hotph Privacy Policy

1. Introduction

hotph ("we", "us", "our") operates the online casino and sports betting platform accessible at hotph.club. We are licensed and regulated by the Philippine Amusement and Gaming Corporation (PAGCOR). In the course of providing our services to registered players throughout the Philippines — from Metro Manila to Cebu, Davao, and beyond — we collect and process certain personal data.

This Privacy Policy describes our practices with respect to the collection, use, storage, disclosure, and protection of your personal data. It applies to all interactions with the hotph Platform, including account registration, gameplay, deposits and withdrawals, customer support, and promotional communications.

By registering an account on hotph or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not consent, you should not register for or continue to use the hotph Platform.

This Policy is intended to comply with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, the issuances of the National Privacy Commission (NPC), and applicable PAGCOR data governance requirements.

2. Data We Collect

hotph collects personal data through multiple touchpoints on the Platform. The categories of data collected include:

2.1 Identity and Contact Data

• Full legal name as it appears on a government-issued Philippine identification document;
• Date of birth (for mandatory age verification — players must be 21 or older);
• Residential address in the Philippines;
• Philippine mobile number;
• Email address;
• Government-issued ID type, number, and document images (for KYC verification as required by PAGCOR).

2.2 Financial Data

• GCash account number or mobile wallet identifiers linked to your hotph account;
• Bank account details (BPI, BDO, Metrobank, or other Philippine bank) where used for deposits or withdrawals;
• Payment card details (partial — hotph does not store full card numbers; processing is handled by PCI-DSS compliant payment processors);
• Transaction history: deposit amounts, withdrawal amounts, dates, and payment method used.

2.3 Gaming and Behavioral Data

• Game session data: games played, bet amounts, game outcomes, session duration;
• Sports betting activity: events wagered on, bet types, odds, and outcomes;
• Bonus and promotion redemption history;
• Responsible gaming tool usage: deposit limits set, self-exclusion requests, cool-off periods.

2.4 Technical Data

• IP address at time of login and during sessions;
• Device type, operating system, and browser information;
• Geolocation data (at country and region level, where permitted);
• Session logs, access timestamps, and Platform interaction data.

2.5 Communications Data

• Records of customer support interactions via live chat or email, including the content of messages;
• Responses to surveys or promotional communications where you choose to participate.

3. How We Use Your Data

hotph uses the personal data we collect for the following purposes:

hotph does not use your personal data for automated decision-making that produces legal or similarly significant effects on you, except in limited fraud prevention contexts where such decisions may result in temporary account restrictions pending human review.

4. Legal Basis for Processing

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

• Contractual necessity: Processing required to provide the services described in our Terms & Conditions — including account management, payment processing, and game delivery — is necessary to fulfil our contract with you as a registered Player;
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including the Anti-Money Laundering Act, PAGCOR licensing conditions, the Tax Code, and NPC issuances;
• Legitimate interests: Processing for fraud prevention, platform security, abuse detection, and the improvement of our services, where such processing does not override your fundamental rights and freedoms;
• Consent: Where processing is not otherwise covered by the above bases — for example, for marketing communications or the use of non-essential cookies — hotph relies on your explicit consent, which may be withdrawn at any time.

5. Data Sharing and Disclosure

hotph does not sell your personal data to any third party. We share your personal data only in the following circumstances and only to the extent necessary for the specified purpose:

5.1 Regulatory Authorities

hotph is legally obligated to share data with PAGCOR in connection with our gaming license, and with the Anti-Money Laundering Council (AMLC) where transactions or activity triggers statutory reporting requirements under Philippine AML law. Such sharing is mandatory and cannot be restricted by your consent preferences.

5.2 Payment Processors

Processing GCash, Maya, bank transfer, and card transactions requires sharing necessary financial and identity data with the relevant payment service providers. All payment processors engaged by hotph are required to maintain security and confidentiality standards consistent with Philippine data protection law and, where applicable, PCI-DSS standards.

5.3 Identity Verification Service Providers

hotph engages third-party KYC verification providers to validate identity documents and perform age verification checks. These providers process identity data solely on hotph's behalf and under strict data processing agreements.

5.4 Technology and Infrastructure Providers

Game platform providers, cloud hosting services, and IT infrastructure vendors may process certain technical and gaming data in the course of providing their services to hotph. All such providers are bound by data processing agreements that restrict use of your data to the provision of services to hotph only.

5.5 Legal Proceedings

hotph may disclose personal data where required by law, court order, or in connection with legal proceedings involving hotph or a Player.

6. Cookies and Tracking Technologies

hotph uses cookies and similar tracking technologies on the Platform. Cookies are small data files stored on your device that help the Platform function correctly and allow us to understand how you use the site.

