hotph Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") is issued by hotph ("hotph," "we," "us," or "our"), a PAGCOR-regulated online gaming platform accessible at hotph.cam. This Policy applies to all personal data collected from users ("Player," "User," "you," or "your") who access the hotph website, create an account, use any hotph gaming services, or communicate with the hotph support team.

This Policy has been prepared in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations (IRR), and the issuances of the National Privacy Commission (NPC) of the Philippines. hotph is registered as a personal information controller with the NPC in accordance with its registration requirements.

By accessing the hotph platform or registering an account, you acknowledge that you have read, understood, and consent to the collection and processing of your personal data as described in this Policy. If you do not consent, you must immediately discontinue use of all hotph services.

2. Personal Information Controller

For the purposes of the Data Privacy Act of 2012, hotph acts as the Personal Information Controller (PIC) for all personal data collected through the hotph platform. hotph determines the purpose and means of processing your personal data. Our Data Protection Officer (DPO) can be reached via the contact details provided in Section 13 of this Policy.

3. Personal Data We Collect

hotph collects personal data in the following categories:

3.1 Registration and Identity Data

• Full legal name as it appears on government-issued identification;
• Date of birth and age verification information;
• Philippine residential address;
• Valid email address;
• Philippine mobile number;
• Government-issued ID numbers (e.g., passport, driver's license, UMID, SSS, PhilSys ID);
• Selfie photographs and identity document scans for KYC verification.

3.2 Financial and Transaction Data

• GCash or PayMaya account references linked to your hotph account;
• Bank account numbers (BPI, BDO, Metrobank) used for deposits or withdrawals;
• Debit/credit card details (card number, expiry date — stored in encrypted, tokenized form only);
• Deposit history, withdrawal history, and transaction records;
• Wagering history, bet records, and gaming activity logs.

3.3 Technical and Usage Data

• IP address and geolocation data at the time of access;
• Device type, operating system, browser type, and version;
• Session duration, pages visited, and interaction logs;
• Cookies and similar tracking technologies (see Section 9).

3.4 Communications Data

• Customer support chat transcripts and email correspondence;
• Feedback, complaints, and survey responses submitted to hotph;
• Records of consent and communication preferences.

4. Legal Bases and Purposes of Processing

hotph processes your personal data on the following legal bases and for the following purposes:

Purpose of Processing	Legal Basis
Account registration and identity verification (KYC)	Contractual necessity; PAGCOR regulatory compliance; Anti-Money Laundering Act (RA 9160)
Processing deposits and withdrawals	Contractual necessity; legal obligation
Providing gaming services and platform access	Contractual necessity; legitimate interest
Fraud prevention, security monitoring, and AML compliance	Legal obligation; legitimate interest; PAGCOR regulatory requirement
Responsible gaming monitoring and player protection	Legal obligation; legitimate interest; PAGCOR regulatory requirement
Customer support and dispute resolution	Contractual necessity; legitimate interest
Platform improvement, analytics, and product development	Legitimate interest; consent (where required)
Marketing and promotional communications	Consent (opt-in); you may withdraw consent at any time
Compliance with tax, legal, and regulatory requirements	Legal obligation

5. Disclosure of Personal Data to Third Parties

5.1 Categories of Recipients

hotph does not sell, rent, or trade your personal data. We may share your personal data with the following categories of third parties, strictly on a need-to-know basis and subject to appropriate data processing agreements and confidentiality obligations:

• Payment processors and financial institutions: GCash (Mynt), PayMaya (PayMongo/Voyager), BPI, BDO, Metrobank, Visa, and Mastercard, for the purpose of processing deposits and withdrawals;
• KYC and identity verification service providers: Third-party identity verification platforms used to validate government-issued IDs and perform liveness checks;
• Game content providers: Licensed game studios and RNG certification bodies whose games appear in the hotph lobby;
• IT infrastructure and cloud service providers: Hosting, storage, and cybersecurity service providers operating under strict data processing agreements;
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where required by law or regulatory directive;
• Professional advisers: Legal counsel, auditors, and compliance consultants bound by professional confidentiality obligations.

5.2 International Data Transfers

Where hotph engages service providers located outside the Philippines, we ensure that such transfers comply with the Data Privacy Act's cross-border data transfer provisions. We require that recipient organizations maintain data protection standards equivalent to those required under Philippine law, and we execute appropriate data transfer agreements to formalize this requirement.

