hotwin Privacy Policy

1Introduction

hotwin ("hotwin," "we," "us," or "our") is committed to protecting the personal data of every player who uses the hotwin platform at hotwin.cam. This Privacy Policy ("Policy") sets out how hotwin collects, processes, stores, and protects personal data in relation to your use of our online casino, sports betting, and gaming services (the "Platform").

This Policy applies to all registered players, prospective players, and visitors to hotwin.cam regardless of device or access method. It applies to all personal data collected through the Platform, including data provided during registration, during gameplay, through the cashier, and through any communication with the hotwin support team.

hotwin processes personal data in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and any applicable guidelines issued by the National Privacy Commission (NPC) of the Philippines.

2Who We Are — Data Controller

For the purposes of this Policy, hotwin operates as the Data Controller in relation to the personal data of players on the Platform. As Data Controller, hotwin determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable data protection law.

hotwin has designated a Data Protection Officer ("DPO") responsible for overseeing data protection practices, handling data subject requests, and acting as the primary point of contact for data privacy-related matters. The hotwin DPO can be contacted at the address set out in Section 15 of this Policy.

3Personal Data We Collect

hotwin collects different categories of personal data depending on how you interact with the Platform. The following table summarises the categories of personal data collected and the primary purpose for each.

hotwin does not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, health data, or sexual orientation, except where collection is specifically required by law or expressly consented to by you.

4How We Collect Your Data

hotwin collects personal data through the following channels and mechanisms:

4.1 Data You Provide Directly

The majority of the personal data hotwin holds is provided directly by you when you: register an account on hotwin.cam; complete the KYC verification process by submitting identity documents; make a deposit or withdrawal via GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard, or USDT; contact the hotwin support team via live chat or email; respond to surveys, promotions, or feedback requests.

4.2 Data Collected Automatically

When you access or use the hotwin Platform, certain technical and usage data is collected automatically through server logs, analytics tools, and cookies. This includes your IP address, device identifiers, browser configuration, session duration, pages visited, games launched, and in-game actions taken.

4.3 Data from Third Parties

hotwin may receive limited personal data from third parties in the following contexts: identity verification service providers used in the KYC process; payment processors confirming transaction status; fraud detection services flagging suspicious activity; social login providers (Google, Facebook) where you choose to register using a social account. Data received from third parties is processed in accordance with this Policy and is limited to what is necessary for the specified purpose.

5How We Use Your Personal Data

hotwin uses the personal data collected for the following purposes:

• Account management: Creating, verifying, maintaining, and administering your hotwin account and associated wallet;
• Identity verification (KYC): Verifying your identity and confirming that you meet the minimum age requirement of 21 years, as required by PAGCOR and applicable Philippine law;
• Transaction processing: Processing deposits and withdrawals through your chosen payment method and maintaining accurate transaction records;
• Fraud and AML prevention: Detecting, investigating, and preventing fraud, money laundering, and other financially or legally prohibited activities on the Platform;
• Regulatory compliance: Fulfilling obligations under applicable Philippine gaming regulations, anti-money laundering law, and any directions issued by PAGCOR or the NPC;
• Responsible gaming: Monitoring gaming behaviour to identify potential problem gambling patterns and to provide appropriate responsible gaming interventions, tools, and support;
• Customer support: Responding to your queries, resolving disputes, and delivering technical and account support via live chat and email;
• Platform improvement: Analysing anonymised usage data to identify performance issues, user experience improvements, and feature development priorities;
• Marketing communications: Sending you information about hotwin bonuses, promotions, and platform updates where you have provided consent to receive such communications. You may withdraw this consent at any time.

6Legal Basis for Processing

hotwin processes your personal data under one or more of the following lawful bases, as specified under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform the contract between you and hotwin — i.e., to operate your account, process your deposits and withdrawals, and deliver gaming services;
• Legal obligation: Processing required to comply with applicable Philippine law, including KYC obligations, anti-money laundering regulations, PAGCOR reporting requirements, and NPC directives;
• Legitimate interests: Processing that serves hotwin's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where those interests are not overridden by your privacy rights;
• Consent: Processing based on your explicit, informed consent — specifically for marketing communications and, where applicable, the processing of sensitive personal information. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.

7Data Sharing & Third-Party Disclosure

hotwin does not sell, rent, or trade your personal data. Personal data may be shared with the following categories of third parties, strictly to the extent necessary for the stated purpose:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard, and USDT processing partners — to facilitate your deposits and withdrawals;
• KYC and identity verification providers: Third-party services engaged to verify identity documents and perform age verification;
• Fraud and AML screening services: Providers of transaction monitoring, device fingerprinting, and sanctions screening services;
• Game providers: Certified iGaming software providers who supply the games in the hotwin lobby. These providers may receive limited technical data such as session tokens, device type, and bet history for game delivery and fairness certification purposes;
• Regulatory authorities: PAGCOR, the National Privacy Commission, and other competent Philippine government authorities where disclosure is required by law, regulation, or court order;
• Professional advisers: Legal, accounting, and audit professionals engaged by hotwin in the ordinary course of business, subject to confidentiality obligations.

