1. Our Approach
The Payment Card Industry Data Security Standard ("PCI DSS") is the global security standard for organizations that store, process, or transmit payment card data. Milli's architecture is designed to minimize the cardholder data that Milli touches, so that sensitive card data is handled only by PCI DSS validated partners.
2. Scope
- Milli Elite Card. Card numbers, expiration dates, and security codes for the Milli Elite Card are generated, stored, and processed by the issuing bank's card processor, which is validated as a PCI DSS Level 1 Service Provider. When you view your card details in the app, they are displayed through the processor's secure, tokenized interface and are not stored on Milli systems.
- Subscription payments. Subscription payments are processed by Apple, Google, or a PCI DSS Level 1 validated payment processor. Milli does not receive or store full card numbers or security codes.
- Milli systems. Milli stores only tokens, masked card numbers (last four digits), and transaction metadata.
3. Milli's PCI DSS Program: In Process
Milli's PCI DSS certification is in process. Milli does not currently hold a PCI DSS Attestation of Compliance. Because full cardholder data is handled by validated partners, Milli's compliance responsibility is limited to the controls applicable to its environment. Milli is completing the PCI DSS Self-Assessment Questionnaire appropriate to its integration and intends to obtain its Attestation of Compliance before the Milli Elite Card launches, along with any higher validation level required by its partners or the card networks.
4. How Card Data Is Protected
- Tokenization of card data and encryption in transit (TLS 1.2 or higher) and at rest (AES-256)
- Strict network segmentation between card-related services and other systems
- Least-privilege access, multi-factor authentication, and access logging
- Annual partner PCI DSS validation reviews, including Attestations of Compliance
- Quarterly vulnerability scans and annual penetration testing, as described in our Security Policy
5. Requesting Documentation
Financial institution partners may request Milli's partners' Attestations of Compliance, and Milli's own PCI DSS documentation once complete, at compliance@drivemilli.com.
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