Privacy Policy

1.Introduction

hotph ("hotph," "we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses our online casino and sports betting platform at hotph.net (the "Platform"). This Privacy Policy ("Policy") describes how hotph collects, uses, stores, shares, and protects your personal information when you access or use the Platform, create an account, make a deposit, participate in games, or contact our support team.

This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines. By using the hotph Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

This Policy should be read together with our Terms & Conditions, which govern your use of the Platform. Capitalized terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

2.Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, the data controller responsible for your personal information is:

• Entity: hotph
• Platform: hotph.net
• Contact: [email protected]

If you have any questions or concerns about how hotph handles your personal data, or if you wish to exercise any of your data subject rights, please contact our Data Protection Officer (DPO) at the email address above.

3.Data We Collect

hotph collects the following categories of personal data from players and visitors to the Platform:

Category	Examples	Purpose
Identity Data	Full name, date of birth, government-issued ID number, nationality	Account registration, KYC verification, age verification
Contact Data	Philippine mobile number, email address, residential address	Account communication, OTP delivery, support
Financial Data	GCash number, PayMaya account, bank account details (BPI, BDO, Metrobank, UnionBank), transaction history	Deposit and withdrawal processing, fraud prevention
Technical Data	IP address, device type, browser type, operating system, session tokens	Platform security, fraud detection, service optimization
Usage Data	Games played, bet amounts, session duration, login timestamps, pages visited	Responsible gaming monitoring, personalization, analytics
Communications Data	Support chat transcripts, email correspondence, feedback submissions	Customer support, dispute resolution, service improvement
Verification Documents	Scanned copies of government IDs, proof of address, selfie photos	KYC compliance, anti-money laundering obligations

hotph does not intentionally collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. We do not collect information about your religious beliefs, political opinions, or health status unless you voluntarily provide such information in the context of a responsible gaming self-assessment.

4.How We Collect Your Data

hotph collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud screening data from payment processors; publicly available information used for compliance screening.
• Payment providers: Transaction confirmation data from GCash, PayMaya, BPI, BDO, Metrobank, and UnionBank when you make deposits or request withdrawals.

5.How We Use Your Data

hotph uses your personal data for the following purposes:

• Account management: Creating and maintaining your hotph account, verifying your identity and age (21+ requirement), and managing your PHP wallet.
• Service delivery: Processing deposits and withdrawals, enabling gameplay, delivering bonuses and promotions, and providing customer support.
• Legal and regulatory compliance: Meeting our obligations under Philippine gaming regulations, anti-money laun dering laws, KYC requirements, and NPC regulations.
• Fraud prevention and security: Detecting and preventing fraudulent activity, unauthorized account access, money laundering, and abuse of promotions.
• Responsible gaming: Monitoring gameplay patterns to identify problem gambling indicators, enforcing deposit limits and self-exclusion requests, and sending responsible gaming reminders.
• Platform improvement: Analyzing usage data to improve game offerings, website performance, and the overall player experience.
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications. You may opt out at any time.

6.Legal Basis for Processing

hotph processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you — i.e., to operate your account, process transactions, and deliver gaming services.
• Legal obligation: Processing required to comply with applicable Philippine laws, including anti-money laundering regulations, gaming regulations, and NPC requirements.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and optional analytics features, where you have given explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7.Data Sharing & Disclosure

7.1 Service Providers. hotph shares personal data with trusted third-party service providers who assist in operating the Platform, including KYC verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank, UnionBank), cloud hosting providers, fraud detection services, and customer support platforms. All service providers are contractually bound to process your data only on hotph's instructions and to maintain appropriate security standards.

7.2 Regulatory Authorities. hotph may disclose personal data to Philippine regulatory authorities, law enforcement agencies, or courts where required by applicable law, court order, or regulatory directive. This includes disclosures required under the Anti-Money Laundering Act (AMLA) and its amendments.

7.3 Business Transfers. In the event of a merger, acquisition, or sale of all or substantially all of hotph's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

7.4 No Sale of Data. hotph does not sell, rent, lease, or trade your personal information to third-party marketers or data brokers under any circumstances.

8.Cookies & Tracking Technologies

hotph uses cookies and similar tracking technologies to enhance your experience on the Platform. The types of cookies we use include:

• Essential cookies: Required for the Platform to function correctly, including session management, login authentication, and security features. These cannot be disabled.
• Analytics cookies: Used to collect aggregated, anonymized data about how players use the Platform, helping us identify areas for improvement.
• Preference cookies: Used to remember your settings and preferences, such as language selection and display options.
• Marketing cookies: Used to deliver relevant promotional content to players who have opted in to marketing communications. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling essential cookies may affect the functionality of the Platform. For more information on managing cookies in popular Philippine browsers and devices, refer to your browser's help documentation.

9.Data Retention

hotph retains your personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following retention periods:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with Philippine anti-money laundering record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction.
• KYC documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Support communications: Retained for two (2) years from the date of the last communication, unless a longer period is required for dispute resolution.
• Marketing data: Retained until you withdraw consent or request deletion, whichever is earlier.

Upon expiry of the applicable retention period, hotph will securely delete or anonymize your personal data in accordance with its data disposal procedures.

10.Data Security

hotph 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 for all data transmitted between your device and the hotph Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Multi-factor authentication (MFA) options for player accounts.
• Regular security audits and penetration testing conducted by independent security professionals.
• Strict access controls limiting employee access to personal data on a need-to-know basis.
• Incident response procedures for detecting, reporting, and responding to personal data breaches in accordance with NPC notification requirements.

While hotph takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, hotph will notify you and the National Privacy Commission in accordance with applicable requirements.

11.Your Data Subject Rights

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

• Right to be informed: The right to be notified of how your personal data is being collected and processed — which this Policy fulfills.
• Right of access: The right to request a copy of the personal data hotph holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to hotph's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used format and to transmit it to another controller where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated.

To exercise any of these rights, please submit a written request to [email protected]. hotph will respond to your request within fifteen (15) business days. We may require you to verify your identity before processing your request.

12.Children's Privacy

The hotph Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. hotph does not knowingly collect personal data from individuals under the age of 21. If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete such data and close the associated account.

If you are a parent or guardian and believe that a minor has registered on the hotph Platform, please contact us immediately at [email protected].

13.Cross-Border Data Transfers

hotph primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to and processed in other countries — for example, where hotph uses cloud infrastructure or third-party service providers with operations outside the Philippines.

Where such transfers occur, hotph ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that require the recipient to maintain data protection standards equivalent to those required under Philippine law. By using the Platform, you consent to such transfers where they are necessary for the delivery of hotph's services.

14.Third-Party Links

The hotph Platform may contain links to third-party websites or services. This Privacy Policy applies solely to the hotph Platform and does not cover the privacy practices of any third-party websites. hotph is not responsible for the content or privacy practices of external sites. We encourage you to review the privacy policies of any third-party sites you visit.

15.Policy Updates

hotph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, hotph will notify registered players via the email address or mobile number associated with their account and will update the "Last Updated" date at the top of this page.

Your continued use of the Platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree to the updated Policy, you must cease using the Platform and may request account closure in accordance with the Terms & Conditions.

16.Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or hotph's data processing practices, please contact our Data Protection Officer:

• Email: [email protected]
• Response Time: Within 15 business days
• Support Hours: 24/7, in English and Filipino

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have not been adequately addressed by hotph.