Privacy Policy

This Privacy Policy explains how Milky Wei Games Inc., an Ontario, Canada corporation operating the Hotpipe platform (“Hotpipe,” “we,” “us,” or “our”), collects, uses, and shares information when you use our website, application, and related SaaS services (the “Platform”). By using the Platform, you agree to this Policy and our Terms of Service.

Hotpipe is a trading-automation SaaS product. We are not a registered investment adviser or broker-dealer, and we do not use your information to provide personalized investment advice or to make trading decisions on your behalf.

1. Information we collect

Account and contact information

When you register or sign in, we collect information such as your email address and authentication-related data (for example, one-time codes and session data).

Broker and trading configuration

If you connect a brokerage account supported on the Platform, we process connection metadata and credentials or tokens required to communicate with that broker on your behalf, account identifiers you authorize us to see, and the webhook sources, transforms, trade rules, and order records you create or that result from your rules.

Webhook and event data

When a source posts to your inbound URL, we receive the payload you configure that source to send. That may include symbols, prices, strategy names, or other fields you choose to include. You control what third parties send to Hotpipe.

Billing and subscription information

If you subscribe to a paid plan, we process billing-related information such as plan selection, subscription status, and payment outcomes. Card payments are handled by our payment processor; Hotpipe does not store full payment card numbers.

Usage and technical data

We may collect IP address, device/browser information, timestamps, and logs related to API requests, authentication, errors, and security events, to operate and protect the Platform.

Cookies and similar technologies

We use cookies and similar technologies that are necessary to operate the Platform. In particular, after you sign in we set secure, HttpOnly session cookies so the browser can keep you authenticated. These cookies are used for authentication and security — not for third-party advertising. You can block or delete cookies in your browser, but doing so will prevent sign-in and other authenticated features from working.

We do not currently use third-party advertising or cross-site tracking cookies on the Platform. If that changes, we will update this Policy.

2. How we use information

We use information to:

• provide, maintain, secure, and improve the Platform as SaaS;
• authenticate you, secure accounts, and prevent abuse or fraud;
• run the automation you configure (including transmitting order instructions to brokers you connect);
• manage subscriptions, billing, plan limits, and related notices;
• communicate service notices and respond to support requests;
• analyze aggregated or de-identified usage to improve reliability;
• comply with law and enforce our Terms.

We do not sell your personal information. We do not use your trading configuration to give you investment recommendations.

3. How we share information

We may share information with:

• Brokers and integrations you connect — as needed to authenticate and place or manage orders according to your rules;
• Service providers that help us operate the Platform, such as cloud hosting, databases, content delivery and DNS, source control and deployment, transactional email, monitoring, and payment processing. These providers process data on our behalf under obligations to protect it, and receive only what is needed for their function;
• Legal and safety recipients when required by law, regulation, legal process, or to protect rights, safety, and security;
• Business transfers in connection with a merger, acquisition, financing, or sale of assets, subject to appropriate confidentiality.

Webhook providers (such as charting platforms) send data directly to URLs you configure; their privacy practices are governed by their own policies. Brokers and payment processors also have their own privacy policies for data they hold independently.

4. Retention

We retain account, configuration, event, order-related, and billing records for as long as your account is active and as needed to provide the Platform, resolve disputes, enforce agreements, and meet legal, tax, and accounting obligations. You may request deletion of your account; some records may remain in backups or logs for a limited period, and we may retain information when required by law (for example, certain billing records).

5. Security

We use administrative, technical, and organizational measures appropriate to the nature of the Platform — including encryption in transit, application-layer protection of broker credentials, and access controls scoped to your account. No method of transmission or storage is completely secure. You are responsible for protecting access to your email, devices, and brokerage credentials, and for reviewing activity in your brokerage account. See our Security page for a summary of our approach.

6. Your choices

• Update or correct account email/contact details through the product flows we provide.
• Disconnect brokerage connections and delete webhook sources or trade rules you no longer need.
• Manage or cancel a paid subscription through the billing flows we provide or by contacting us.
• Request account deletion or access to your personal information by contacting us at the email below (subject to verification and legal exceptions).

7. Children

The Platform is not directed to individuals under 18. We do not knowingly collect personal information from children. If you believe a child has provided us information, contact us and we will take appropriate steps.

8. International users

We are based in Ontario, Canada, and may process information in Canada, the United States, and other countries where we or our service providers operate. If you access the Platform from another jurisdiction, you understand that your information may be transferred to and processed in jurisdictions with different data protection laws.

9. Additional rights in certain jurisdictions

Quebec (Law 25)

If you reside in Quebec, the person in charge of the protection of personal information at Hotpipe is our Privacy Officer, reachable at [email protected]. You have the right to request access to and rectification of your personal information, to withdraw consent to its use or disclosure (subject to legal and contractual restrictions), and to ask that we cease disseminating it in certain circumstances. If you are not satisfied with our response to a privacy request, you may file a complaint with the Commission d'accès à l'information du Québec.

European Economic Area, United Kingdom, and Switzerland (GDPR)

If the EU or UK General Data Protection Regulation or the Swiss Federal Act on Data Protection applies to our processing of your personal data, Milky Wei Games Inc. is the data controller. We process personal data on the following legal bases: performance of our contract with you (operating your account and the automation you configure), legitimate interests (securing and improving the Platform, preventing abuse), compliance with legal obligations, and consent where we ask for it. You have the right to request access to, rectification or erasure of, or a portable copy of your personal data; to restrict or object to certain processing; and to withdraw consent at any time without affecting prior processing. You may also lodge a complaint with your local supervisory authority. Where we transfer personal data outside your jurisdiction (including to Canada and the United States), we rely on applicable safeguards such as adequacy decisions or standard contractual clauses. Canada has been recognized by the European Commission as providing adequate protection for data transferred to organizations subject to PIPEDA.

To exercise any of these rights, contact us at [email protected]. We will verify your request and respond within the timelines required by applicable law.

10. Changes

We may update this Privacy Policy from time to time. We will post the revised Policy with an updated “Last updated” date. If changes are material, we may also provide additional notice (for example, by email or an in-product notice). Continued use of the Platform after changes take effect constitutes acceptance of the revised Policy, except where applicable law requires a different process.

11. Contact

Privacy questions or requests go to our Privacy Officer, who is accountable for Hotpipe's compliance with applicable privacy law: [email protected]. You may also contact us to access or correct your personal information, as provided under applicable Canadian privacy law.