6. Data Retention

hotph retains your personal data for as long as necessary to fulfill the purposes described in this Policy, comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements. Specific retention periods are as follows:

• Account and identity data: Retained for the duration of your account, and for five (5) years following account closure, as required by PAGCOR regulations and AML compliance requirements;
• Transaction and financial data: Retained for five (5) years from the date of each transaction, in compliance with the Anti-Money Laundering Act;
• Customer support communications: Retained for two (2) years from the date of the last communication;
• Technical and usage logs: Retained for twelve (12) months from the date of collection, unless required for longer periods in connection with a security investigation or dispute.

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

7. Your Rights as a Data Subject

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by hotph:

• Right to be Informed: You have the right to be informed of the fact that your personal data is being processed, the purpose of processing, the scope and method of processing, and the identity of hotph as the personal information controller.
• Right to Access: You have the right to request access to your personal data held by hotph, including the purposes of processing, the categories of data processed, and the recipients to whom your data has been disclosed.
• Right to Correction: You have the right to request that inaccurate, incomplete, outdated, or misleading personal data be corrected or updated.
• Right to Erasure or Blocking: You have the right to request the erasure or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where processing is unlawful — subject to overriding legal and regulatory obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing, profiling, or any other purpose not strictly necessary for the performance of your account contract.
• Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Damages: You have the right to be indemnified for any damages sustained as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal data.
• Right to File a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe hotph has processed your personal data in violation of the Data Privacy Act.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 13. We will respond to all data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

8. Security Measures

hotph implements a comprehensive set of technical, organizational, and physical security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• TLS 1.3 encryption for all data transmitted between your device and the hotph platform;
• AES-256 encryption for all personal data stored on hotph servers;
• Strict role-based access controls ensuring that only authorized personnel can access personal data, strictly limited to what is necessary for their role;
• Regular penetration testing and vulnerability assessments conducted by independent cybersecurity firms;
• Multi-factor authentication (MFA) enforced for all hotph staff with access to personal data systems;
• Continuous 24/7 monitoring of platform infrastructure for unauthorized access attempts and anomalous activity;
• Mandatory data protection training for all hotph employees who handle personal data.

9. Cookies and Tracking Technologies

hotph uses cookies and similar tracking technologies on the hotph.cam website to ensure the platform functions correctly, to remember your preferences, to analyze usage patterns, and to assist with security monitoring. The categories of cookies used are as follows:

• Strictly Necessary Cookies: Essential to the operation of the platform. These cookies enable account authentication, session management, and security functions. They cannot be disabled without affecting platform functionality.
• Performance and Analytics Cookies: Used to collect anonymized data about how players use the hotph platform, which pages are visited most frequently, and where errors occur. This data is used to improve platform performance and user experience.
• Functionality Cookies: Used to remember your language preferences, regional settings, and display preferences across sessions.

You may control or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the hotph platform. hotph does not use third-party advertising or tracking cookies.

10. Children's Privacy

hotph services are strictly restricted to individuals who are at least twenty-one (21) years of age, in compliance with PAGCOR regulations. hotph does not knowingly collect or process personal data from individuals under the age of 21. If hotph becomes aware that personal data has been collected from an underage individual, we will immediately suspend the associated account, delete the personal data, and report the matter as required by applicable law. If you believe that an underage person has registered on hotph, please notify our support team immediately.

11. Responsible Gaming and Data Processing

As part of our PAGCOR-mandated responsible gaming obligations, hotph processes certain personal data, including gaming activity patterns, transaction frequency, and self-reported information, for the purpose of identifying players who may be experiencing gambling-related harm. This processing is carried out in the legitimate interest of player protection and in compliance with PAGCOR responsible gaming directives. The results of this processing may trigger proactive outreach from hotph's responsible gaming team. You may read more about the tools available to you on our Responsible Gaming page.

12. Amendments to This Policy

hotph reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. We will provide advance notice of material changes by posting the updated Policy on the hotph website and, where appropriate, notifying registered users by email. The "Last Updated" date at the top of this Policy will be revised accordingly. Your continued use of the hotph platform after the effective date of any amendment constitutes acceptance of the updated Policy.

13. Contact — Data Protection Officer

For all data privacy inquiries, data subject access requests, complaints, or concerns regarding hotph's handling of your personal data, please contact our Data Protection Officer in writing:

Platform: hotph.cam
Email: [email protected]
Subject Line: Data Privacy — [Your Request Type]
Regulator: National Privacy Commission (NPC), Philippines
Gaming Regulator: Philippine Amusement and Gaming Corporation (PAGCOR)