hot88 Privacy Policy

Scope & Application

This Privacy Policy applies to all personal data processed by hot88 in connection with:

• The hot88 website accessible at hot88.my and all associated subdomains and mobile-optimized interfaces;
• The account registration, login, KYC verification, deposit, withdrawal, betting, and customer support processes;
• Any communication between you and hot88 via live chat, email, or any other channel;
• Cookies and tracking technologies deployed on the hot88 platform.

This Policy applies to all registered players, prospective players who browse the platform without an account, and any individual who contacts hot88 Customer Support. By accessing the platform or registering an account, you acknowledge that you have read and understood this Privacy Policy.

This Policy should be read alongside the Terms & Conditions and the Responsible Gaming Policy, all of which together govern your relationship with hot88.

Definitions

The following terms have the meanings set out below throughout this Privacy Policy:

• "Platform" — the hot88 website, mobile interface, and any associated digital service operated by hot88.
• "Personal Data" — any information that identifies or could reasonably identify a natural person, including name, national identity number, mobile number, IP address, device identifier, and payment account details.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, and deletion.
• "Controller" — hot88, the entity that determines the purposes and means of Processing your Personal Data.
• "Processor" — a third party that Processes Personal Data on behalf of hot88 strictly under our instructions (e.g., a payment gateway or identity verification provider).
• "Player" / "You" — any individual who registers or uses an Account on the Platform.
• "KYC" — Know Your Customer; the identity and age verification process required before withdrawals are approved.
• "KTP" — Kartu Tanda Penduduk; the standard Indonesian national identity card issued to citizens aged 17 and above.
• "Cookies" — small text files placed on your device by the Platform to enable functionality, remember preferences, and support analytics.
• "WIB" — Western Indonesia Time (UTC+7), the default time zone used for all timestamps in our systems.

Data We Collect

3.1 Registration Data

When you create a hot88 account, we collect: your full legal name as it appears on your KTP; a unique username of your choosing; a password (stored in hashed, non-recoverable form — we never store plaintext passwords); a valid Indonesian mobile phone number; your date of birth; and your city of residence (e.g., Jakarta, Surabaya, Bandung, Bali, Medan).

3.2 Identity Verification (KYC) Data

To comply with anti-money-laundering obligations and to confirm that you are at least 21 years of age, we collect a clear photograph or scanned copy of your KTP, and a recent selfie photograph for liveness verification. These documents are processed by our KYC team and by our certified identity verification partner and are retained for the period specified in Section 9.

3.3 Financial Data

We collect records of all deposit and withdrawal transactions, including the payment method used (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata, OVO, DANA, GoPay, ShopeePay, or LinkAja), transaction amounts in Indonesian Rupiah (IDR), transaction timestamps (WIB), and the bank account or e-wallet identifier associated with each transaction. We do not store full bank account numbers or e-wallet PINs.

3.4 Betting & Gaming Data

We maintain records of all bets placed, games played, outcomes, stakes, and winnings associated with your Account. This data is used for account management, dispute resolution, responsible gaming monitoring, and regulatory compliance.

3.5 Technical & Device Data

We automatically collect your IP address, browser type and version, operating system, device type (desktop, mobile, tablet), screen resolution, referring URL, pages visited, session duration, and timestamps of Platform interactions. This data helps us detect fraud, improve platform performance, and tailor the experience to your device.

3.6 Communications Data

When you contact Customer Support via live chat or email, we retain a record of the conversation, including the subject matter, timestamps, and any attachments you provide. These records are used to resolve your enquiry, improve support quality, and provide a reference in case of escalation.

3.7 Marketing Preferences

If you opt in to promotional communications, we record your preference and use it to send you relevant offers via SMS or on-platform notifications. You may withdraw this consent at any time from your Account Settings.

How We Collect Data

hot88 collects Personal Data through the following channels:

• Directly from you — when you complete the registration form, submit KYC documents, make a deposit or withdrawal, contact Customer Support, or update your Account Settings;
• Automatically — through server logs, cookies, session tracking, and device fingerprinting as you interact with the Platform (see Section 8 for full cookie details);
• From third-party payment providers — payment gateways confirm transaction status and provide reference data necessary to credit your Balance or process your withdrawal;
• From identity verification partners — our KYC partner returns a verification result (pass/fail) and flags any document anomalies; the underlying document images are stored by hot88 directly;
• From fraud-detection services — risk-scoring signals such as device reputation, IP geolocation, and velocity checks are provided by third-party fraud prevention tools and are used solely for security purposes.

