Privacy Policy

1. Introduction

million99 ("we," "us," or "our") is committed to protecting the privacy and personal data of all players and visitors who use the million99 Platform. This Privacy Policy describes how we collect, use, disclose, and safeguard your information in connection with your use of our online casino and sports betting services at million99.asia.

This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC). It also reflects our obligations under PAGCOR's data governance guidelines.

We encourage you to read this Policy carefully. If you have questions about how we handle your personal data, please contact our Data Protection Officer (DPO) using the details provided in Section 12.

2. Data We Collect

When you register and use million99, we collect the following categories of personal data:

We do not collect sensitive personal information (such as racial or ethnic origin, political opinions, or health data) unless specifically required for responsible gaming assessments or legal compliance purposes, and only with your explicit consent.

3. How We Use Your Data

million99 uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your million99 account, including identity verification and age confirmation (21+ requirement).
• Service Delivery: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and UnionBank; to provide access to games and betting services.
• Legal & Regulatory Compliance: To comply with PAGCOR regulations, anti-money laundering (AML) obligations, and the Philippine Data Privacy Act.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Responsible Gaming: To monitor gaming patterns and identify players who may need responsible gaming support or intervention.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the million99 Platform's features and performance.
• Marketing Communications: To send you promotional offers, bonuses, and updates — only where you have opted in to receive such communications.

We will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or as otherwise permitted by law.

4. Legal Basis for Processing

Under the Philippine Data Privacy Act, million99 processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you — i.e., to provide the million99 gaming and betting services you have registered for.
• Legal Obligation: Processing is required to comply with applicable laws, including PAGCOR regulations, AML laws, and tax reporting obligations.
• Legitimate Interests: Processing is necessary for our legitimate interests, such as fraud prevention, platform security, and improving our services, provided these interests are not overridden by your rights.
• Consent: For marketing communications and certain non-essential cookies, we rely on your explicit consent, which you may withdraw at any time.

5. Data Sharing & Disclosure

million99 does not sell or rent your personal data to third parties. We may share your data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and UnionBank, to process your financial transactions.
• Identity Verification Providers: Third-party KYC service providers who assist with age and identity verification.
• Game Providers: Licensed game studios (such as Jili, Pragmatic Play, and CQ9) may receive limited technical data necessary to deliver their games on the Platform.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies, where required by law.
• Law Enforcement: Where we are legally required to disclose information in response to a valid court order, subpoena, or law enforcement request.
• IT & Security Service Providers: Trusted technology partners who assist with platform hosting, security monitoring, and technical operations, under strict data processing agreements.

6. Data Retention

million99 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. Our general retention periods are as follows:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with PAGCOR and AML 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.
• Support Communications: Retained for two (2) years from the date of the last interaction.
• Technical & Usage Logs: Retained for up to twelve (12) months for security and fraud prevention purposes.
• Marketing Consent Records: Retained for the duration of your consent and for one (1) year after withdrawal of consent.

When personal data is no longer required, million99 will securely delete or anonymize it in accordance with our data disposal procedures.

7. Cookies & Tracking Technologies

million99 uses cookies and similar tracking technologies to enhance your experience on the Platform. A cookie is a small text file placed on your device when you visit our website. We use the following types of cookies:

• Essential Cookies: Required for the Platform to function correctly. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled.
• Performance Cookies: Help us understand how players use the Platform by collecting anonymous usage statistics. This data is used to improve Platform performance and user experience.
• Functional Cookies: Remember your preferences, such as language settings and display options, so you do not need to re-enter them on each visit.
• Analytics Cookies: Allow us to analyze traffic patterns and player behavior on the Platform to improve our services and content.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the million99 Platform. Continued use of the Platform after being informed of our cookie use constitutes your consent to the use of essential and functional cookies.

8. Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by million99:

• Right to Be Informed: You have the right to know what personal data million99 collects about you and how it is used — which is the purpose of this Privacy Policy.
• Right to Access: You may request a copy of the personal data we hold about you at any time by contacting our Data Protection Officer.
• Right to Correction: If any of your personal data is inaccurate or incomplete, you have the right to request that we correct it promptly.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests.
• Right to Data Portability: You may request that we provide your personal data in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: If you believe your data rights have been violated, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of these rights, please contact our Data Protection Officer at the details provided in Section 12. We will respond to all verified requests within thirty (30) days, as required by the Data Privacy Act.

9. Data Security

million99 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-Bit SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted using industry-standard SSL/TLS protocols.
• Firewalls & Intrusion Detection: Our servers are protected by enterprise-grade firewalls and real-time intrusion detection systems.
• Access Controls: Access to personal data is restricted to authorized personnel only, on a strict need-to-know basis. All staff with data access undergo regular privacy and security training.
• Two-Factor Authentication (OTP): million99 supports OTP-based two-factor authentication to protect player accounts from unauthorized access.
• Regular Security Audits: We conduct periodic security assessments and vulnerability testing to identify and address potential risks to our systems.
• Data Breach Response: In the event of a personal data breach, million99 will notify affected players and the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, as required by law.

While we take all reasonable steps to protect your data, no method of electronic transmission or storage is 100% secure. We encourage you to use a strong, unique password for your million99 account and to enable two-factor authentication for additional protection.

10. Children's Privacy

The million99 Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. We do not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you are a parent or guardian and believe that your child has registered on million99, please contact our support team immediately at [email protected].

million99 employs age verification procedures during registration to prevent underage access. We take our responsibility to protect minors seriously and cooperate fully with PAGCOR's guidelines on this matter.

11. Updates to This Privacy Policy

million99 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or Platform features. When we make changes, we will update the "Last Updated" date at the top of this page.

For material changes that significantly affect how we handle your personal data, we will make reasonable efforts to notify registered players via email or in-platform notification prior to the changes taking effect. Your continued use of the million99 Platform after any changes are posted constitutes your acceptance of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how million99 protects your personal information.

12. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact the million99 Data Protection Officer (DPO):

For complaints that remain unresolved after contacting our DPO, you may escalate your concern to the National Privacy Commission of the Philippines at privacy.gov.ph.