Privacy Policy — millon88 Online Casino

1 Who We Are

millon88 ("millon88," "we," "us," or "our") is an online casino and sports betting platform operating at millon88.net, designed and operated for players in the Philippines. For the purposes of the Data Privacy Act of 2012 and its implementing rules, millon88 acts as the Personal Information Controller in respect of the personal data of its registered players and site visitors.

Our designated Data Privacy Officer (DPO) is responsible for overseeing compliance with this Privacy Policy and applicable data privacy legislation. You may contact the DPO at any time via email at [email protected], clearly marking your communication as "Data Privacy Enquiry."

2 Scope of This Policy

This Privacy Policy applies to all personal data collected by millon88 through the following channels:

• The millon88 website accessible at millon88.net and all subdomain pages thereon;
• Any future millon88 mobile application made available to Philippine players;
• Communications between you and millon88, including live chat, email, and SMS;
• Any other means by which you provide personal information to millon88 in connection with your use of the platform or its services.

This Policy does not apply to third-party websites, payment platforms (such as GCash, Maya, BPI, or BDO), or game software providers accessed through links or integrations on the millon88 platform. Those third parties operate under their own privacy policies, and we encourage you to review them independently.

3 Personal Data We Collect

millon88 collects the following categories of personal data from players and site visitors:

millon88 does not collect sensitive personal information (as defined in RA 10173, Section 3(l)) such as health data, religious or political affiliations, or biometric data, unless specifically required for regulatory identity verification and only with your explicit consent.

4 How We Collect Your Data

millon88 collects personal data through the following means:

• Direct submission: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting support, or responding to a survey or promotion.
• Automated technical collection: Technical and usage data collected automatically when you access and interact with the millon88 platform, through server logs, session tracking, and browser cookies.
• Payment processors: Financial data shared by GCash, Maya, and participating banks in connection with your deposit and withdrawal transactions, subject to those providers' own privacy policies.
• Identity verification providers: Where third-party KYC services are used to verify the authenticity of identity documents submitted by players, limited identity data may be shared with and returned from those providers.
• Publicly available sources: In cases of fraud investigation or regulatory inquiry, millon88 may cross-reference data against publicly available government records where permitted by law.

5 Purpose & Legal Basis for Processing

millon88 processes your personal data only for the following specific, legitimate purposes, each grounded in a lawful basis under RA 10173:

• Account creation and management: To register your account, authenticate your identity at login, maintain your account settings, and communicate important account-related notices. Basis: performance of contract.
• Payment processing: To process deposits and withdrawals via GCash, Maya, and bank transfer, and to maintain accurate transaction records. Basis: performance of contract; legal obligation.
• Identity verification (KYC): To verify your age (21+), identity, and the ownership of your payment method before processing withdrawals, as required by applicable Philippine gaming regulations. Basis: legal obligation.
• Fraud prevention and security: To detect and prevent fraudulent transactions, money laundering, collusion, account takeovers, and other prohibited conduct. Basis: legitimate interest; legal obligation.
• Responsible gaming: To monitor play patterns that may indicate problem gambling, to administer self-exclusion and deposit limit requests, and to comply with responsible gaming obligations. Basis: legal obligation; legitimate interest.
• Legal compliance: To comply with PAGCOR requirements, anti-money laundering regulations under Republic Act No. 9160 as amended, tax obligations, and court or regulatory orders. Basis: legal obligation.
• Platform improvement: To analyse aggregated, anonymised usage data to improve the millon88 platform, fix technical issues, and enhance the player experience. Basis: legitimate interest.
• Marketing communications: To send promotional offers and platform updates to players who have consented to receive such communications. You may withdraw consent at any time by contacting support. Basis: consent.

6 Disclosure of Personal Data

millon88 does not sell, rent, or trade your personal data. We disclose your data only in the following limited circumstances:

• Payment service providers: GCash (G-Xchange, Inc.), Maya (PayMaya Philippines, Inc.), BPI, BDO, Metrobank, and other participating banks — to facilitate deposit and withdrawal processing. These providers receive only the data necessary to execute the specific transaction.
• KYC and identity verification providers: Third-party identity verification services engaged by millon88 for the purpose of authenticating player documents. These providers are bound by confidentiality obligations and may not use your data for any other purpose.
• Game software providers: JILI Gaming, Pragmatic Play, PG Soft, Evolution Gaming, and other integrated studios may receive your player ID and session token for the purpose of game delivery. These providers do not receive your contact or financial data.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and any court or law enforcement body with a legitimate legal basis to require disclosure. millon88 will only comply with lawful requests and will notify you where legally permitted to do so.
• Professional advisors: Legal counsel, accountants, and auditors who are bound by professional confidentiality obligations, where disclosure is necessary for the operation and governance of millon88.
• Business transfers: In the event of a merger, acquisition, or transfer of all or part of millon88's business assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections as set out in this Policy. You will be notified of any such transfer.

7 International Data Transfers

Where millon88 engages service providers — including game software studios and technical infrastructure providers — whose operations are based outside the Philippines, your data may be processed in other countries. In all such cases, millon88 ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to RA 10173, including contractual data processing agreements with each third-party processor.

millon88 does not transfer personal data to jurisdictions that have not implemented adequate data protection frameworks without first obtaining your explicit consent or ensuring appropriate contractual protections are in place.

