milyun Privacy Policy

1 Scope & Application

This Privacy Policy applies to all personal data collected, processed, stored, and transferred by milyun in connection with the operation of its online gaming platform at milyun.cam. It covers all registered members, visitors who browse the platform without registering, and any individual who contacts milyun's customer support team.

This policy applies regardless of the device or method used to access the milyun platform — desktop browser, mobile browser, or any other means of accessing milyun.cam. The policy should be read alongside milyun's Terms & Conditions, available at milyun.cam/terms-conditions, which govern the overall use of the platform and are incorporated herein by reference.

milyun's privacy practices are designed to comply with the Data Privacy Act of 2012 of the Republic of the Philippines (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC). Where applicable international data protection standards intersect with milyun's operations, those standards are also considered in our data handling practices.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, milyun acts as the Personal Information Controller (PIC) with respect to personal data collected through the milyun.cam platform. As PIC, milyun determines the purposes and means by which personal data is processed.

Third-party service providers who process personal data on milyun's behalf — such as payment processors, KYC verification providers, and game software suppliers — act as Personal Information Processors (PIPs) and are contractually obligated to process data only in accordance with milyun's instructions and in compliance with applicable data protection law.

For all privacy-related inquiries, requests, and complaints, members may contact milyun's designated Data Protection Officer at the contact details provided in Section 15 of this policy.

3 Personal Data We Collect

milyun collects personal data across several categories depending on the nature of your interaction with the platform. The following table summarizes the main categories of data collected:

milyun collects only the personal data that is necessary for the purposes described in this policy. We do not collect sensitive personal information (as defined by the Data Privacy Act) unless required for legal compliance purposes, such as in the context of anti-money laundering or enhanced due diligence obligations.

4 How We Collect Your Data

milyun collects personal data through the following means:

• Direct collection: Information you provide when you register for an account, complete KYC verification, make deposits or withdrawal requests, participate in promotions, or contact our support team.
• Automated collection: Technical data collected automatically when you access the milyun platform, including through cookies, web beacons, server logs, and similar tracking technologies. See Section 8 for full details on cookies.
• Third-party sources: Identity and document verification data received from our KYC service providers; fraud screening data from our anti-fraud partners; payment verification data from payment processors including GCash, PayMaya, and Philippine banking partners.
• Publicly available sources: In limited circumstances where required for compliance purposes, milyun may verify information against publicly available databases including government records and adverse media sources.

5 How We Use Your Personal Data

milyun processes your personal data for the following purposes:

• Account management: Creating, maintaining, and managing your milyun account, including authentication, security controls, and account history;
• Service delivery: Providing access to games, processing deposits and withdrawals, crediting bonuses, and delivering all gaming services on the platform;
• Identity verification (KYC): Verifying your identity, age (confirming you are 21+), and eligibility to use the platform in compliance with PAGCOR-aligned regulations;
• Anti-money laundering (AML) compliance: Monitoring transactions and gaming activity for suspicious patterns, reporting obligations under Philippine anti-money laundering law, and enhanced due diligence where required;
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behavior and administering player protection tools including self-exclusion and limit controls;
• Customer support: Responding to your inquiries, resolving disputes, and maintaining records of communications;
• Marketing communications: Sending promotional offers, bonus notifications, and platform news — but only where you have opted in to receive such communications. You may unsubscribe at any time;
• Platform improvement: Analyzing usage patterns, technical performance, and user feedback to improve the milyun platform experience;
• Legal compliance: Fulfilling obligations under applicable Philippine law, including the Data Privacy Act, Anti-Money Laundering Act, and gaming regulations.

6 Legal Bases for Processing

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

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions you agreed to at registration — including account management, game delivery, and payment processing;
• Legal obligation: Processing required to comply with applicable Philippine law, including KYC obligations, AML reporting, and regulatory requirements under gaming law;
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your rights;
• Consent: Processing for marketing communications and optional analytics where you have given explicit, freely given, and specific consent. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

7 Data Sharing & Disclosure

milyun does not sell your personal data to third parties. We do not share your data with advertisers or data brokers. Personal data is shared only in the following limited circumstances:

• Service providers (Personal Information Processors): Third-party vendors engaged by milyun to provide platform infrastructure, KYC verification, payment processing (GCash, PayMaya, BPI, BDO, Metrobank), fraud detection, customer support tooling, and game delivery. All such providers are bound by data processing agreements requiring compliance with applicable data protection law;
• Regulatory authorities: Philippine government agencies including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement authorities where disclosure is required by law or valid legal process;
• Dispute resolution: Where a dispute is referred to a third-party mediator or court, relevant data may be disclosed to the extent necessary for resolution of that dispute;
• Business transfers: In the event of a merger, acquisition, or sale of milyun's business or assets, personal data may be transferred to the successor entity, subject to the same privacy protections set out in this policy. Affected members will be notified in advance of any such transfer.

8 Cookies & Tracking Technologies

milyun uses cookies and similar technologies on the milyun.cam platform. Cookies are small text files stored on your device by your browser when you visit a website. They serve several functions on our platform:

• Strictly necessary cookies: Required for the platform to function — including session authentication, login persistence (when "Remember Me" is selected), and security controls. These cannot be disabled without preventing core platform functionality;
• Functional cookies: Remember your preferences such as language settings and last-visited game category. Improve your experience on return visits;
• Analytics cookies: Collect aggregated, anonymized data about how the platform is used — page visit frequency, navigation patterns, and feature adoption. Used exclusively for platform improvement purposes;
• Security cookies: Support fraud detection and anti-abuse systems that protect all platform members.

milyun does not use advertising cookies or share cookie data with advertising networks. Most modern browsers allow you to manage cookie preferences through browser settings. Disabling strictly necessary cookies will affect your ability to log in and use the platform.

