millon88 Privacy Policy

1Who We Are

millon88 operates the online casino and sports betting platform accessible at millon88.org (the "Platform"). For the purposes of Philippine data protection law — specifically Republic Act No. 10173, the Data Privacy Act of 2012 (DPA) — millon88 is the Personal Information Controller responsible for your personal data collected through the Platform.

millon88 operates under the regulatory framework of the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to all applicable Philippine laws and regulations, including those governing data privacy, anti-money laundering, and responsible gaming. This Privacy Policy applies to all players who access, register, or transact on the millon88 platform.

2Personal Data We Collect

millon88 collects personal data that is necessary to provide you with a safe, regulated, and functional online gaming service. The categories of personal data we collect include:

millon88 does not collect sensitive personal information as defined under the DPA (such as health data, political views, or religious beliefs) except where explicitly required by specific PAGCOR regulatory obligations, in which case you will be separately notified and asked for consent.

3How We Collect Your Data

millon88 collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawal requests, contacting customer support, or responding to surveys or promotions.
• Automated technologies: When you access the millon88 platform, we automatically collect technical and usage data through cookies, server logs, and similar tracking technologies. See Section 7 for full details on our cookie practices.
• Third-party sources: Identity verification and KYC data may be cross-referenced against third-party verification databases, payment provider records, or publicly available government databases as required by PAGCOR's anti-money laundering (AML) obligations.
• Responsible gaming tools: Where you interact with millon88's responsible gaming features — such as setting deposit limits or requesting self-exclusion — this activity is recorded as part of your account profile to ensure the tools function correctly.

4How We Use Your Personal Data

millon88 uses personal data collected from players for the following purposes:

• Account management: Creating and maintaining your millon88 account, verifying your identity and age, and ensuring your account settings and preferences are applied correctly.
• Service delivery: Enabling you to access games, process deposits and withdrawals, award bonuses and promotions, and deliver all features of the millon88 platform.
• Regulatory compliance: Fulfilling millon88's obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, and all other applicable Philippine laws. This includes mandatory reporting of suspicious transactions to the Anti-Money Laundering Council (AMLC).
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, bonus abuse, and other security threats to the platform and to other players.
• Responsible gaming: Monitoring gaming behavior to identify patterns that may indicate problem gambling, enforcing player-set limits and self-exclusions, and providing appropriate support information where warranted.
• Customer support: Responding to enquiries, processing complaints, and resolving disputes efficiently.
• Marketing communications: With your consent, sending promotional offers, new game announcements, and platform updates via SMS or email. You may opt out of marketing communications at any time.
• Platform improvement: Analyzing aggregated and anonymized usage data to improve game performance, user experience, and platform features.

5Legal Basis for Processing

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

• Contractual necessity: Processing that is necessary to perform the contract between you and millon88 — i.e., to operate your account, process your transactions, and deliver gaming services.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, AMLA obligations, DPA requirements, and any other applicable Philippine legal or regulatory mandates.
• Legitimate interests: Processing for fraud prevention, security monitoring, platform analytics, and responsible gaming purposes where these interests are not overridden by your privacy rights.
• Consent: Processing for direct marketing communications, non-essential cookies, and any other processing for which millon88 has specifically requested and obtained your consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6Data Sharing and Disclosure

millon88 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share personal data only in the following circumstances:

• Service providers: Third-party companies that process data on our behalf to deliver specific services, including payment processors (GCash, Maya, BPI, BDO, Metrobank), game software providers, KYC/identity verification services, fraud detection providers, and customer support platform providers. All service providers are contractually bound to process data only as instructed by millon88 and to maintain appropriate security standards.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other Philippine government bodies where disclosure is required by law, court order, or regulatory mandate.
• Law enforcement: Where millon88 is required or permitted by applicable law to disclose data to law enforcement agencies in connection with the investigation of criminal activity, including fraud and money laundering.
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of millon88's assets, player data may be transferred as part of that transaction. Affected players will be notified in advance of any such transfer.

7Cookies and Tracking Technologies

millon88 uses cookies and similar tracking technologies on the platform to enhance your experience, maintain session security, and collect analytics data. The following types of cookies are used:

• Strictly necessary cookies: Required for the platform to function. These include session cookies that keep you logged in during your visit and security cookies that protect against CSRF attacks. These cannot be disabled without impairing platform functionality.
• Functional cookies: Remember your preferences such as language settings, game view preferences, and last-visited sections to personalize your experience.
• Analytics cookies: Collect anonymized data about how players interact with the millon88 platform — which pages are visited, how long sessions last, and which features are used most. This data is used solely to improve the platform.
• Marketing cookies: Used with your consent to track interactions with promotional content and to ensure that marketing communications are relevant to your gaming preferences. You may opt out of marketing cookies at any time.

