Batman 11 Privacy Policy – Data Protection Malaysian Members We Take Seriously

Batman 11 is an online casino and Sports Betting platform built specifically for Malaysians. As a platform that places member trust above all else, batman 11 takes our responsibility to protect the privacy and personal data of every individual who uses our services very seriously.

This Privacy Policy is written in plain language and designed to be easily understood by Malaysian users — not a legal document packed with confusing technical jargon. We want you to genuinely understand what we do with your data, why we need it, and what rights you have over it.

Batman 11 operates in compliance with Malaysia's Personal Data Protection Act 2010 (PDPA) and all applicable legislation in force in Malaysia. We take a privacy-by-design approach to building our platform — meaning data protection is not something we add on later, but something built into every feature and function of batman 11 from the ground up.

Batman 11 collects personal data from members through several channels — during account registration, during platform use, during financial transactions, and through interactions with our customer support team. Below is a summary of the types of data we collect and why:

Batman 11 only collects data that is genuinely necessary to provide services to you. We do not collect irrelevant or excessive information beyond what is required for the stated purposes.

Personal data we collect from batman 11 members is used solely for the following purposes. We do not use your data for anything outside of what is stated here without first obtaining fresh consent from you:

• Account management: Registering your account, verifying your identity at login, and processing withdrawal requests to your Touch 'n Go, DuitNow, GrabPay, Boost, ShopeePay, or FPX bank account in Malaysian Ringgit (MYR).
• KYC & anti-fraud compliance: Verifying that you meet the minimum age requirement of 18, and detecting and preventing fraudulent activity, multi-account use, and money laundering.
• Service provision: Enables you to play slots, baccarat, Live Casino, Sports Betting (EPL, Liga Super Malaysia, badminton, cricket, e-sports), and all other games on the batman 11 platform.
• Customer support: Responding to enquiries and resolving issues you raise via live chat or email in Bahasa Melayu.
• Essential communications: Sending notifications related to account security, transaction confirmations, and changes to batman 11's Terms & Conditions or Privacy Policy.
• Responsible gaming: Monitoring gameplay patterns to identify potential problem gambling and notifying members who may need support, in line with batman 11's commitment to member wellbeing.
• Marketing (with your consent only): Sending promotions, special bonuses for Hari Raya Aidilfitri, Chinese New Year, Deepavali, and personalised offers — only if you have given consent to receive marketing communications.
• Platform improvements: Analysing usage data in aggregate and anonymised form to understand how members use the batman 11 platform and to make relevant improvements.

Batman 11 processes members' personal data on valid legal grounds under Malaysia's Personal Data Protection Act 2010 (PDPA). We rely on several legal bases depending on the nature of the processing carried out:

• Contract performance: Data processing required to fulfill the service agreement between you and batman 11 — including managing your account, processing deposits and withdrawals in MYR, and providing access to games.
• Legal compliance: Processing required to fulfil legal obligations such as KYC requirements, anti-money laundering prevention, and compliance with financial regulations in force in Malaysia.
• Legitimate interests: Processing for the purposes of platform security, fraud detection, and the protection of batman 11's legitimate rights — provided these interests do not override your fundamental rights.
• Your consent: For marketing communications and opt-in purposes that require your explicit consent — you have the right to withdraw that consent at any time.

Batman 11 does not sell, rent, or trade members' personal data to any third party for their own marketing purposes. This is a core commitment we hold firm. That said, there are specific situations where batman 11 needs to share data with certain parties in order for the platform to function:

• Licensed payment providers: Required transaction data is shared with licensed Malaysian payment gateways including Touch 'n Go, DuitNow, GrabPay, Boost, ShopeePay, and the FPX network to process your deposits and withdrawals in Malaysian Ringgit (MYR). These providers maintain their own privacy policies and are subject to Bank Negara Malaysia regulations.
• Game provider: Minimal game data (such as player ID and bet amount) is shared with game providers including Evolution Gaming, Pragmatic Play, SA Gaming, and Ezugi to enable you to play their games on the batman 11 platform. This data does not include your full identity information.
• Cloud storage & infrastructure services: Batman 11 uses secure cloud infrastructure providers to store platform data. All such providers are bound by strict data processing agreements and are not permitted to use your data for any other purpose.
• Legal authorities: Where batman 11 is required by Malaysian law or a valid court order to disclose information to law enforcement agencies or regulatory bodies, we will comply with those obligations.
• Professional advisors: In cases of legal dispute or audit, data may be shared with legal counsel or accountants who are bound by professional confidentiality obligations.

All third parties that receive data from batman 11 are required to handle it in accordance with strict security and confidentiality standards, and are not permitted to use it for any purpose other than what has been agreed upon.

Batman 11 continually invests in cybersecurity infrastructure to ensure member personal data is protected to the highest achievable standard. Security is not something we treat lightly — it is the foundation of trust that underpins the entire relationship between batman 11 and its members.

The technical and organisational security measures we have implemented include:

• 256-bit SSL Encryption: All communications between your device and batman 11's servers are protected with 256-bit SSL encryption — the same standard used by Maybank, CIMB, and Malaysia's major banks to secure online banking transactions.
• Data-at-rest encryption: Sensitive data stored in batman 11's databases is encrypted using strong encryption algorithms, meaning that even if someone gains unauthorised access to the database, the data cannot be read without the encryption key.
• 24/7 threat monitoring: Our intrusion detection and cyber threat monitoring systems operate around the clock to detect and block any unauthorised access attempts before they can affect member data.
• Data segregation: Payment system data is kept separate from game data and member profile data across distinct infrastructure environments to minimise the risk of any security incident.
• Internal access controls: Only batman 11 staff who require access to specific data in order to perform their duties are permitted to do so — a strict need-to-know principle is enforced at every level of the organisation.
• Regular security testing: Batman 11 conducts regular penetration testing and security audits by independent security experts to identify and address vulnerabilities before they can be exploited.

Batman 11 does not store your personal data indefinitely. We retain data only for as long as necessary for the purposes described in this Privacy Policy or as required by applicable Malaysian law.

• Active account data: For as long as your account remains active on batman 11, plus a reasonable period after account closure to allow for the resolution of any outstanding claims or disputes.
• Financial transaction records (RM deposits and withdrawals): Minimum 7 years from the date of the transaction — this is a legal requirement under Malaysia's Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001.
• KYC records (MyKad copies and verification documents): Minimum 5 years after the business relationship ends or 5 years from the date the document was received, whichever is later — in line with Malaysia's AML/CFT compliance requirements.
• Customer support communication logs: 3 years from the date of interaction, for quality control and dispute resolution purposes.
• Usage data and technical logs: 12 months in detailed form; aggregated and anonymised data may be retained longer for platform analytics purposes.
• Marketing data (with your consent): Until you withdraw your consent to receive marketing communications from batman 11.

Once the relevant retention period has ended, batman 11 will securely delete or anonymise the data so that it can no longer be linked to your identity.

The batman 11 platform uses cookies and similar tracking technologies to enhance the user experience, ensure platform security, and understand how members use our services. The following are the types of cookies we use:

You can manage cookie settings through your web browser. However, disabling essential cookies may affect your ability to use certain features on the batman 11 platform properly.

Under Malaysia's Personal Data Protection Act 2010 (PDPA) and batman 11's internal policies, you have the following rights regarding your personal data held by us. Batman 11 is committed to making it easy for you to exercise these rights:

The batman 11 platform is strictly for individuals aged 18 and above. Batman 11 does not knowingly collect, process, or store the personal data of anyone under the age of 18. This is not merely a business policy — it is our moral and legal commitment to protecting young people in Malaysia.

Should batman 11 discover that personal data has been collected from an individual under the age of 18 without our knowledge, we will take the following steps immediately:

• Close the relevant account immediately
• Deleting all personal data associated with that individual
• Returning any remaining account balance to the original deposit source
• Taking additional preventive measures to avoid similar incidents in the future

If you suspect that an individual under the age of 18 may be using the batman 11 platform, please report it to us immediately via email at support@batman11.asia or through live chat. We will investigate every report thoroughly and take appropriate action.

Batman 11 reserves the right to amend or update this Privacy Policy from time to time to reflect changes in our privacy practices, new legal requirements, or improvements to how we serve our Malaysian members.

When we make significant amendments to this Privacy Policy, we will:

• Updating the "Last updated" date at the top of this page
• Sending email notifications to all registered members outlining the key changes
• Displaying a clear notice within the batman 11 platform for at least 14 days before the amendment takes effect
• For highly material amendments, we may seek fresh consent from you before continuing to process your data

Your continued use of the batman 11 platform after the effective date of any amended Privacy Policy constitutes your acceptance of the updated policy. We encourage you to review this page periodically.

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, please contact us through the following channels:

• Privacy Email: support@batman11.asia — include "Privacy Enquiry" in your email subject line for faster processing. Response time within 24 hours on business days.
• 24/7 Live Chat: Access live chat directly from the batman 11 platform. Our support team operates in Bahasa Melayu and is available at all times, including weekends and Malaysian public holidays.

Batman 11 is committed to addressing every privacy enquiry seriously and providing clear responses within a reasonable timeframe. If you are not satisfied with our response, you have the right to lodge a complaint with the Department of Personal Data Protection (JPDP) Malaysia, the regulatory body for PDPA in Malaysia.