All third parties with whom hotwin shares personal data are required to process that data only for the specified purpose, to maintain appropriate security measures, and to comply with applicable data protection law.

8Cookies & Tracking Technologies

The hotwin Platform uses cookies and similar tracking technologies to provide functionality, maintain your session, and collect usage data. The categories of cookies used are as follows:

• Strictly necessary cookies: Required for the Platform to function — including session management, login authentication, and security features. These cannot be disabled without impacting functionality.
• Functional cookies: Remember your preferences such as language settings, last-played game, and deposit method to provide a more personalised experience.
• Analytics cookies: Collect anonymised usage data to help hotwin understand how players navigate the Platform and identify areas for improvement. Data is aggregated and does not identify individual players.
• Security cookies: Used by hotwin's fraud detection systems to identify unusual device behaviour and prevent account takeover attempts.

You may adjust your browser settings to refuse or delete non-essential cookies. Disabling strictly necessary cookies will affect the functionality of the hotwin Platform and may prevent you from logging in or completing transactions.

9Data Retention

hotwin retains personal data for as long as is necessary to fulfil the purposes described in this Policy, or as required by applicable Philippine law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping obligations.
• Financial transaction records: Retained for a minimum of five (5) years in accordance with AMLA requirements applicable to covered institutions in the Philippines.
• KYC documentation: Retained for a minimum of five (5) years from the date of document submission, or for a longer period if required by a regulatory investigation or legal proceeding.
• Support communication records: Retained for a minimum of two (2) years from the date of the communication.
• Marketing preference data: Retained until consent is withdrawn or the account is closed, whichever is earlier.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be linked to any individual.

10Data Security

hotwin implements a layered security architecture to protect your personal data from unauthorised access, disclosure, alteration, and destruction. Security measures in place include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and hotwin servers;
• AES-256 encryption at rest for sensitive data fields including identity document images and financial account details;
• Role-based access controls ensuring that staff can access personal data only to the extent required by their specific role;
• Multi-factor authentication required for all hotwin administrative system access;
• Regular third-party security audits and penetration testing of Platform infrastructure;
• Automated anomaly detection systems monitoring for unusual access patterns and potential data breaches;
• Secure data disposal procedures ensuring that decommissioned storage media is permanently sanitised before disposal.

11Your Data Privacy Rights

Under the Data Privacy Act of 2012 and its Implementing Rules, you have the following rights in relation to your personal data held by hotwin. You may exercise any of these rights by contacting the hotwin Data Protection Officer as set out in Section 15.

hotwin will respond to verified data subject requests within thirty (30) calendar days. Where a request is complex or involves a large volume of data, we may extend this period by a further thirty (30) days and will notify you accordingly. We will not charge a fee for reasonable requests. If you believe your rights have not been respected, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

12Children's Privacy and Age Restriction

The hotwin Platform is strictly restricted to individuals who are 21 years of age or older. hotwin does not knowingly collect personal data from individuals under the age of 21. The minimum age requirement is enforced through the KYC identity verification process, which all players must complete before withdrawal privileges are activated.

If hotwin becomes aware that personal data has been collected from an individual who is under 21 years of age, that data will be deleted promptly and the associated account will be closed. Any funds deposited by an underage individual will be returned to the originating payment method after the completion of required regulatory procedures. If you believe that a minor has registered an account on the hotwin Platform, please contact us immediately.

13International Data Transfers

In connection with the delivery of Platform services, some personal data processed by hotwin may be transferred to, or accessed by, systems or personnel located outside the Philippines — for example, in connection with certified game providers, cloud infrastructure providers, or fraud detection services that operate internationally.

Any such transfer is conducted only where appropriate safeguards are in place to ensure that the personal data receives a level of protection equivalent to that afforded under the Data Privacy Act of 2012. Safeguards may include contractual data processing agreements incorporating standard data protection clauses, or transfers to countries assessed by the NPC as providing adequate data protection.

14Policy Updates

hotwin reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory guidance. When material changes are made to this Policy, hotwin will:

• Update the "Effective date" at the top of this page;
• Send an email notification to all registered players at least seven (7) days before the updated Policy takes effect;
• Display a prominent notice on the hotwin Platform during the notice period.

Your continued use of the hotwin Platform after the effective date of the updated Policy constitutes your acceptance of the revised terms. If you do not agree with the updated Policy, you should contact hotwin support to close your account in accordance with our Terms & Conditions — see Terms & Conditions.

15Contact & Data Protection Officer

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or want to report a privacy concern, please contact the hotwin Data Protection Officer using the details below:

If you are not satisfied with hotwin's response to a data privacy concern, you have the right to file a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph). hotwin fully cooperates with NPC investigations and inquiries.

For issues related to responsible gaming — including self-exclusion, deposit limits, and cooling-off requests — please visit our Responsible Gaming page or contact support directly.