6.1 Types of Cookies

• Strictly necessary cookies: Required for the Platform to function — including session authentication, security tokens, and cashier functionality. These cannot be disabled without breaking Platform functionality;
• Performance and analytics cookies: Used to understand how players use the Platform so that we can improve it. Data collected is aggregated and does not identify individuals;
• Functional cookies: Remember your preferences such as language settings and game lobby layout;
• Marketing cookies: Used only where you have given explicit consent to receive targeted promotional content based on your gaming activity on the Platform.

You may manage your cookie preferences through your browser settings. Disabling strictly necessary cookies will affect the functionality of the Platform. Note that disabling all cookies may prevent you from logging in to your hotph account.

7. Data Retention

hotph retains your personal data for as long as necessary to fulfil the purposes described in this Privacy Policy, subject to the following minimum retention periods required by Philippine law:

• Account and KYC records: Retained for a minimum of five (5) years following account closure, as required by PAGCOR licensing conditions and the Anti-Money Laundering Act;
• Transaction records: Retained for a minimum of five (5) years as required by AML regulations and applicable tax law;
• Gaming activity logs: Retained for a minimum of three (3) years for regulatory audit and dispute resolution purposes;
• Customer support communications: Retained for a minimum of two (2) years or until any related dispute or legal matter is resolved, whichever is later.

Following the expiry of applicable retention periods, personal data is securely deleted or anonymised in accordance with NPC-recognised disposal standards.

8. Data Security

hotph implements technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the hotph Platform;
• Encryption at rest for stored personal and financial data;
• Access controls restricting data access to authorized hotph personnel on a need-to-know basis;
• Regular security assessments and penetration testing of the Platform;
• Two-factor authentication options available to all registered Players for account access;
• Incident response procedures compliant with the NPC's 72-hour breach notification requirement.

No system can guarantee absolute security. In the event of a personal data breach that is likely to result in serious harm to affected Players, hotph will notify the NPC and affected individuals within the timeframes prescribed by the Data Privacy Act and NPC regulations.

9. Your Data Rights

As a data subject 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 told what personal data we collect about you and how it is used — which this Privacy Policy fulfils;
• Right of Access: The right to request a copy of the personal data hotph holds about you;
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected — you can update most account information directly in your account settings, or contact support for KYC-related corrections;
• Right to Erasure: The right to request deletion of your personal data, subject to legal retention obligations (such as AML and PAGCOR requirements that may require us to retain certain data regardless of your request);
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format where technically feasible;
• Right to Object: The right to object to processing based on legitimate interests, or to withdraw consent for consent-based processing such as marketing communications at any time;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe hotph has violated your data privacy rights.

To exercise any of the rights above, contact hotph's Data Protection Officer using the details in Section 12. hotph will respond to data rights requests within the timeframes required by NPC regulations — generally within fifteen (15) business days of receipt of a complete and verifiable request.

10. Children's Privacy

hotph is strictly prohibited from accepting players under the age of 21 under PAGCOR licensing conditions and Philippine gambling law. The Platform is not directed at, nor intended for use by, any individual under 21 years of age.

hotph does not knowingly collect or process personal data belonging to individuals under 21. Age verification is a mandatory component of the hotph registration process — all accounts require submission of a valid government-issued Philippine ID confirming the holder is 21 or older before real-money gaming access is granted.

If hotph becomes aware that personal data has been collected from an individual under 21, the relevant account will be immediately suspended, the data will be securely deleted to the extent permitted by law, and the matter will be reported to PAGCOR as required by our licensing conditions.

11. Changes to This Privacy Policy

hotph may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal requirements, or PAGCOR regulatory obligations. Material changes — meaning changes that significantly affect how we collect, use, or share your personal data — will be communicated to registered Players via the email address or mobile number on their account prior to taking effect.

Minor or administrative changes may be made without individual notification, and the updated Policy will be published on this page with a revised "Last Updated" date. Your continued use of the hotph Platform following the publication of a revised Privacy Policy constitutes your acknowledgement of and agreement to the updated terms.

12. Contact Us & Data Protection Officer

hotph has designated a Data Protection Officer (DPO) as required under the Philippine Data Privacy Act and NPC regulations. For all privacy-related queries, data rights requests, or concerns regarding hotph's handling of your personal data, you may contact us through the following:

Please include your registered mobile number or email address, the nature of your request, and any relevant details to allow us to verify your identity and process your request efficiently. If you are not satisfied with hotph's response to a privacy complaint, you have the right to escalate the matter to the National Privacy Commission (NPC) through their official channels.