Batman 11 Privacy Policy — How We Protect the Personal Data of Malaysian Members

Introduction — Batman 11's Commitment to Your Privacy

Batman 11 is an online betting platform built and operated specifically for Malaysian players. As part of our commitment to being a trustworthy platform, we take the privacy and security of our members' personal data extremely seriously.

This Privacy Policy explains in detail how Batman 11 collects, uses, stores, protects and, in certain situations, discloses your personal information when you register and use our platform. This document forms part of a broader agreement between you and Batman 11, which also includes our Terms & Conditions and Responsible Gambling documentation.

By registering an account or using any part of the Batman 11 platform, you acknowledge that you have read and understood this Privacy Policy and agree to the processing of your personal information as described herein. If you do not agree with any part of this policy, please do not use the Batman 11 platform.

Types of Personal Data We Collect

Batman 11 collects various types of personal information across different contexts. Below is a detailed explanation of the data we collect and how it is collected:

A. Data You Provide Directly

• Registration Information: Your full name, date of birth, identity card number (MyKad), mobile phone number, and email address as provided when registering your Batman 11 account.
• Identity Verification Information: A copy of your MyKad, passport, or other identification document that we may request for age and identity verification purposes, particularly prior to processing your first withdrawal or when required by compliance obligations.
• Financial Information: E-wallet account details (Touch 'n Go eWallet, GrabPay, Boost, ShopeePay), DuitNow information, and FPX account details used for deposits and withdrawals. Batman 11 does not store credit or debit card numbers directly — transactions are processed through PCI DSS-certified third-party payment processors.
• Communication with Support: Your live chat history, emails, and other interactions with the Batman 11 support team.

B. Automatically Collected Data

• Platform Usage Data: Betting records, game history, deposit and withdrawal transactions, and all activity within your Batman 11 account.
• Technical Data: IP address, browser type, operating system, device type, screen resolution, and other technical information automatically logged when you access the platform.
• Cookie Data: Session information, user preferences, and tracking data collected through cookies and similar technologies. Please refer to Section 6 for more details on how Batman 11 uses cookies.
• Location Data: General location information derived from your IP address for compliance and security purposes. Batman 11 does not collect precise location data (GPS) without your explicit consent.

How Batman 11 Uses Your Personal Data

Batman 11 uses the personal data collected for the following purposes:

• Account Management: Creating and managing your Batman 11 account, processing your registration, verifying your identity, and maintaining the security of your account.
• Transaction Processing: Processing deposits made via Touch 'n Go eWallet, DuitNow, GrabPay, Boost, ShopeePay or FPX, as well as processing your withdrawal requests in Malaysian Ringgit (MYR).
• Service Delivery: Gives you access to all Batman 11 services, including slots, football and badminton Sports Betting, live matches, lottery, and other platform features.
• Security & Fraud Prevention: Detecting and preventing fraud, money laundering, the use of multiple accounts and any activity that violates Batman 11's Terms & Conditions.
• Legal Compliance: Fulfilling legal obligations including Know Your Customer (KYC), Anti-Money Laundering (AML) and other relevant compliance requirements.
• Service Communications: Sending important account-related notifications, including transaction confirmations, security updates, policy changes, and relevant betting information.
• Platform Improvements: Analysing usage data in aggregate (without identifying individuals) to understand how users interact with the Batman 11 platform and make ongoing improvements to the user experience.
• Customer Support: Providing assistance and resolving issues reported by members through Batman 11's support channels.

Data Sharing with Third Parties

Batman 11 does not sell your personal data. However, in the course of operating the platform and meeting our legal obligations, we may share your personal data with the following parties under limited and controlled circumstances:

• Payment Processors: Batman 11 works with local Malaysian payment processors who handle your transactions via Touch 'n Go eWallet, DuitNow, GrabPay, Boost, ShopeePay, and FPX. These processors receive only the data required to complete the relevant transaction and are bound by strict confidentiality agreements.
• Game Software Providers: Slot and Live Casino game providers that partner with Batman 11 may receive the session identifiers required to run the games. They do not receive your full personal identification details.
• Technology Service Providers: Cloud infrastructure, hosting, and cybersecurity providers that support the operation of the Batman 11 platform may have limited access to data in the course of performing their technical work. All such parties are bound by strict data protection agreements.
• Legal Authorities: Batman 11 will disclose personal information to law enforcement, regulatory bodies, or government agencies when required to do so by law or a valid court order, or when we believe disclosure is necessary to prevent crime or protect public safety.

In all of the data-sharing cases described above, Batman 11 ensures that the receiving parties are bound by appropriate data protection obligations and use the data solely for the stated purposes. Batman 11 does not share your personal data with advertisers, marketing companies, or any third parties not listed above.

Data Security Measures at Batman 11

Batman 11 continuously invests in security infrastructure and procedures to ensure your personal data is protected against unauthorised access, disclosure, alteration, or destruction.

The technical security measures we have in place include:

• 256-bit SSL/TLS Encryption: All communications between your browser or app and Batman 11's servers are encrypted using 256-bit SSL/TLS protocols. This ensures that data in transit — including login credentials, payment details, and personal information — cannot be intercepted or read by unauthorised parties.
• Stored Data Encryption: Sensitive data stored in Batman 11's databases, including passwords and financial information, is encrypted using robust encryption algorithms. Passwords are stored in hashed form and are never saved as plain text.
• Internal Access Controls: Access to member personal data by Batman 11 staff is restricted on a least-privilege basis — staff may only access data that is necessary to carry out their legitimate job responsibilities.
• Continuous Security Monitoring: Batman 11's systems are monitored around the clock to detect any anomalies, unauthorised access attempts or suspicious activity. Our security team responds promptly to any identified threats.
• Regular Security Audits: Batman 11 conducts regular penetration testing and vulnerability assessments by independent security experts to identify and address potential weaknesses before they can be exploited.

While Batman 11 takes all reasonable steps to protect your data, no online security system can guarantee absolute 100% security. You also play an important role in protecting your account by using a strong password, keeping it confidential, and promptly reporting any suspicious activity to the Batman 11 support team.

Cookies & Tracking Technologies

Batman 11 uses cookies and similar technologies to enhance the user experience, maintain platform security, and understand how users interact with our platform.

Types of Cookies We Use

• Essential Cookies: These cookies are required for the core functions of the Batman 11 platform, including maintaining your login session, keeping your account secure, and enabling essential platform features to work correctly. They cannot be disabled, as the platform will not function without them.
• Performance Cookies: These cookies help us understand how users interact with the Batman 11 platform — which pages are visited most often, how long users spend on the platform, and where users encounter difficulties. This information is used to make ongoing improvements to the platform.
• Functional Cookies: These cookies allow the platform to remember your preferences and settings, such as your interface language and display preferences, so you do not need to reconfigure them each time you visit Batman 11.
• Security Cookies: Batman 11 uses dedicated cookies to detect and prevent fraudulent activity, bot usage, and other security threats to the platform and member accounts.

You can manage your cookie settings through your web browser's options. However, disabling certain cookies may affect Batman 11's platform functionality and your overall user experience. We recommend enabling essential cookies to ensure the best possible experience.

Data Retention Period

Batman 11 retains your personal data only for as long as necessary to fulfil the original purpose of collection, or as required by applicable law. The following is a general guide to our data retention periods:

• Active Account Data: As long as your Batman 11 account remains active, we retain all data associated with it, including registration details, betting history, and transaction records.
• After Account Closure: When an account is closed at your request or at Batman 11's discretion, we will retain financial transaction records and account activity for the period required under Malaysian financial and anti-money laundering laws, which is generally seven (7) years.
• Identity Verification Data: Identity verification documents such as copies of MyKad are retained for the period required for KYC compliance purposes and as mandated by applicable law.
• Support Communication Logs: Customer support interaction history is retained for three (3) years after the last interaction for reference and dispute resolution purposes.
• Marketing Data: If you have given consent to receive marketing communications, the relevant data will be retained until you withdraw that consent.

Once the relevant retention period has expired, Batman 11 will securely delete or anonymise your personal data using methods that ensure it cannot be recovered.

Your Rights as a Data Subject

Batman 11 respects your rights as a data subject under Malaysia's Personal Data Protection Act 2010 (PDPA) and our own privacy policy. The following are the rights you hold in relation to your personal data at Batman 11:

To exercise any of the rights listed above, please contact Batman 11's support team by email at support@batman11.site, clearly stating the right you wish to exercise and providing sufficient information for us to verify your identity before processing your request.

Children's Data Protection

Batman 11 is an online betting platform intended exclusively for individuals aged 18 and above. We do not knowingly collect or process personal data from individuals under the age of 18.

If we discover that someone under the age of 18 has registered an account on Batman 11 or provided us with their personal data, we will immediately take the following steps:

• Suspending and terminating the account in question immediately.
• Permanently deleting all personal data relating to the minor from our systems.
• Returning any deposited funds where applicable, via an appropriate method.

If you have reason to believe that someone under the age of 18 has used the Batman 11 platform, please contact our support team immediately at support@batman11.site so that we can take the appropriate action.

Changes to Batman 11's Privacy Policy

Batman 11 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our privacy practices, new legal requirements, or developments in the services we offer.

When significant changes are made to this Privacy Policy, Batman 11 will take the following steps to ensure you are informed:

• Updating the "Last Updated" date displayed at the top of this page.
• Publishing a notice about significant changes on the platform's homepage or via in-account notifications.
• For significant changes that materially affect your privacy rights, Batman 11 will send a direct notice to the email address registered on your account.

Your continued use of the Batman 11 platform after a revised Privacy Policy is published constitutes your acceptance of the latest version. If you do not agree with the changes made, you have the right to close your Batman 11 account.

Contact Batman 11 for Privacy Enquiries

If you have any questions, concerns or complaints regarding how Batman 11 handles your personal data, or if you wish to exercise any of your privacy rights outlined in Section 8, please contact us through the following channels:

• Privacy Email: support@batman11.site — please include "Privacy Enquiry" in the subject line of your email.
• Live Chat: Available directly within the Batman 11 platform at all times — 24 hours a day, 7 days a week, in Bahasa Malaysia.

Batman 11 is committed to addressing all privacy-related enquiries seriously and within a reasonable timeframe. For formal data access or data deletion requests, we will process them within 21 business days from the date the request is received.