Privacy Policy
This policy explains what personal data Federico Mancuso, an individual resident in Panama ("we", "us") collects through the Hot Tottie website, application form and membership, why we use it, and the rights you have. We are the data controller. Contact: [email protected].
1. Data we collect
- Application data: the information you enter in our application form, which is hosted by Google Forms (for example name, email, country, Discord username, trading background, and your answers), and anything you tell us on a screening call. No payment details are collected at this stage.
- Membership and billing data: your name, email, billing country and subscription status. Payments are handled by Whop, the merchant of record. When you pay, Whop collects and processes your card and billing details under its own privacy policy. We receive your name, email, country and subscription status, never full card numbers.
- Community data: your username, profile and the messages and content you post in the Club's private channels (hosted on Discord), and your participation in live calls (which may be recorded only with notice). Community conversations are private to members, but they are visible to our administrators and moderators and are processed by Discord.
- Access records: because we grant and remove access to the Discord server manually, we keep a membership record with your name, email, Discord username, and start and renewal dates.
- Communications: emails and messages you send us.
- Technical data: basic server logs (IP address, browser, pages requested) created when you visit the website. The website is hosted by Cloudflare, which processes this data to deliver and protect the site. We do not use analytics or advertising tools, and we do not use any data for marketing.
2. Why we use it and our legal bases
- To review applications and run screening calls, to take steps at your request before a contract (GDPR Art. 6(1)(b)) and our legitimate interest in admitting suitable members.
- To provide membership, take payment and manage your subscription: contract performance.
- To keep the community safe, enforce our Terms and prevent fraud: legitimate interests.
- To meet tax, accounting and legal obligations, including working out which taxes apply based on your country: legal obligation.
- To email you service messages about your membership: contract and legitimate interests. We only send marketing with your consent where required.
3. Who we share data with
We do not sell your personal data. We share it only with service providers that help us run the Club, acting on our instructions, such as: Whop (payments, acting as merchant of record and an independent controller of your payment data), Google (application form, email and calendar), Discord (community), Cloudflare (website hosting), and our accountants and professional advisers. We may also disclose data where required by law or to protect our rights.
Other members can see the username, profile and content you choose to share inside the Club.
4. International transfers
Some providers are based outside your country, including in the United States. Where required, transfers rely on appropriate safeguards such as the EU Standard Contractual Clauses or an adequacy decision.
5. How long we keep it
- Applications that are not accepted: up to 12 months.
- Member data: for the duration of membership and up to 24 months afterwards, unless you ask us to delete it sooner.
- Billing and tax records: as long as the law requires (typically 6 to 10 years).
6. Your rights
Depending on where you live, you may have the right to access, correct, delete, restrict or object to our use of your data, to data portability, and to withdraw consent at any time. To exercise a right, email [email protected]. You also have the right to complain to your local data-protection authority. We will respond within one month.
7. Cookies and fonts
The website loads fonts from Google Fonts, which means your IP address is sent to Google when the page loads. We do not use advertising cookies. We do not use analytics cookies either.
8. Security
We use reasonable technical and organisational measures to protect your data, but no system is perfectly secure.
9. Children
The Club is for adults only (18+). We do not knowingly collect data from anyone under 18.
10. Changes
We may update this policy and will change the date above when we do. For material changes we will notify members.
11. Contact
Federico Mancuso
Panama City, Panama
[email protected]