Batman11 Privacy Policy – How We Protect Your Personal Data

This Privacy Policy applies to all users of the batman11 platform — covering the batman11.best website and the batman11 mobile app for Android and iOS. It sets out our privacy practices in full and forms part of the overall agreement between you and batman11, together with Terms & Conditions and Responsible Gaming Policy page.

1. Introduction & Scope of This Privacy Policy

Batman11 is an online Sports Betting and casino platform operating in Malaysia. As a data controller, batman11 takes full responsibility for protecting the personal data of all members who use our platform. We take this responsibility seriously — not merely to comply with the law, but because we genuinely believe that member trust is the most valuable asset we have.

This Privacy Policy is written in Bahasa Melayu to ensure it is accessible to all our Malaysian members without reliance on translation. It explains in plain language — not legal jargon — what happens to your data when you use batman11.

This policy applies to:

• All registered users of the batman11 platform.
• Visitors to batman11.best who have not yet registered as a member.
• Individuals who contact the batman11 support team via live chat or email.
• Anyone who interacts with batman11 through any of our official communication channels.

2. Personal Data We Collect

Batman11 follows a data minimisation principle — we only collect information that is strictly necessary for the stated purposes. The following are the main categories of data we may collect from you:

Information you provide directly to us:

• Full name as stated in your official Malaysian identification document.
• An active Malaysian phone number — used for OTP verification and important account-related communications.
• Date of birth — to confirm that you meet the minimum age requirement of 18 years to use the batman11 platform.
• Payment method details you have registered — such as your Touch 'n Go account name, DuitNow account number, or GrabPay account information. Batman11 does not store your payment method passwords or PINs.
• Correspondence with the batman11 support team — including live chat logs and emails sent to support@batman11.best.
• Identity verification documents such as a copy of your Malaysian identity card (MyKad) when required for the KYC process.

Data collected automatically when you use the platform:

• IP address and network information indicating your general location.
• Device information — including device type, operating system, browser version, and screen resolution.
• Platform usage data — pages visited, session duration, features used, and your navigation path within the batman11 app.
• Betting and game records — including selected markets, bet amounts, outcomes, and win/loss history.
• Login session data — including login times, logout times, and device switches.

3. How Batman11 Uses Your Data

The data we collect is used solely for purposes related to the operation of the batman11 platform and the delivery of services to you as a member. Specifically, batman11 uses your data to:

• Account management: Creating and maintaining your batman11 account, processing your registration, and managing secure login sessions.
• Financial transaction processing: Processing deposits made via Touch 'n Go eWallet, DuitNow, GrabPay, Boost, ShopeePay, and FPX — as well as handling withdrawal requests and ensuring funds are sent to the correct account.
• Provision of betting and gaming services: Recording and settling all bets, calculating winnings, and managing all technical aspects of your gaming experience.
• Identity verification and legal compliance: Fulfils the KYC (Know Your Customer) and AML (Anti-Money Laundering) requirements established under Malaysian law.
• Platform security and fraud detection: Monitoring suspicious activity, preventing unauthorised access, and protecting the integrity of the batman11 platform from misuse.
• Customer support: Enables the batman11 support team to assist you effectively when you contact us with an enquiry or issue.
• Service communications: Sending important account-related notifications such as deposit confirmations, withdrawal status updates, and security alerts.
• Platform improvements: Analyses aggregated, non-identifiable usage patterns to improve the design, performance, and features of the batman11 platform.
• Responsible gambling: Helps monitor gaming patterns that may indicate signs of problem gambling, and ensures that the limits you have set are properly enforced.

4. Legal Basis for Data Processing

Batman11 processes your personal data on the basis of one or more lawful grounds recognised under Malaysia's Personal Data Protection Act 2010 (PDPA):

• Consent: By registering as a batman11 member, you give your explicit consent for us to process your data for the purposes stated in this policy. You may withdraw that consent at any time by closing your account, though doing so will end your ability to use the batman11 platform.
• Contract performance: Data processing required to deliver the services you request — including bet processing and financial transactions — is based on the contractual agreement between you and batman11 as set out in our Terms & Conditions.
• Legal obligation: Certain data must be processed and retained by batman11 to fulfil legal obligations applicable in Malaysia, including AML, KYC, and financial record-keeping requirements.
• Legitimate interests: Batman11 may process certain data based on our legitimate interests — such as ensuring platform security and preventing fraud — provided those interests do not override your fundamental rights and freedoms as an individual.

5. Data Sharing with Third Parties

Batman11 does not sell or rent your personal data to any third party. However, to enable batman11 to deliver its services, certain data may need to be shared with selected categories of third parties. All such sharing is carried out under strict controls:

• Payment service providers: Data required to process transactions is shared with licensed payment gateway providers — including Touch 'n Go eWallet, DuitNow, GrabPay, Boost, ShopeePay, and FPX banks. All these providers are bound by strict confidentiality obligations and comply with recognised financial security standards.
• Software and game providers: To provide live casino, slots, and poker games, batman11 works with licensed game software providers. Only data strictly necessary for the delivery of these games is shared with them.
• Cloud and infrastructure service providers: Data is stored on servers managed by carefully vetted cloud infrastructure providers bound by comprehensive data protection agreements.
• Government authorities and law enforcement: batman11 may be required to disclose certain data to the relevant authorities when mandated by a court order, legal proceedings, or directives from a competent regulatory body in Malaysia.

6. Batman11 Data Security Measures

Batman11 continuously invests in comprehensive technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction:

Technical measures:

• 256-bit SSL/TLS encryption for all client-server communications — including all financial transactions and gaming sessions.
• Sensitive data is stored in encrypted form using industry-recognised encryption algorithms.
• Intrusion detection and prevention systems (IDS/IPS) that monitor network traffic around the clock.
• Two-factor authentication (2FA) is available to all members and is mandatory for high-risk operations such as large withdrawals.
• Network segmentation to ensure that servers storing sensitive data cannot be accessed directly from the public internet.
• Regular security audits conducted by qualified independent third parties.

Organisational measures:

• Access to member data is restricted to batman11 staff who require it to perform their job duties only — the principle of least privilege access.
• All batman11 staff who handle personal data are required to complete data protection training and are bound by legally enforceable confidentiality agreements.
• Clear incident response procedures are in place to handle any data breaches swiftly and effectively.

7. Data Retention & Deletion

Batman11 does not retain your data longer than necessary. Data retention periods are determined based on the purpose of collection and applicable legal requirements:

• Active account data: Retained for as long as your account remains active and in operation on batman11.
• Financial records and transaction data: Retained for the minimum period required under applicable Malaysian laws governing financial records and AML compliance — typically no less than seven (7) years from the date of the transaction.
• Customer support communication data: Live chat logs and support emails are retained for three (3) years for reference and dispute resolution purposes.
• Technical data and system logs: Technical logs are typically retained for 90 days for security and fraud detection purposes.

When you request the closure of your batman11 account, all active account data will be anonymised or deleted within a reasonable timeframe — except for data that batman11 is legally obligated to retain, such as financial transaction records.

8. Cookies & Tracking Technologies

Batman11 uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device when you visit the batman11 website or use the app.

Types of cookies we use:

• Essential cookies (strictly necessary): Required for core batman11 platform functionality — including login sessions and security. Cannot be disabled without affecting platform functionality.
• User preference cookies: Saves your display preferences such as language, theme, and other settings so you do not need to reconfigure them each time you log in.
• Analytics cookies: Used to understand how users interact with the batman11 platform in aggregate — helping us identify areas for improvement. This data cannot be used to identify any individual personally.
• Security cookies: Helping detect suspicious activity, prevent fraud, and ensure the security of your login sessions.

You can manage your cookie settings through your web browser. Most modern browsers let you view, delete, and block cookies from specific websites. Please note that disabling essential cookies will affect the functionality of the batman11 platform and may prevent you from logging in or making transactions.

9. Your Rights as a Data Subject

Under Malaysia's Personal Data Protection Act 2010 (PDPA), you as a data subject have the following rights regarding your personal data held by batman11. Batman11 is committed to helping you exercise these rights efficiently and without unnecessary obstacles:

• Right of Access: You have the right to request a copy of the personal data we hold about you. Access requests will be processed within 14 business days.
• Right to Rectification: If you find that the personal data we hold about you is inaccurate or incomplete, you have the right to request a correction and we will update it promptly.
• Right to Withdraw Consent: You may withdraw the consent you have given batman11 to process your data at any time. Withdrawing consent will mean you are no longer able to use the batman11 platform.
• Right to Erasure: Under certain circumstances, you have the right to request the deletion of your personal data from batman11's systems, subject to batman11's legal obligations to retain specific data.
• Right to Object to Processing: You have the right to object to the processing of your data in certain circumstances, particularly where processing is based on batman11's legitimate interests.
• Right to Lodge a Complaint: If you believe that batman11 has processed your data unlawfully or in breach of the PDPA, you have the right to lodge a complaint with the Personal Data Protection Commissioner of Malaysia.

10. Amendments to This Privacy Policy

Batman11 reserves the right to amend or update this Privacy Policy from time to time to reflect changes in our privacy practices, legislation, or how we handle data. The date of the most recent update will always be displayed at the top of this document.

For material amendments — meaning changes that significantly affect how we use your data or your rights — batman11 will endeavour to provide reasonable advance notice via in-platform notifications or email to affected members.

It is your responsibility as a member to review this Privacy Policy periodically. Continued use of the batman11 platform after any amendment is published will be considered your acceptance of the latest version of the policy.

11. Contact Batman11's Privacy Officer

If you have any questions, concerns, or complaints regarding this Privacy Policy or how batman11 handles your personal data, please contact us through the following channels:

• Privacy Email: support@batman11.best — for specific privacy enquiries and data rights requests. Please include "Privacy Request" in the subject line of your email.
• Live Chat: Available directly within the batman11 platform — log in to your account and click the support icon. For privacy-related matters, ask to be connected with our compliance team.

Our team is committed to handling every privacy inquiry seriously, professionally, and within a reasonable timeframe. Complete data rights requests will be processed within 14 business days from the date a fully completed request is received.

For information on responsible gaming and the limit-setting tools available at batman11, please visit our Responsible Gaming page. For general questions about the batman11 platform, please refer to our FAQ first.