Privacy Policy – million88

1. Who We Are

million88 ("million88," "we," "us," "our") operates the online casino and sports betting platform accessible at million88.biz (the "Platform"). million88 is the data controller responsible for the personal information you provide when registering, using, or otherwise interacting with the Platform. All data processing activities described in this Privacy Policy are carried out by million88 or by third-party processors engaged under appropriate data processing agreements in compliance with applicable Philippine data protection law, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations.

By creating a million88 account, accessing the Platform, or submitting any personal information to us, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

2. Personal Data We Collect

million88 collects the following categories of personal data from Players and Platform visitors:

million88 does not collect sensitive personal information (as defined under RA 10173) beyond what is strictly necessary for identity and age verification purposes. We do not collect racial or ethnic origin, religious beliefs, health data, or sexual orientation information from Players.

3. How We Collect Your Data

million88 collects personal data through the following means:

• Direct submission: Information you provide when registering a million88 account, completing KYC verification, making a deposit or withdrawal, contacting our support team, or participating in promotions;
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including via cookies, web beacons, and server logs;
• Third-party sources: Identity verification providers, payment processors (GCash, PayMaya, BPI, BDO), and fraud prevention services may share data with million88 as part of their service provision;
• Public sources: Publicly available information used to verify identity or detect fraud, in accordance with applicable law.

4. How We Use Your Personal Data

million88 processes your personal data for the following purposes:

• Creating and managing your million88 account, including verifying your identity and eligibility to use the Platform;
• Processing deposits and withdrawals in Philippine Peso via GCash, PayMaya, BPI, BDO, and other accepted payment methods;
• Providing customer support and responding to your enquiries, complaints, and requests;
• Administering bonuses, promotions, and loyalty rewards applicable to your account;
• Detecting and preventing fraud, money laundering, underage gambling, multi-accounting, and other prohibited conduct;
• Complying with anti-money laundering (AML), counter-terrorist financing (CTF), and other applicable legal and regulatory obligations;
• Enforcing responsible gaming obligations, including processing self-exclusion requests and monitoring for problem gambling indicators;
• Improving Platform performance, game offerings, and user experience through aggregated and anonymised analytics;
• Sending you service communications, including transaction confirmations, security alerts, and material policy updates;
• Sending you marketing communications where you have provided explicit consent, including information about new games, promotions, and features available on million88.

5. Legal Basis for Processing

million88 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform the agreement between you and million88, including account creation, payment processing, and game provision;
• Legal obligation: Processing required to comply with applicable laws, including AML/CTF requirements, age verification obligations, and regulatory reporting duties;
• Legitimate interests: Processing carried out for the legitimate interests of million88, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights;
• Consent: Processing carried out on the basis of your explicit consent, including marketing communications. You may withdraw consent at any time by contacting million88 support at [email protected].

6. Sharing Your Data

million88 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients only as necessary and under appropriate safeguards:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers processing your PHP transactions;
• Identity verification providers: Third-party KYC and AML screening services that assist million88 in verifying player identity and detecting prohibited conduct;
• Game software providers: Licensed game studios and live casino operators whose titles are hosted on the million88 Platform, to the extent necessary for game delivery and integrity;
• IT and infrastructure providers: Cloud hosting, cybersecurity, and technical support vendors engaged under data processing agreements;
• Regulatory and law enforcement authorities: Government agencies, including PAGCOR and the Anti-Money Laundering Council (AMLC), where disclosure is required by applicable law or regulatory order;
• Legal and professional advisers: Lawyers, auditors, and compliance consultants engaged in connection with million88's legal obligations or dispute resolution.

All third-party processors engaged by million88 are contractually bound to process personal data only on million88's instructions and in compliance with applicable data protection law.

7. International Data Transfers

Some of million88's third-party service providers operate outside the Philippines. Where personal data is transferred internationally, million88 ensures that appropriate safeguards are in place, including contractual data transfer agreements that provide an equivalent level of data protection to that required under Philippine law. By using the Platform, you consent to international transfers of your personal data where necessary for the provision of million88 services.

8. Data Retention

million88 retains personal data for as long as your account remains active and for a minimum of five (5) years following account closure, in accordance with Philippine AML/CTF record-keeping obligations. Gameplay logs and financial transaction records may be retained for longer periods where required by applicable regulatory requirements. Following the applicable retention period, personal data is securely deleted or anonymised.

9. Cookies and Tracking Technologies

9.1 What We Use

The million88 Platform uses cookies, local storage, and similar tracking technologies to enhance your experience and to collect technical data about Platform usage. Categories of cookies used include: (a) strictly necessary cookies required for Platform functionality; (b) performance cookies that collect anonymised analytics data; and (c) functional cookies that remember your preferences.

9.2 Managing Cookies

You may configure your browser settings to refuse or delete cookies at any time. However, disabling strictly necessary cookies may impair the functionality of the million88 Platform, including your ability to log in and complete transactions. million88 does not use third-party advertising cookies or cross-site tracking technologies for behavioural advertising purposes.

10. Your Data Protection Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by million88:

• Right to be informed: The right to be notified of how your personal data is collected, used, and processed, as set out in this Privacy Policy;
• Right of access: The right to request a copy of the personal data million88 holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to erasure: The right to request deletion of your personal data, subject to million88's legal and regulatory retention obligations;
• Right to data portability: The right to receive your personal data in a structured, commonly used format;
• Right to object: The right to object to processing based on legitimate interests, including direct marketing;
• Right to withdraw consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact million88 at [email protected]. We will respond to all verified requests within thirty (30) calendar days. million88 may require you to verify your identity before processing any data rights request.

11. Children's Privacy

The million88 Platform is strictly for users who are 21 years of age or older. million88 does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from an underage individual, we will immediately delete the relevant data and close the associated account. If you believe a minor has registered on the million88 Platform, please contact us immediately at [email protected].

12. Security Measures

million88 implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include: 256-bit SSL/TLS encryption for all data transmissions; encrypted storage of passwords and sensitive financial data; regular security audits and penetration testing; role-based access controls limiting employee access to personal data; and two-factor authentication (2FA) available for all Player accounts. While million88 takes all reasonable steps to secure your data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your million88 login credentials.

13. Changes to This Privacy Policy

million88 may update this Privacy Policy periodically to reflect changes in our data practices, legal obligations, or Platform features. Where changes are material, million88 will notify active account holders via the email address registered to their account. The date at the top of this page indicates when the Policy was last revised. Your continued use of the million88 Platform following any update constitutes acceptance of the revised Privacy Policy.

14. Contact and Complaints

For any privacy-related queries, data access requests, or complaints regarding million88's handling of your personal data, please contact us:

• Email: [email protected]
• Live Chat: Available 24/7 via the million88 Platform

If you are not satisfied with million88's response to a privacy complaint, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information about the NPC and its complaint process is available through official Philippine government channels.