9 Data Retention

milyun retains personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law — whichever is longer. The following general retention periods apply:

• Active account data: Retained for the full duration of your account's active status plus a minimum of five (5) years after account closure, in compliance with Philippine anti-money laundering record-keeping requirements;
• KYC and identity documents: Retained for a minimum of five (5) years from the date of account closure or the last transaction, as required by the Anti-Money Laundering Act;
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction;
• Customer support communications: Retained for a minimum of two (2) years from the date of the last communication in a support thread;
• Technical and session logs: Retained for a minimum of one (1) year from the date of generation, or longer where required for security investigations.

After applicable retention periods expire, personal data is securely deleted or anonymized such that it can no longer be associated with any individual. Where anonymization is not technically feasible, data is securely destroyed in accordance with milyun's data disposal procedures.

10 Data Security

milyun implements technical and organizational security measures appropriate to the nature and sensitivity of the personal data we process. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the milyun platform;
• Encryption of sensitive data fields (including passwords and financial identifiers) at rest using industry-standard cryptographic protocols;
• Role-based access controls limiting staff access to personal data to only those with a legitimate operational need;
• Multi-factor authentication for all internal systems that access personal data;
• Regular security vulnerability assessments and penetration testing by independent security professionals;
• Data breach response procedures including NPC notification obligations under the Data Privacy Act, where a breach meets the threshold for mandatory reporting.

While milyun maintains robust security measures, no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. In the event of a personal data breach that is likely to result in a real risk of harm to affected members, milyun will notify those members and the National Privacy Commission in accordance with the timeframes prescribed by the Data Privacy Act.

11 Your Rights Under the Data Privacy Act

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by milyun:

• Right to be informed: The right to know what personal data milyun holds about you, how it is being used, and to whom it has been disclosed;
• Right of access: The right to request a copy of the personal data milyun holds about you, in a commonly used electronic format where technically feasible;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data held about you;
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to milyun's legal retention obligations;
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format, and to request that this data be transmitted to another controller where technically feasible;
• Right to object: The right to object to processing of your personal data for direct marketing purposes. This right is absolute — if you object to marketing processing, we will stop immediately;
• Right to damages: The right to claim compensation for any damages sustained due to inaccurate, incomplete, outdated, false, or unlawfully obtained personal data held by milyun.

To exercise any of these rights, contact milyun's Data Protection Officer using the contact details in Section 15. milyun will respond to all valid data subject requests within fifteen (15) calendar days of receipt, as required by the Data Privacy Act. Identity verification may be required before certain requests are actioned, to protect against unauthorized access to another person's data.

12 Children & Minors

The milyun platform is strictly restricted to individuals aged 21 years and above. milyun does not knowingly collect personal data from any person under 21 years of age. All accounts are subject to age verification through KYC procedures at registration.

If milyun becomes aware that personal data has been collected from a person under the age of 21 without verified parental or guardian consent, all such data will be promptly deleted and the associated account will be permanently closed. Any funds held in such an account will be handled in accordance with applicable regulatory requirements.

If you believe that a minor has accessed the milyun platform or that personal data of a minor has been inadvertently collected, please contact our Data Protection Officer immediately at the contact details in Section 15.

13 Cross-Border Data Transfers

Some of milyun's service providers and technical infrastructure partners may be located outside the Philippines. Where personal data is transferred to a jurisdiction outside the Philippines, milyun ensures that appropriate safeguards are in place to protect that data at a standard equivalent to that required by the Data Privacy Act of 2012.

Such safeguards include contractual clauses that bind recipient processors to data protection standards consistent with Philippine law, and — where applicable — ensuring transfers are made only to jurisdictions that the National Privacy Commission has recognized as providing an adequate level of protection.

Game software providers, whose platforms operate the actual game logic for games available on milyun, process certain gaming session data through their own systems. All such providers are contractually required to process this data only for the purpose of game delivery and statistical integrity, and are prohibited from using it for any other purpose.

14 Amendments to This Policy

milyun reserves the right to update or amend this Privacy Policy at any time. Where amendments are material — meaning they substantially affect how your personal data is collected, used, or shared — milyun will provide at least 14 days' advance notice by posting a prominent notice on the platform and, where practicable, notifying registered members via their registered email address or Philippine mobile number.

Your continued use of the milyun platform after the effective date of any revised Privacy Policy constitutes your acknowledgment of and agreement to the revised terms. The date of the most recent revision is always displayed at the top of this policy. The current version is always accessible at milyun.cam/privacy-policy.

Where an amendment requires fresh consent under the Data Privacy Act — for example, where milyun proposes to use your data for a new purpose not covered by this policy — milyun will seek that consent separately before processing your data for the new purpose.

15 Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact milyun's Data Protection Officer through the following channel:

• Data Protection & Privacy: [email protected] — subject line: "Privacy Request — [your registered email]"
• General Customer Support: [email protected]
• Support Hours: 8:00 AM – 2:00 AM PHT, 7 days a week
• Platform: milyun.cam

milyun will acknowledge all privacy-related requests within five (5) business days and will endeavor to fully respond within fifteen (15) calendar days as required under the Data Privacy Act. Complex requests requiring third-party involvement may take longer, in which case milyun will notify you of the expected timeline.

If you are not satisfied with milyun's response to your privacy complaint, you have the right to escalate your complaint to the National Privacy Commission of the Philippines. Details on the NPC complaints process are available through official Philippine government channels.