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the millon88 platform.

8Data Retention

millon88 retains personal data for the minimum period necessary to fulfil the purposes for which it was collected, subject to the following retention guidelines:

• Account and identity data: Retained for the duration of your active account plus a minimum of five (5) years following account closure, in compliance with PAGCOR licensing requirements and AMLA record-keeping obligations.
• Financial transaction records: Retained for a minimum of five (5) years in compliance with AMLA and PAGCOR reporting requirements.
• Customer support communications: Retained for three (3) years from the date of the last interaction, or longer where records are relevant to an ongoing dispute or investigation.
• Marketing consent records: Retained for the duration of your consent and for a further two (2) years following withdrawal of consent, to demonstrate compliance with the DPA.
• Technical and session data (logs): Retained for a maximum of twelve (12) months from the date of collection for security and fraud prevention purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in a manner that prevents re-identification.

9Data Security

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

• Industry-standard Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the millon88 servers.
• Encryption of sensitive data fields — including financial account identifiers and government ID numbers — at rest using AES-256 encryption.
• Role-based access controls ensuring that millon88 staff can only access player data to the extent required for their specific job function.
• Regular penetration testing and security audits conducted by independent third-party security specialists.
• Two-factor authentication (2FA) for player accounts and for all internal millon88 administrative systems.
• Documented incident response procedures, including notification protocols compliant with the National Privacy Commission's personal data breach notification requirements under NPC Circular 16-03.

10Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by millon88. To exercise any of these rights, contact us using the details in Section 14:

• Right to be informed: To be told what personal data we hold about you and how it is processed. This Privacy Policy fulfils that obligation.
• Right of access: To request and receive a copy of the personal data millon88 holds about you.
• Right to rectification: To request correction of inaccurate or incomplete personal data.
• Right to erasure: To request deletion of your personal data, subject to our legal retention obligations under PAGCOR and AMLA regulations.
• Right to data portability: To receive your personal data in a structured, commonly used, machine-readable format where technically feasible.
• Right to object: To object to processing of your personal data for direct marketing or where processing is based on legitimate interests.
• Right to lodge a complaint: To lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated.

millon88 will respond to all data subject rights requests within fifteen (15) business days of receipt. Where a request is complex or numerous, we may extend this period by a further thirty (30) days, with notification to you of the extension and the reason for it.

11Children's Privacy

The millon88 platform is strictly intended for adults aged 21 years and older in accordance with PAGCOR regulations. millon88 does not knowingly collect personal data from individuals under the age of 21. Registration by underage individuals is prohibited.

If millon88 becomes aware that personal data has been collected from an individual under 21 years of age, the relevant account will be immediately suspended, all associated personal data will be deleted, and any funds held in the account will be handled in accordance with PAGCOR guidance.

If you believe that millon88 has inadvertently collected data from an underage individual, please contact us immediately using the details in Section 14 so that we may take prompt corrective action.

12International Data Transfers

Some of millon88's third-party service providers — including game software providers and technical infrastructure partners — may be located outside the Philippines. Where personal data is transferred to recipients in countries that do not provide an equivalent level of data protection as Philippine law, millon88 ensures that appropriate safeguards are in place, which may include:

• Standard contractual clauses approved by or acceptable under the DPA framework.
• Binding corporate rules where applicable.
• The recipient country being recognized by the NPC as providing adequate data protection.

millon88 will not transfer your personal data to any jurisdiction or recipient that cannot demonstrate adequate protections for your data rights.

13Updates to This Privacy Policy

millon88 may update this Privacy Policy from time to time to reflect changes in our data practices, updates to Philippine data protection law or PAGCOR requirements, or improvements to our platform. When material changes are made, we will:

• Update the "Last updated" date at the top of this page.
• Notify active players via their registered email address and/or via a notice on the platform at login, at least seven (7) days before the changes take effect.

We encourage you to review this Privacy Policy periodically. Your continued use of the millon88 platform following any update to this Policy constitutes your acceptance of the revised terms.

14Contact Us & Complaints

millon88 has appointed a Data Protection Officer (DPO) to oversee compliance with this Privacy Policy and the Data Privacy Act of 2012. If you have any questions, concerns, or requests relating to this Policy or your personal data, please contact us:

• Live Chat: Available 24/7 on the millon88 platform — our support agents can assist with data requests and escalate to the DPO where required.
• Email: [email protected]

If you are not satisfied with millon88's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the competent supervisory authority for data protection matters in the Philippines.