Summary: hotspin collects personal data to operate our platform, verify your identity, process payments, and comply with Philippine gaming regulations. We do not sell your data. You have the right to access, correct, and delete your information. By using hotspin, you agree to the practices described in this Privacy Policy.
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1. Introduction
hotspin ("hotspin," "we," "us," or "our") operates the online gaming platform accessible at hotspin.one (the "Platform"). We are committed to protecting the privacy and personal data of all players and visitors who use our Platform. This Privacy Policy ("Policy") describes how hotspin collects, uses, stores, shares, and protects your personal information in connection with your use of the Platform.
This Policy applies to all personal data collected through the hotspin Platform, including data collected during account registration, identity verification, gameplay, financial transactions, customer support interactions, and your use of our website. It applies to all players accessing hotspin from the Philippines and any other eligible jurisdiction.
By registering an account on hotspin or otherwise using 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 do not use the hotspin Platform.
This Policy should be read alongside hotspin's Terms & Conditions and Responsible Gaming Policy, which together form the complete agreement governing your use of the Platform.
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2. Data We Collect
hotspin collects personal data in several ways: directly from you when you register or interact with the Platform, automatically through your use of the Platform, and from third-party service providers involved in identity verification and payment processing. The categories of personal data we collect include:
- Registration Data: Full legal name, date of birth, nationality, residential address (including city and province within the Philippines), email address, and mobile phone number.
- Identity Verification (KYC) Data: Government-issued identification documents such as Philippine passport, SSS ID, UMID, driver's license, or PhilSys national ID; proof of address documents; and selfie photographs for liveness verification.
- Financial Data: Payment method details (GCash account number, PayMaya account, BPI/BDO/Metrobank account details, Visa/Mastercard card details), transaction history, deposit and withdrawal records, and wallet balance information.
- Gaming Activity Data: Game session logs, bet history, win/loss records, bonus usage, and responsible gaming tool settings (deposit limits, session limits, self-exclusion status).
- Technical Data: IP address, device type and operating system, browser type and version, session timestamps, and geolocation data (city/region level) used to verify your location for regulatory compliance.
- Communications Data: Records of your interactions with hotspin's customer support team, including live chat transcripts and email correspondence.
- Cookie and Usage Data: Information collected through cookies and similar tracking technologies as described in Section 7 of this Policy.
hotspin collects only the personal data that is necessary for the purposes described in this Policy. We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health information, except where required by law or where you voluntarily provide such information in the context of a responsible gaming self-assessment.
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3. How We Use Your Data
hotspin uses the personal data we collect for the following purposes:
- Account Management: To create, maintain, and manage your hotspin account, including processing your registration, verifying your identity, and enabling you to log in securely.
- Service Delivery: To provide you with access to hotspin's gaming products, including live dealer games, slots, bingo, and sports betting, and to process your deposits and withdrawals.
- Regulatory Compliance: To comply with our obligations under Philippine gaming regulations, anti-money laundering laws, and Know Your Customer requirements. This includes verifying your age (21+), identity, and source of funds where required.
- Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other prohibited conduct on the Platform.
- Responsible Gaming: To monitor gaming activity for signs of problem gambling, to enforce responsible gaming tools you have activated (such as deposit limits and self-exclusion), and to provide appropriate support resources.
- Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through our 24/7 support team.
- Platform Improvement: To analyze usage patterns, identify technical issues, and improve the performance, features, and user experience of the hotspin Platform.
- Communications: To send you important account notifications, security alerts, and updates to our Terms & Conditions or Privacy Policy. Where you have opted in, we may also send promotional communications about hotspin offers and new games.
hotspin does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by law or where you have given explicit consent.
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4. Legal Basis for Processing
hotspin processes your personal data on the following legal bases:
- Contractual Necessity: Processing that is necessary to perform our contract with you under the hotspin Terms & Conditions, including account management, payment processing, and service delivery.
- Legal Obligation: Processing required to comply with applicable laws and regulations, including Philippine gaming regulations administered by PAGCOR, anti-money laundering legislation, and tax reporting obligations.
- Legitimate Interests: Processing necessary for hotspin's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your privacy rights.
- Consent: Processing based on your explicit consent, such as the sending of promotional communications. You may withdraw your consent at any time by contacting hotspin support or updating your account communication preferences.
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5. Data Sharing & Disclosure
hotspin 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 as necessary for the purposes described in this Policy:
- Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard, for the purpose of processing your deposits and withdrawals. These providers are bound by their own privacy policies and applicable financial regulations.
- Identity Verification Providers: Third-party KYC and age verification service providers who assist hotspin in verifying your identity and age in compliance with regulatory requirements.
- Regulatory Authorities: PAGCOR and other competent Philippine government authorities, where disclosure is required by law, court order, or regulatory instruction.
- Technology Service Providers: Cloud hosting, data storage, cybersecurity, and analytics providers who process data on hotspin's behalf under strict data processing agreements that prohibit them from using your data for their own purposes.
- Game Content Providers: Game studios and live dealer platform providers whose games are available on hotspin, to the extent necessary to deliver the gaming service and resolve disputes.
All third parties with whom hotspin shares personal data are required to implement appropriate technical and organizational security measures and to process your data only in accordance with hotspin's instructions and applicable law.
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6. Data Retention
hotspin retains your personal data for as long as your account is active and for a period thereafter as required by applicable law and regulatory obligations. Specifically:
- Account 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 requirements.
- KYC Documents: Retained for a minimum of five (5) years from the date of submission or from the date of account closure, whichever is later.
- Transaction Records: Retained for a minimum of five (5) years from the date of each transaction.
- Gaming Activity Logs: Retained for a minimum of three (3) years from the date of each gaming session.