Purpose of Processing

The table below sets out each category of Personal Data we collect, the purpose for which it is processed, and the legal basis relied upon (detailed further in Section 6):

Legal Basis for Processing

hot88 processes Personal Data under one or more of the following legal bases:

• Performance of contract: Processing is necessary to fulfil our obligations to you under the Terms & Conditions — for example, creating your Account, processing your deposits, settling your bets, and handling your withdrawals.
• Legal obligation: Certain processing activities are required by applicable anti-money-laundering regulations, age-verification requirements, and the conditions attached to our international gaming licence — including the collection and retention of KYC documents and transaction records.
• Legitimate interest: We process technical, device, and behavioural data to protect the Platform from fraud, abuse, and unauthorised access; to maintain platform security and stability; and to improve our services. Our legitimate interest in fraud prevention does not override your privacy rights where those rights take precedence.
• Consent: Where we send you optional marketing communications, we rely on your explicit opt-in consent. You may withdraw this consent at any time without affecting the lawfulness of processing before withdrawal.

Data Sharing & Disclosure

7.1 Categories of Recipients

hot88 shares Personal Data only with the following categories of recipients, and only to the minimum extent necessary:

• Payment processors: BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata, OVO, DANA, GoPay, ShopeePay, LinkAja, and their gateway partners receive transaction reference data required to route and confirm payments.
• Identity verification partners: Our KYC provider receives KTP images and selfie photographs solely to perform document authentication and liveness checks. They are contractually prohibited from using this data for any other purpose.
• Game providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft receive an anonymised player session token to facilitate gameplay. They do not receive your name, KTP number, or financial account details.
• Fraud-prevention and security services: Risk-scoring platforms receive IP addresses, device identifiers, and behavioural signals to evaluate transaction risk.
• Customer support platform: Our live chat infrastructure provider processes conversation transcripts in order to deliver support. They act as a Data Processor under contract with hot88.
• Legal and regulatory authorities: hot88 will disclose Personal Data when required to do so by a lawful court order, regulatory directive, or law enforcement request under applicable law.

7.2 No Sale of Personal Data

hot88 does not sell, rent, exchange, or otherwise transfer your Personal Data to any third party for commercial or marketing purposes. All sharing arrangements are governed by binding data processing agreements that require recipients to maintain confidentiality and security standards equivalent to those applied by hot88.

7.3 Business Transfers

In the event of a merger, acquisition, or sale of substantially all of hot88's assets, Personal Data held by hot88 may be transferred to the acquiring entity. You will be notified of any such transfer via in-platform notification no less than 30 days before it takes effect, and you will retain the right to request account closure and data deletion before the transfer occurs.

Cookies & Tracking Technologies

8.1 What Are Cookies?

Cookies are small text files placed on your device by the Platform when you visit. They allow the Platform to remember your preferences, maintain your login session, and gather analytics data about how the Platform is used. hot88 also uses similar technologies including local storage objects and session tokens.

8.2 Types of Cookies We Use

8.3 Managing Cookies

Strictly necessary cookies cannot be disabled as they are essential to the Platform's operation. You may configure your browser to block or delete other cookie categories; however, doing so may impair certain Platform features such as saved preferences and session continuity. Instructions for managing cookies vary by browser and are available in your browser's help documentation.

Data Retention

hot88 retains Personal Data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by regulatory obligations. The following retention periods apply:

At the end of the applicable retention period, Personal Data is either securely deleted from our systems or anonymised so that it can no longer be linked to any individual. Anonymised, aggregated data may be retained indefinitely for statistical and analytical purposes.

Security Measures

hot88 applies a defence-in-depth approach to data security, incorporating technical, administrative, and physical safeguards appropriate to the sensitivity of the data held:

• Encryption in transit: All communications between your device and the Platform are encrypted using TLS 1.2 or higher with 256-bit AES encryption. HTTPS is enforced site-wide with HTTP Strict Transport Security (HSTS) headers.
• Encryption at rest: Sensitive fields including KTP numbers, payment account identifiers, and KYC document images are encrypted at rest using AES-256 within our database systems.
• Password security: Passwords are hashed using a strong one-way algorithm (bcrypt or equivalent). Plaintext passwords are never stored or transmitted by hot88's systems.
• Access controls: Access to personal data within hot88's internal systems is restricted to staff members with a demonstrated business need. Access is logged, reviewed, and revoked promptly upon role change or employment termination.
• Penetration testing: hot88's Platform undergoes periodic penetration testing and vulnerability assessments conducted by independent security professionals.
• Incident response: In the event of a data breach that creates a risk to your rights, hot88 will notify affected players via their registered mobile number or in-platform notification within 72 hours of confirming the breach, and will implement containment and remediation measures without delay.

Your Rights

As a player on the hot88 platform, you have the following rights with respect to your Personal Data. All requests should be submitted via live chat or email to [email protected] and will be acknowledged within 72 business hours (WIB):

Please note that certain rights are subject to limitations where legal retention obligations, fraud prevention requirements, or ongoing regulatory proceedings apply. hot88 will clearly communicate any limitations when responding to your request.

Minors

If hot88 becomes aware that Personal Data has been collected from an individual under 21 — whether through a fraudulent registration, a failed KYC check, or any other means — that Account will be immediately suspended. Any real-money balance resulting from deposits will be returned to the originating payment source after completion of an investigation. The Personal Data of the underage individual will be deleted from our systems to the fullest extent permitted by regulatory obligations.

Parents and guardians who believe a minor may have accessed the Platform should contact Customer Support via live chat immediately so that the situation can be investigated and resolved without delay.

International Data Transfers

hot88 operates a globally distributed infrastructure. Some Personal Data processing activities — particularly those carried out by our identity verification partner, fraud-detection service, and game providers — may involve the transfer of data to servers located outside Indonesia.

Where such transfers occur, hot88 ensures that appropriate safeguards are in place, which may include:

• Standard contractual clauses requiring the recipient to maintain data protection standards equivalent to those described in this Policy;
• Binding corporate rules where the recipient is an affiliated entity;
• Transfer to jurisdictions that provide an adequate level of data protection as recognised by applicable international standards.

You may request details of the specific safeguards in place for any given transfer by contacting Customer Support. hot88 does not transfer Personal Data to jurisdictions that lack adequate protections without first putting contractual safeguards in place.

Third-Party Services

The hot88 Platform integrates third-party game content from providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft. When you launch a game, your device may communicate directly with the game provider's servers to load game assets. This interaction is governed by the game provider's own privacy terms, and hot88 is not responsible for the data practices of third-party game studios once a direct connection is established.

hot88 does not embed third-party social media widgets, advertising trackers, or affiliate-tracking pixels that would transmit your Personal Data to external marketing platforms without your knowledge. Any analytics or performance-monitoring tools used by hot88 are configured to anonymise IP addresses and to aggregate data before transmission.

Changes to This Privacy Policy

hot88 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. The "Last Updated" date at the top of this page will be revised whenever a material change is made.

For material changes — those that meaningfully affect how we use your Personal Data or your rights as a data subject — hot88 will provide advance notice via in-platform notification or SMS to your registered mobile number at least 7 days before the change takes effect.

Non-material changes (such as formatting improvements, clarifications of existing practices, or corrections of typographical errors) may be made without advance notice. Your continued use of the Platform following the publication of any revised Policy constitutes your acceptance of the updated terms. If you do not accept the revised Policy, you should cease using the Platform and contact Customer Support to request account closure.

Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise any of your data subject rights, or wish to raise a complaint about hot88's data-handling practices, please contact us through the following channel:

All data subject requests will be assessed on their individual merits. hot88 may need to verify your identity before actioning a request to ensure that personal data is not disclosed to, or deleted at the request of, an unauthorised third party. Identity verification for this purpose will not require you to submit new documents if your KYC has already been approved — Customer Support will verify your identity through your registered account details.