delete or anonymize your personal data in accordance with its data disposal procedures.

millon88 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Encryption: All data transmitted between your device and the millon88 Platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data at rest is encrypted using AES-256 encryption.
• Access controls: Access to personal data is restricted to authorized millon88 personnel and service providers on a strict need-to-know basis. All access is logged and audited.
• Two-factor authentication: millon88 supports and encourages the use of two-factor authentication (2FA) for Member accounts to prevent unauthorized access.
• Regular security audits: millon88 conducts regular security assessments, penetration testing, and vulnerability scans to identify and address potential security risks.
• Incident response: millon88 maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, millon88 will notify the National Privacy Commission and affected Members within the timeframes required by law.

While millon88 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your millon88 account credentials and for notifying us immediately of any suspected unauthorized access.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by millon88:

• Right to be informed: The right to know what personal data millon88 collects about you and how it is used — which this Policy fulfills.
• Right of access: The right to request a copy of the personal data millon88 holds about you, including information on how it has been processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data. You may update most account information directly through your millon88 account settings.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to millon88's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller where technically feasible.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe millon88 has violated your data privacy rights.

To exercise any of these rights, please contact the millon88 Data Protection Officer using the details in Section 14. millon88 will respond to all verified requests within fifteen (15) business days, or within the timeframe required by applicable law.

The millon88 Platform is strictly intended for individuals who are twenty-one (21) years of age or older, in accordance with Philippine gaming regulations. millon88 does not knowingly collect personal data from individuals under the age of 21.

If millon88 discovers or is notified that it has inadvertently collected personal data from a person under 21 years of age, it will promptly delete such data and close the associated account. If you believe that a minor has registered on the millon88 Platform, please contact us immediately at the details provided in Section 14.

Parents and guardians are encouraged to use parental control tools and to monitor their children's online activity to prevent underage access to gambling platforms.

millon88 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or Platform features. When we make material changes, we will update the "Last Updated" date at the top of this Policy and, where appropriate, notify registered Members via email or in-platform notification.

Your continued use of the millon88 Platform following the posting of an updated Privacy Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically to stay informed about how millon88 protects your personal data.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by millon88, please contact our Data Protection Officer:

• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 through the millon88 Platform
• Response Time: Within fifteen (15) business days for data privacy requests