Privacy Policy

This Privacy Policy ("Policy") describes how hotwin ("hotwin", "we", "us", "our") collects, processes, stores, and protects the personal information of players and visitors who access the hotwin platform at hotwin.club ("Platform").

hotwin takes data privacy seriously. We operate in compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), and its implementing rules and regulations. As a player on the hotwin platform, you have rights over your personal data, and this Policy is designed to help you understand and exercise those rights.

By registering an account on hotwin or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the hotwin Platform.

hotwin is the data controller responsible for the personal information collected through the hotwin Platform. As data controller, hotwin determines the purposes and means of processing your personal data.

For all data privacy enquiries, requests, or complaints, you may contact the hotwin Data Protection Officer (DPO) via the support email address listed in Section 13 of this Policy. hotwin will respond to all data privacy requests within the timeframes required under the Data Privacy Act of 2012.

hotwin collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

hotwin does not collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. We do not collect biometric data, political opinions, religious beliefs, or health information unless specifically required by applicable law.

hotwin uses your personal data for the following purposes:

• Account Management: To create, maintain, and administer your hotwin player account, including processing your registration and verifying your identity through KYC procedures.
• Service Delivery: To provide you with access to hotwin's games, promotions, bonuses, and all other platform features.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other accepted payment methods.
• Regulatory Compliance: To comply with our obligations under Philippine gaming regulations, the Data Privacy Act of 2012, anti-money laundering laws, and other applicable legislation.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the hotwin Platform.
• Responsible Gaming: To monitor gaming activity and identify players who may be at risk, and to administer responsible gaming tools such as deposit limits and self-exclusion.
• Customer Support: To respond to your enquiries, complaints, and support requests.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications. You may opt out at any time.
• Platform Improvement: To analyse usage patterns and improve the hotwin Platform's performance, features, and user experience.

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

• Contractual Necessity: Processing is necessary to perform the contract between you and hotwin (i.e., to provide you with the gaming services you have registered for).
• Legal Obligation: Processing is necessary to comply with hotwin's legal obligations under Philippine gaming regulations, anti-money laundering laws, and tax legislation.
• Legitimate Interests: Processing is necessary for hotwin's legitimate interests in operating a secure, compliant, and commercially viable gaming platform, provided those interests are not overridden by your data protection rights.
• Consent: For certain processing activities — such as marketing communications and non-essential cookies — hotwin relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

hotwin does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, solely to process your financial transactions.
• Identity Verification Providers: Third-party KYC and identity verification service providers engaged to assist hotwin in verifying player identities and complying with regulatory requirements.
• Game Providers: Licensed game software providers whose games are hosted on the hotwin Platform, to the extent necessary to deliver gameplay services.
• Regulatory Authorities: The Philippine Amusement and Gaming Corporation (PAGCOR) and other competent regulatory or law enforcement authorities, where hotwin is legally required or permitted to disclose your data.
• Anti-Money Laundering Bodies: The Anti-Money Laundering Council (AMLC) of the Philippines, where hotwin is required to report suspicious transactions under applicable AML legislation.
• IT and Security Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers engaged by hotwin to operate and secure the Platform.
• Professional Advisers: Lawyers, auditors, and accountants engaged by hotwin, subject to professional confidentiality obligations.

All third parties with whom hotwin shares personal data are required to handle that data in accordance with applicable data protection laws and hotwin's data processing standards. hotwin does not authorise any third party to use your personal data for their own independent purposes.

hotwin retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account Data: Retained for the duration of your hotwin account and for a minimum of five (5) years following account closure, in accordance with Philippine gaming and AML regulatory requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required under Philippine AML legislation.
• KYC and Identity Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Gaming History: Retained for a minimum of three (3) years from the date of each gaming session.
• Customer Support Records: Retained for three (3) years from the date of the relevant interaction.
• Marketing Consent Records: Retained until you withdraw consent, plus a reasonable period thereafter for record-keeping purposes.

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

hotwin implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the hotwin Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing of the hotwin Platform.
• Multi-factor authentication requirements for hotwin staff accessing systems that process personal data.
• Incident response procedures to detect, report, and address personal data breaches in a timely manner.

While hotwin takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your hotwin Login credentials and for notifying hotwin immediately if you suspect any unauthorised access to your account.

hotwin uses cookies and similar tracking technologies on the Platform to enhance your experience, analyse usage, and support security functions. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Functional Cookies: Remember your preferences and settings (such as language and display options) to personalise your experience on hotwin.
• Analytics Cookies: Collect anonymised data about how players use the hotwin Platform, helping us identify areas for improvement. These are only set with your consent.
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of hotwin's marketing campaigns. These are only set with your consent.

You can manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the hotwin Platform. For strictly necessary cookies, no consent is required as they are essential to the operation of the service.

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights in relation to your personal data held by hotwin:

• Right to Be Informed: The right to be informed of how your personal data is being collected and processed, as set out in this Policy.
• Right of Access: The right to request a copy of the personal data hotwin holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data hotwin holds about you.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to hotwin's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on hotwin's legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, 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 hotwin has not handled your personal data in accordance with the Data Privacy Act of 2012.

To exercise any of these rights, please contact the hotwin Data Protection Officer using the contact details in Section 13. hotwin will respond to all verified requests within thirty (30) days, or within such other period as required by applicable law.

The hotwin Platform is strictly intended for persons aged 21 years and above. hotwin does not knowingly collect personal data from individuals under the age of 21. The 21+ age requirement is a strict legal requirement under Philippine gaming regulations and is enforced through hotwin's KYC verification process.

If hotwin becomes aware that personal data has been collected from a person under 21 years of age, that data will be deleted immediately and the associated account will be permanently closed. If you believe that a minor has registered on the hotwin Platform, please contact hotwin support immediately so that appropriate action can be taken.

Parents and guardians are encouraged to use parental control tools and to monitor the online activities of minors in their care to prevent access to age-restricted platforms such as hotwin.

hotwin 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. Where changes are material, hotwin will notify you via the Platform or by email to your registered address prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the hotwin Platform following the effective date of any updated Policy constitutes your acknowledgement of the changes. We encourage you to review this Policy periodically to stay informed about how hotwin protects your personal data.

If you have any questions, concerns, or requests regarding this Privacy Policy or the way hotwin handles your personal data, please contact our Data Protection Officer:

Email: [email protected]

hotwin aims to acknowledge all data privacy requests within five (5) business days and to resolve them within thirty (30) days. For complex requests, we may require additional time and will notify you accordingly.

If you are not satisfied with hotwin's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines.