hot511 Privacy
Policy

1 Who We Are

hot511 is an internationally licensed online betting and gaming platform operating at hot511.org. We serve Members primarily based in Indonesia, offering sports betting markets — including BRI Liga 1, EPL, La Liga, Bundesliga, Champions League, and international football events such as the AFF Cup and FIFA World Cup — as well as live casino games, electronic table games, and a curated slot gacor (high-payout slots) library.

For the purposes of this Privacy Policy, hot511 acts as the data controller in respect of all personal data collected from Members and visitors to the Platform. As data controller, we determine the purposes for which personal data is processed and the means by which it is processed, and we are accountable for ensuring that all processing activities comply with applicable international data protection standards.

Our designated data protection contact can be reached at [email protected]. All privacy-related enquiries, data subject access requests, and complaints should be directed to this address with the subject line "Privacy — Data Request" for prioritised handling.

2 Data We Collect

hot511 collects personal data in the following categories. We apply the principle of data minimisation throughout — meaning we collect only what is genuinely necessary for the stated purpose.

3 How We Collect Data

hot511 collects personal data through the following channels and mechanisms:

• Direct registration: Data you provide when creating a hot511 account, completing your profile, or submitting KYC documentation.
• Transactional activity: Data generated automatically when you make a deposit, place a wager, request a withdrawal, or claim a promotional bonus on the Platform.
• Support interactions: Data you share when contacting our customer support team via live chat or email at [email protected].
• Automated technical collection: Device, browser, and session data collected automatically when you visit the Platform, via server logs, cookies, and similar tracking technologies (see Section 8 for full details).
• Third-party verification partners: Identity and fraud-risk data received from our KYC service providers and payment processors when verifying your identity or processing financial transactions.

4 Purpose of Processing

hot511 processes your personal data only for specific, explicit, and legitimate purposes. The table below maps each processing purpose to the relevant data category and legal basis.

hot511 does not use your personal data for automated decision-making that produces significant legal effects without human review, with the exception of automated fraud-risk scoring which may trigger an account review flag — in all such cases, a member of our compliance team conducts a manual review before any account action is taken.

5 Legal Basis for Processing

hot511 processes personal data on the following legal bases in accordance with internationally recognised data protection principles:

• Contractual necessity: Processing required to deliver the services described in the hot511 Terms & Conditions — including account management, transaction processing, and KYC verification — is necessary for the performance of the contract between you and hot511.
• Legal obligation: Processing required for hot511 to comply with its obligations under its international operating licence, anti-money laundering (AML) regulations, and applicable financial crime prevention laws.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and aggregate analytics, where hot511's legitimate interests in maintaining a safe and fair platform outweigh any privacy impact on individual Members.
• Consent: Processing for non-essential cookies and marketing communications (where applicable) is conducted on the basis of your freely given, specific, and informed consent. You may withdraw consent at any time without detriment to your Account status.

6 Data Sharing

hot511 does not sell or rent your personal data to any third party. We share personal data only in the following strictly defined circumstances:

• Payment processors: We share the minimum necessary financial and identity data with our Indonesian banking partners (BCA, BRI, BNI, Mandiri, CIMB Niaga) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to process deposits and withdrawals on your behalf.
• KYC and identity verification providers: We share identity documents and data points with our licensed third-party KYC partners solely for the purpose of verifying your identity and assessing fraud or AML risk.
• Game content providers: Aggregated, non-personally-identifiable session data may be shared with licensed game studios (including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft) for game performance analytics and regulatory reporting.
• Technology infrastructure providers: Our hosting, content delivery network (CDN), and cybersecurity vendors may process technical data on our behalf as data processors under contracts that impose binding data protection obligations equivalent to those in this Policy.
• Regulatory and law enforcement authorities: We will disclose personal data to competent authorities where required by law, by court order, or by the instructions of our licensing regulator. In all such cases, disclosure is limited to the minimum data necessary to satisfy the specific legal requirement.

7 International Data Transfers

As an internationally licensed platform serving Members primarily in Indonesia, hot511 may transfer personal data to service providers and infrastructure partners located outside of Indonesia. Such transfers are necessary to deliver the global-standard gaming experience — including access to live dealer studios, real-time sportsbook data feeds, and 24/7 technical infrastructure — that hot511 provides.

Wherever personal data is transferred internationally, hot511 ensures that appropriate safeguards are in place, including:

• Standard contractual clauses (SCCs) with all data processors located outside the jurisdiction of our licensing authority, contractually binding them to data protection standards equivalent to those in this Policy;
• Transfer only to jurisdictions that our licensing authority has assessed as providing an adequate level of data protection;
• Technical safeguards — including end-to-end encryption in transit and at rest — that protect data regardless of the geographic location of the processing.

8 Cookies & Tracking Technologies

hot511 uses cookies and similar tracking technologies (including browser local storage and session storage) on the Platform. Cookies are small data files placed on your device that enable specific Platform functionality and help us understand how our users interact with the site.

You can manage your cookie preferences through your browser settings. Note that disabling cookies beyond the strictly necessary category may affect the performance and functionality of certain Platform features. hot511 does not deploy third-party advertising cookies or cross-site tracking pixels.

9 Data Retention

hot511 retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law and our licensing obligations. The following retention periods apply as a general guide:

• Active account data: Retained for the duration of your account's active status, plus a minimum of five (5) years following account closure, as required by our international AML compliance obligations.
• Transaction and financial records: Retained for a minimum of five (5) years following the date of the transaction, in compliance with financial record-keeping requirements under our operating licence.
• KYC documentation: Retained for a minimum of five (5) years following account closure or the completion of the last transaction to which the verification relates.
• Support communications: Retained for two (2) years from the date of the last communication, unless the communication relates to a formal complaint or legal matter, in which case it is retained for the duration of that matter plus two years.
• Technical / log data: Server logs and technical access records are retained for up to ninety (90) days unless flagged as relevant to a security investigation.

Upon expiry of the applicable retention period, personal data is securely and permanently deleted or anonymised in a manner that makes re-identification impossible.

10 Your Rights

As a hot511 Member, you hold the following rights in respect of the personal data we hold about you. To exercise any of these rights, please contact us at [email protected] with the subject line "Privacy — Data Request". We will respond to all verified requests within 30 calendar days.

11 Minors & Age Verification

The hot511 platform is strictly intended for adults aged 21 years and over. hot511 does not knowingly collect, process, or retain the personal data of individuals under the age of 21. This minimum age threshold applies to all Members regardless of their country of residence.

If hot511 discovers or has reasonable grounds to believe that personal data has been collected from an individual under the age of 21, we will:

• Immediately suspend the associated account and freeze all pending transactions;
• Delete or anonymise all personal data associated with that account as promptly as possible;
• Return any deposited funds (excluding winnings, which will be forfeited) via the original payment method after completing any legally required documentation.

12 Security Measures

hot511 employs a comprehensive, layered approach to data security designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security infrastructure includes the following measures:

• Transport Layer Security: All data exchanged between your device and our servers is encrypted in transit using TLS 1.2 or higher. Our SSL certificate is renewed and monitored continuously, and HTTP connections are automatically redirected to HTTPS.
• Encryption at Rest: Sensitive personal data stored in our databases — including identity documents, financial records, and KYC files — is encrypted at rest using AES-256 encryption. Password credentials are stored exclusively as salted cryptographic hashes and are never stored in plaintext.
• Access Controls: Access to personal data within hot511's internal systems is restricted on a strict need-to-know basis. All staff with access to personal data undergo mandatory data protection training, and access rights are reviewed and audited quarterly.
• Intrusion Detection & Monitoring: Our infrastructure is protected by real-time intrusion detection systems (IDS), distributed denial-of-service (DDoS) mitigation, and 24/7 security operations monitoring. Anomalous access patterns trigger automatic alerts and lockdown procedures.
• Third-Party Security Audits: hot511 engages independent cybersecurity firms to conduct penetration testing and vulnerability assessments on a regular basis. Critical vulnerabilities identified during these assessments are remediated within defined SLA windows.
• Data Breach Response: In the event of a personal data breach that poses a risk to Members, hot511 will notify affected Members and, where required by our licensing obligations, the relevant regulatory authority, within 72 hours of becoming aware of the breach. The notification will describe the nature of the breach, the data affected, and the steps we are taking to address it.

13 Changes to This Policy

hot511 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or our licensing obligations. When a material change is made, we will provide reasonable advance notice to active Members via email to their registered address and a prominent notice displayed on the Platform.

The effective date and version number displayed at the top of this page will be updated each time a new version of the Policy is published. We encourage all Members to review this Policy periodically. Your continued use of the Platform following the effective date of any update constitutes your acceptance of the revised Policy.

If you disagree with the terms of an updated Privacy Policy, you have the right to close your account and request deletion of your personal data prior to the effective date of the change, subject to our legal data retention obligations as described in Section 9.

14 Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by hot511, please contact our data protection team using the details below. Our support team is available 24 hours a day, 7 days a week, including all Indonesian public holidays such as Idul Fitri, Idul Adha, Indonesian Independence Day (17 August), Nyepi, and Waisak.

• Email: [email protected] — use the subject line "Privacy — Data Request" for data subject access requests, or "Privacy — Complaint" for privacy-related complaints. We acknowledge all privacy enquiries within 24 hours (WIB) and resolve them within 30 calendar days.
• Live Chat: Available directly within the Platform 24/7. Our support team includes native Indonesian-speaking agents who can assist you in Bahasa Indonesia upon request, even though the Platform itself operates in English.
• Response Commitment: Privacy-related requests receive prioritised handling. Initial acknowledgement is provided within 24 hours; substantive responses and data subject request fulfilment are completed within 30 calendar days of identity verification. Complex requests may require up to 60 days; you will be notified if this extension is needed.