8 Data Retention

millon88 retains your personal data for as long as your account is active and for a further period after account closure as required by applicable law and regulation. The following general retention periods apply:

• Account and identity data: Retained for a minimum of five (5) years following account closure, as required for AML compliance under RA 9160 as amended by RA 10365 and subsequent legislation.
• Financial transaction records: Retained for a minimum of five (5) years following the date of the transaction, as required for tax and regulatory reporting purposes.
• Support communications: Retained for two (2) years following the closure of the relevant support ticket, unless the matter is subject to ongoing legal proceedings.
• Technical and usage data: Retained in anonymised or aggregated form for platform analytics. Personally identifiable technical data is retained for twelve (12) months from collection.
• Self-exclusion records: Retained indefinitely to prevent re-registration by self-excluded players, as required by responsible gaming obligations.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with accepted data disposal standards.

9 Security Measures

millon88 implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the millon88 platform;
• Encryption at rest for sensitive personal and financial data stored in millon88's databases;
• Role-based access controls, ensuring that only authorised millon88 personnel with a legitimate operational need can access personal data;
• Two-factor authentication (2FA) available to all players and mandatory for internal administrative access;
• Regular internal security audits and vulnerability assessments;
• Strict third-party vendor security assessment before any data processor is engaged.

10 Cookies & Tracking Technologies

millon88 uses cookies and similar tracking technologies to operate the platform, authenticate your session, remember your preferences, and collect anonymised analytics on how the site is used. The following types of cookies are used:

• Strictly necessary cookies: Required for the platform to function. These include session authentication cookies that keep you logged in during an active session. These cannot be disabled without impairing platform functionality.
• Functional cookies: Used to remember your preferences such as language settings and login method choices. Disabling these may affect your experience but will not prevent core platform access.
• Analytics cookies: Anonymised data collected to understand how players interact with the millon88 site, which pages are visited most, and where technical issues occur. This data is used solely for platform improvement and is not linked to your personal identity.
• Security cookies: Used to detect fraud signals, identify suspicious login patterns, and protect the integrity of your session.

You may manage cookie preferences through your browser settings. Note that disabling all cookies may prevent the millon88 platform from functioning correctly. millon88 does not use third-party advertising cookies or behavioural targeting cookies.

11 Your Data Subject Rights

Under Republic Act No. 10173 and its implementing rules, you have the following rights in relation to your personal data held by millon88. These rights are not absolute and may be subject to limitations imposed by law or regulatory requirements:

To exercise any of these rights, submit a written request to [email protected] with "Data Subject Rights Request" in the subject line. millon88 will acknowledge your request within 3 business days and provide a substantive response within 15 business days, or advise you if an extension is required.

12 Minors

The millon88 platform is strictly for individuals aged 21 years and above. millon88 does not knowingly collect personal data from individuals under the age of 21. If we become aware that an account has been created by or on behalf of a person under the age of 21, we will immediately suspend the account, delete the associated personal data to the extent not required by law, and forfeit any balance in line with our Terms and Conditions.

If you believe that a minor may have registered an account or provided personal data to millon88 using false age information, please contact us immediately at [email protected].

13 Third-Party Services

The millon88 platform integrates with third-party services including game software providers, payment processors, and analytics tools. When you interact with these integrations — for example, by launching a JILI or Pragmatic Play game, or completing a GCash deposit — your data may be processed by those third parties in accordance with their own privacy policies.

millon88 is not responsible for the privacy practices of third-party services. We encourage you to review the privacy policies of GCash (G-Xchange, Inc.), Maya (PayMaya Philippines, Inc.), and your bank before linking them to your millon88 account.

millon88 does not share your personal data with game providers beyond what is necessary for game delivery — specifically, an anonymised player session token that does not include your name, contact details, or financial information.

14 Data Breach Response

millon88 maintains a documented Data Breach Response Plan. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, millon88 will:

• Notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, as required by NPC Circular 16-03;
• Notify affected players directly as soon as reasonably practicable, providing details of the nature of the breach, the data categories involved, and the steps being taken to address the breach;
• Take immediate remedial action to contain the breach, including temporary account access restrictions where necessary to protect player data;
• Conduct a post-incident review and implement additional safeguards to prevent recurrence.

Notifications to affected players will be delivered via the registered email address or Philippine mobile number on file. Please ensure your contact details are kept current in your millon88 account settings.

15 Amendments to This Policy

millon88 reserves the right to amend this Privacy Policy at any time to reflect changes in law, regulatory requirements, platform operations, or data processing practices. Where a change is material — for example, a new category of data being collected or a new class of third-party recipient — millon88 will provide at least fourteen (14) calendar days' notice to registered players via their registered email address or through a prominent in-platform notification before the revised policy takes effect.

Minor or clarificatory amendments may be made with immediate effect. The "Last Revised" date displayed at the top of this page will always reflect the date of the most recent update. We encourage you to review this page periodically.

Your continued use of the millon88 platform after any amendment takes effect constitutes your acceptance of the revised Privacy Policy. If you do not accept an amendment, you must cease using the platform and request account closure before the revised policy's effective date.

16 Contact Us — Data Privacy

All privacy-related communications should be directed to the millon88 Data Privacy Officer:

• Email: [email protected] — subject line: "Data Privacy Enquiry"
• Live Chat: Available 24/7 via the millon88 website. For data subject rights requests, please confirm your identity and specify "Data Privacy" when initiating the chat.
• Response timeframe: Acknowledgement within 3 business days; substantive response within 15 business days as required by NPC regulations.

If you believe millon88 has not adequately addressed your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines at www.privacy.gov.ph or through their official contact channels.