BILLIONAIRE PRIVACY POLICY

Effective date: 10/23/2023
Last updated: 08/23/2026

This Privacy Policy explains how BILLIONAIRE collects, uses, stores, discloses, and protects personal data when you use our website, game servers, online store, Discord community, support channels, surveys, and related services (collectively, the "Services").

1. Who Controls Your Personal Data

The personal information controller responsible for the processing described in this Privacy Policy is:

BILLIONAIRE is an online-only business. The absence of a public-facing physical office does not affect our responsibility to process personal data lawfully and transparently. The address above is provided for privacy and legal communications.

If a third-party provider processes personal data for us, that provider acts only for the purposes and under the instructions applicable to the relevant service, subject to its own privacy obligations.

2. Scope

This Privacy Policy applies to personal data collected through:

  • billionaireark.com and related BILLIONAIRE webpages;
  • BILLIONAIRE game servers and connected services;
  • the BILLIONAIRE online store;
  • Discord and other community platforms;
  • support tickets, email, and live chat;
  • surveys and feedback forms; and
  • transactions involving subscriptions, digital items, credits, or other Services.

Third-party platforms, including Discord, Steam, Epic Games, console networks, hosting providers, payment processors, and analytics providers, may process data under their own privacy policies.

3. Personal Data We Collect

We collect only data that are adequate, relevant, necessary, and proportionate to a declared and legitimate purpose. (IRR of the Data Privacy Act of 2012 (2016))

Depending on how you use the Services, we may collect:

3.1 Account and platform data

  • username, display name, and account identifier;
  • Discord ID or similar platform identifier;
  • linked Steam, Epic Games, console, or other platform identifier;
  • account status, roles, permissions, and server membership; and
  • information needed to verify account ownership or deliver account-related benefits.

3.2 Contact data

  • email address;
  • messages and contact details included in support requests; and
  • other information you voluntarily provide for account, billing, or support purposes.

3.3 Transaction data

  • transaction ID;
  • payment date and amount;
  • product, subscription, or digital item purchased;
  • account connected with the transaction;
  • payment status, refund, reversal, or chargeback status; and
  • limited information supplied by the payment processor for reconciliation and dispute handling.

We do not intentionally collect or store complete payment-card numbers, card security codes, or full bank-account credentials. Payment processors handle payment credentials under their own security and privacy practices.

3.4 Gameplay, moderation, and communications data

  • game-server activity relevant to administration or support;
  • chat messages, reports, trade records, and transaction records;
  • account actions, warnings, suspensions, and bans;
  • logs concerning cheating, exploitation, abuse, fraud, or security incidents; and
  • communications with staff and support personnel.

3.5 Technical and usage data

  • IP address;
  • device, browser, and operating-system information;
  • connection, access, and error logs;
  • cookie and similar technology data;
  • pages viewed, forms submitted, downloads, and general interaction data; and
  • security information generated by hosting, content-delivery, or protection services.

We do not intentionally collect sensitive personal information unless it is necessary, legally permitted, and processed under an appropriate legal basis.

4. Purposes of Processing

We process personal data for the following specific purposes:

  • creating, maintaining, and securing accounts;
  • linking accounts and verifying eligibility for Services or Digital Items;
  • processing subscriptions, purchases, refunds, reversals, and payment disputes;
  • delivering digital content, roles, credits, tokens, or other account benefits;
  • providing customer support and responding to inquiries;
  • administering game servers and community platforms;
  • enforcing game rules and community standards;
  • investigating suspected cheating, exploitation, fraud, abuse, or security incidents;
  • maintaining server performance, stability, and security;
  • diagnosing technical problems and preventing unauthorized access;
  • conducting surveys and using feedback to improve the Services;
  • producing aggregated or de-identified analytics where reasonably possible;
  • sending service-related communications;
  • sending promotional communications where permitted and where you have not opted out;
  • complying with legal obligations and responding to lawful government or regulatory requests; and
  • establishing, exercising, or defending legal claims.

We do not use personal data for unrelated purposes without providing appropriate notice and, where required, obtaining consent.

5. Legal Bases for Processing

Depending on the processing activity, we may rely on one or more of the following legal bases:

  • your consent, when consent is required;
  • processing necessary to perform a contract with you or take steps at your request before entering into a contract;
  • compliance with a legal obligation;
  • protection of vital interests;
  • performance of a public-authority function, where applicable; and
  • our legitimate interests, provided those interests are not overridden by your fundamental rights and freedoms.

The IRR recognizes contractual necessity and legitimate interests as possible bases for lawful processing, subject to their applicable requirements. (IRR of the Data Privacy Act of 2012 (2016); Zoleta v. Investigating Staff, et al. (2024))

Where consent is used, it must be freely given, specific, informed, evidenced, and capable of being withdrawn. Acceptance of this Privacy Policy does not constitute blanket consent to every possible use of personal data. (NPC Circular No. 2023-04, Guidelines on Consent (2023))

6. Cookies and Similar Technologies

We may use cookies, session technologies, server logs, Cloudflare services, and analytics tools to:

  • keep the website and Services secure;
  • maintain sessions and necessary functionality;
  • measure website performance;
  • understand general usage patterns;
  • detect errors and abuse; and
  • improve website design and service delivery.

Where a technology is not necessary for the requested Service, we will provide appropriate notice and, where required, request consent before using it.

You may control cookies through your browser or available website settings. Disabling necessary cookies may affect website functionality.

7. Disclosure and Data Sharing

We may disclose personal data only when reasonably necessary for a declared purpose and under an appropriate legal basis.

