Privacy Policy

This Privacy Policy (hereinafter — "Policy") describes how Millennium service (hereinafter — "Service", "we", "our") collects, uses, stores, protects, and discloses personal data of users (hereinafter — "User", "you", "your").

We take your privacy seriously and are committed to processing your personal data in accordance with applicable laws, including:

• GDPR — General Data Protection Regulation (EU) 2016/679
• CCPA — California Consumer Privacy Act
• LGPD — Brazilian General Data Protection Law
• Other applicable data protection laws

By using the Service, you confirm that you have read and understood this Policy. If you do not agree with any terms, please do not use the Service.

The controller (operator) of your personal data is:

For all questions related to personal data processing, you can contact our Data Protection Officer (DPO).

3.1. Data you provide directly:

3.2. Data collected automatically:

3.3. Data from third-party sources:

• OAuth providers (Google, Apple, Discord, Telegram): basic profile (email, name, avatar)
• TON Connect: wallet address when connecting for payment
• Payment providers: transaction status, payment ID

We process your personal data for the following purposes:

Under GDPR, we process data on the following legal bases:

• Consent (Article 6(1)(a)): You give explicit consent during registration and for certain types of processing (e.g., marketing).
• Contract performance (Article 6(1)(b)): Processing is necessary to provide the services you ordered.
• Legitimate interest (Article 6(1)(f)): Processing is necessary for our legitimate interests (security, service improvement), provided it doesn't override your rights.
• Legal obligation (Article 6(1)(c)): Processing is necessary to comply with applicable law.

We retain your data no longer than necessary for processing purposes:

After the retention period expires, data is irreversibly deleted or anonymized.

We implement comprehensive technical and organizational measures to protect your data:

In case of a data breach, we will notify you and relevant supervisory authorities within 72 hours in accordance with GDPR.

We may share your data with the following categories of recipients:

Legal disclosure: We may disclose data to government authorities upon lawful request (court order, subpoena).

Your data may be processed on servers located outside your country, including countries that do not provide an adequate level of protection according to the EU.

For such transfers, we ensure appropriate safeguards:

• Standard Contractual Clauses (SCC) — approved by the European Commission
• Adequacy decisions — for countries with recognized protection levels
• Binding Corporate Rules (BCR) — for intra-group transfers
• Additional technical measures — encryption, pseudonymization

You can request a copy of applicable safeguards by contacting our DPO.

We use cookies and similar technologies to ensure Service operation:

Cookie management: You can manage cookies through browser settings or our cookie management center. Disabling some cookies may limit Service functionality.

The Service is intended for persons who have reached 18 years of age(or the age of majority in your jurisdiction).

We do not knowingly collect personal data from children. If you learn that a minor has provided us with data, please contact us immediately at privacy@millennium.ai for deletion.

We may periodically update this Policy. We will notify you of significant changes:

• By email (if you are subscribed)
• Through a notification in the Service interface
• By publishing the updated version on the website

Continued use of the Service after changes take effect constitutes your agreement to the updated Policy.