- Customer Support Records: Retained for a minimum of two (2) years from the date of each interaction.
- Cookie and Technical Data: Retained for periods ranging from session-only (for session cookies) to up to two (2) years (for persistent analytics cookies).
Upon expiry of the applicable retention period, hotspin will securely delete or anonymize your personal data in accordance with our data destruction procedures. Anonymized data that can no longer be linked to an individual may be retained indefinitely for statistical and analytical purposes.
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7. Cookies & Tracking Technologies
hotspin uses cookies and similar tracking
technologies on the Platform for the following purposes:
- Essential Cookies: Required for the Platform to function correctly. These include session cookies that keep you logged in during your visit and security cookies that help protect your account. These cookies cannot be disabled without affecting Platform functionality.
- Functional Cookies: Used to remember your preferences, such as your preferred language, display settings, and responsible gaming tool configurations, so you do not need to re-enter them on each visit.
- Analytics Cookies: Used to collect aggregated, anonymized data about how players use the Platform, including which pages are visited most frequently and where technical errors occur. This data helps hotspin improve the Platform experience.
- Security and Fraud Prevention Cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and bot traffic on the Platform.
hotspin does not use third-party advertising or behavioral tracking cookies. We do not allow third-party advertisers to place cookies on the hotspin Platform.
You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the hotspin Platform. Instructions for managing cookies are available in the help documentation of your browser.
SESSION_ID, HS_PREF, and HS_SEC are examples of first-party cookies set by hotspin. None of these cookies contain your personal financial data or government ID information.
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8. Security Measures
hotspin implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:
- Encryption: All data transmitted between your device and hotspin's servers is encrypted using TLS 1.2 or higher. Sensitive data stored on our servers, including payment details and KYC documents, is encrypted at rest using AES-256 encryption.
- Access Controls: Access to personal data is restricted to authorized hotspin personnel on a strict need-to-know basis. All access is authenticated, logged, and subject to regular audit.
- Infrastructure Security: hotspin's Platform is hosted on secure, certified cloud infrastructure with firewalls, intrusion detection systems, and regular vulnerability assessments.
- Account Security: Player accounts are protected by password hashing, session timeout controls, and optional two-factor authentication. hotspin will never ask you for your password via email or live chat.
- Incident Response: hotspin maintains a data breach response plan. In the event of a data breach that poses a risk to your rights and freedoms, we will notify affected players and relevant authorities in accordance with applicable law.
While hotspin takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are also responsible for maintaining the security of your hotspin account credentials. Please use a strong, unique password and do not share your login details with anyone.
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9. Your Rights
As a hotspin player, you have the following rights with respect to your personal data. To exercise any of these rights, please contact our support team using the details in Section 13:
- Right of Access: You have the right to request a copy of the personal data hotspin holds about you, along with information about how it is being used.
- Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You can update basic account information directly through your hotspin account settings.
- Right to Erasure: You have 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 hotspin's legal obligations to retain certain data as described in Section 6.
- Right to Restriction: You have the right to request that hotspin restrict the processing of your personal data in certain circumstances, such as while a dispute about the accuracy of your data is being resolved.
- Right to Data Portability: You have the right to receive a copy of the personal data you have provided to hotspin in a structured, commonly used, machine-readable format.
- Right to Object: You have the right to object to hotspin's processing of your personal data where that processing is based on legitimate interests. You also have the right to opt out of promotional communications at any time.
- Right to Withdraw Consent: Where hotspin processes your data based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal.
hotspin will respond to all data rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, and we will notify you of any such extension. We may need to verify your identity before processing your request.
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10. Children's Privacy
The hotspin Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. hotspin does not knowingly collect personal data from individuals under the age of 21.
If hotspin discovers or has reason to believe that a registered account belongs to a person under the age of 21, we will immediately suspend the account, delete all associated personal data to the extent permitted by law, and void any transactions conducted through that account.
If you are a parent or guardian and believe that your child has registered on hotspin or provided personal data to us, please contact our support team immediately at [email protected] so that we can take appropriate action.
21+ Only. hotspin enforces strict age verification as part of our KYC process. All players must provide valid government-issued identification confirming they are at least 21 years of age before real-money play is permitted.
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11. Third-Party Services
The hotspin Platform may contain links to or integrations with third-party services, including payment gateways such as GCash and PayMaya. When you interact with these third-party services, you are subject to their respective privacy policies, which are separate from and independent of this hotspin Privacy Policy.
hotspin is not responsible for the privacy practices of third-party services. We encourage you to review the privacy policies of any third-party service you use in connection with your hotspin account, particularly your chosen payment provider.
Game content on the hotspin Platform is provided by licensed third-party game studios. These studios may collect limited technical data (such as game session identifiers) necessary to deliver the gaming service. They do not have access to your full personal profile or financial data held by hotspin.
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12. Updates to This Privacy Policy
hotspin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When we make material changes to this Policy, we will notify registered players by email and/or by posting a prominent notice on the hotspin Platform prior to the changes taking effect.
The date of the most recent revision is always displayed at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how hotspin protects your personal data.
Your continued use of the hotspin Platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree with the updated Policy, you must cease using the Platform and may request account closure in accordance with the hotspin Terms & Conditions.
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13. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or hotspin's data practices, please contact our Data Protection team through any of the following channels:
- Live Chat: Available 24/7 directly on the hotspin Platform
- Support Email: [email protected]
- Response Time: Under 2 hours via live chat; within 24 hours via email
For data rights requests specifically (access, rectification, erasure, portability), please include your registered account email address and a description of your request. hotspin may require identity verification before processing data rights requests to ensure we are responding to the correct account holder.
Our support team includes Filipino-speaking agents available to assist players from Manila, Cebu, Davao, Quezon City, Makati, and across the Philippines.