Recipients may include:

  • payment processors and payment-risk providers;
  • hosting, server, storage, cybersecurity, and content-delivery providers;
  • customer-support and communications providers;
  • survey, form, and analytics providers;
  • Discord, Steam, Epic Games, console networks, and other platforms you choose to link;
  • professional advisers or service providers assisting with legal, accounting, security, or operational matters;
  • courts, regulators, law-enforcement agencies, or other public authorities when legally required or authorized; and
  • parties involved in a lawful business transfer, provided appropriate safeguards apply.

We do not sell personal data. We do not disclose personal data for unrelated advertising purposes merely because it was provided through a publicly accessible platform. Public availability does not amount to blanket consent for any use. (NPC Circular No. 2023-04, Guidelines on Consent (2023))

8. International Processing

Our service providers may process or store personal data outside the Philippines. Before using a provider, we take reasonable steps to identify the relevant provider, purpose, categories of data, and applicable security and contractual safeguards.

International processing does not authorize unlimited disclosure. It remains subject to the principles of transparency, legitimate purpose, and proportionality. (IRR of the Data Privacy Act of 2012 (2016))

9. Retention

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected, compliance with legal obligations, security, dispute resolution, or the establishment, exercise, or defense of legal claims.

Our general retention periods are:

Category General retention period
Account and platform data While the account remains active, plus 1 year after closure
Support communications 1 year after the matter is closed
Transaction and subscription records 5 years after the transaction or as required by law
Chargeback, fraud, and security records For the period reasonably necessary to investigate, resolve, and defend the matter, up to 2 years after resolution
Gameplay and moderation logs 6 months, subject to extension for an active investigation or dispute
Survey responses Until 1 year after collection, or until reasonably anonymized
Technical and security logs 90 days, subject to security and operational requirements

When retention is no longer necessary, we will delete, anonymize, or securely dispose of the data, subject to lawful exceptions.

10. Security Measures

We use reasonable organizational, physical, and technical safeguards appropriate to the nature and risks of the personal data processed. These may include:

  • access controls based on need;
  • password and account-security measures;
  • encryption in transit and, where appropriate, at rest;
  • secure configuration of hosting and server systems;
  • logging and monitoring for security events;
  • restricted access to support and moderation records;
  • provider due diligence and contractual controls where appropriate; and
  • secure deletion or anonymization when retention is no longer necessary.

No internet transmission or storage system is completely secure. We will investigate suspected security incidents and take measures required by applicable law.

11. Personal Data Breaches

If a personal-data breach occurs, we will assess it promptly, contain and investigate the incident, document the response, and notify the National Privacy Commission and affected data subjects when notification is required by law or applicable NPC rules.

The IRR requires compliance with breach-notification and related reporting obligations, including the applicable 72-hour notification requirement. (IRR of the Data Privacy Act of 2012 (2016))

12. Your Rights

Subject to applicable law and reasonable verification of identity, you may have the right to:

  • be informed whether your personal data are being processed;
  • access personal data concerning you;
  • request correction of inaccurate or incomplete data;
  • request deletion or blocking where legally permitted;
  • object to processing in appropriate circumstances;
  • withdraw consent where processing is based on consent;
  • request data portability where applicable;
  • contest or request review of certain automated processing decisions; and
  • lodge a complaint with the National Privacy Commission.

The right to deletion is not absolute. We may retain data where necessary for legal compliance, security, accounting, dispute resolution, or the establishment, exercise, or defense of legal claims.

The right to be informed includes information about the data collected, processing purposes, processing basis, recipients, retention, the identity and contact details of the controller, and applicable automated processing. (IRR of the Data Privacy Act of 2012 (2016))

13. How to Exercise Your Rights

Submit a request to:

Please identify the account or transaction concerned and describe the request. We may request reasonable information to verify identity and prevent unauthorized disclosure.

We will acknowledge and assess the request within a reasonable period and respond within the period required by applicable law. If we cannot grant the request, we will explain the reason to the extent legally permitted.

14. Automated Processing and Profiling

We may use automated tools for security, spam detection, fraud prevention, technical monitoring, or rule-enforcement support.

We will not rely solely on automated processing to make a decision that produces legal effects or similarly significant effects on you unless the processing is legally permitted and the required safeguards, information, and consent are provided.

If automated processing or profiling becomes relevant to a significant decision, we will provide the information required by applicable law, including the nature and consequences of the processing. (NPC Circular No. 2023-04, Guidelines on Consent (2023))

15. Children

The Services are not directed to children below 13 years old, or the higher minimum age required in the relevant jurisdiction.

We do not knowingly collect personal data from a child in violation of applicable law. If a parent or guardian believes that a child provided personal data unlawfully, contact us at [email protected].

16. Marketing and Communications

We may send communications necessary to operate the account or Services, including transaction confirmations, security notices, support responses, subscription notices, and material service updates.

You may opt out of promotional communications by using the unsubscribe mechanism in the message or contacting [email protected]. Opting out of promotional messages will not stop essential service or transaction communications.

17. Third-Party Services

Third-party platforms and providers may independently collect and process personal data. Their processing is governed by their own policies, not solely by this Privacy Policy.

You should review the privacy policies of platforms you link to the Services, including Discord, Steam, Epic Games, console networks, payment processors, hosting providers, Cloudflare, survey providers, and analytics providers.

18. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in the Services, processing activities, security practices, or legal requirements.

For material changes, we will provide reasonable notice through the website, email, account, or another appropriate channel. If the change requires consent, we will obtain consent in the manner required by law.

The updated policy will state its effective date. We will retain prior versions when reasonably necessary to demonstrate the policy applicable at the time of processing.

19. Contact Us

For privacy questions, access requests, correction requests, deletion requests, complaints, or security concerns: