Privacy Policy

This Privacy Policy (hereinafter the "Policy") sets out how Batman11 (hereinafter "Batman11", "we", "us", or "our") collects, processes, stores, and protects personal data in connection with your use of the website https://batman11.cam (the "Platform") and all related services offered therein.

Batman11 is the data controller responsible for your personal data. We are committed to processing personal data in a lawful, fair, and transparent manner, consistent with applicable data protection legislation and internationally recognised privacy standards.

By registering an account, accessing the Platform, or using any of our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, you must discontinue your use of the Platform immediately.

For the purposes of this Privacy Policy, the following terms shall have the meanings set out below:

• "Personal Data" — any information that identifies or is capable of identifying a natural person, including but not limited to name, email address, date of birth, identity document number, IP address, and payment account details.
• "Processing" — any operation or set of operations performed on personal data, including collection, storage, use, disclosure, alteration, and deletion.
• "Data Controller" — the entity that determines the purposes and means of processing personal data. Batman11 acts as Data Controller for personal data collected via the Platform.
• "Data Processor" — a third party that processes personal data on behalf of Batman11 under a data processing agreement, such as a KYC verification provider or payment gateway.
• "Consent" — a freely given, specific, informed, and unambiguous indication of the User's wishes by which they signify agreement to the processing of personal data relating to them.
• "Cookie" — a small text file placed on a User's device by the Platform for the purposes of session management, analytics, and functionality enhancement.
• "KYC" — Know Your Customer; the identity and address verification process required for regulatory compliance and fraud prevention.

Batman11 collects personal data from you in three ways: directly from you when you interact with the Platform, automatically as a result of your use of the Platform, and from third-party service providers engaged to support our operations.

When you access and use the Batman11 Platform, certain data is collected automatically through technical systems including cookies, log files, and analytics tools:

• Device & Technical Data: IP address, browser type and version, operating system, device type, screen resolution, and network provider.
• Usage Data: Pages visited, time spent on each page, click patterns, navigation paths, game sessions initiated, bets placed, and features accessed.
• Session Data: Login timestamps, session duration, logout events, and concurrent session detection data.
• Geolocation Data: Approximate geographic location derived from IP address, used for regulatory compliance and fraud detection purposes.

Batman11 may receive supplementary personal data from third parties in specific circumstances:

• KYC Providers: Identity verification results, document authenticity assessments, and politically exposed persons (PEP) or sanctions screening outcomes.
• Payment Processors: Transaction confirmations, chargeback notifications, and fraud screening results from payment gateways including DuitNow and FPX.
• Fraud Prevention Services: Risk scores and behavioural pattern analysis from anti-fraud tools used protect the Platform and its Users.

Batman11 processes your personal data for the following specific and legitimate purposes:

• Account Creation and Management: To register your account, verify your identity, maintain account records, and provide you with access to all Platform features.
• Transaction Processing: To process deposits and withdrawals via Malaysian payment methods including Touch 'n Go eWallet, Boost, GrabPay, Maybank FPX, DuitNow, and others, and to maintain accurate transaction records.
• Regulatory Compliance: To fulfil our obligations under applicable anti-money laundering (AML), counter-terrorism financing (CTF), and KYC regulations, including reporting obligations to relevant authorities.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent transactions, account takeovers, collusion, and other forms of financial crime or platform abuse.
• Customer Support: To respond to your enquiries, process complaints, and provide assistance via Live Chat, email, or other support channels.
• Platform Improvement: To analyse usage patterns, conduct A/B testing, and improve the functionality, performance, and security of the Platform based on aggregated and anonymised data insights.
• Responsible Gambling: To monitor player behaviour for indicators of problem gambling and to apply or communicate responsible gambling tools where appropriate, in furtherance of player protection obligations.
• Marketing Communications: To send you promotional offers, bonus notifications, and product updates where you have opted in to receive such communications. You may withdraw consent for marketing communications at any time.

Batman11 processes your personal data one or more of the following legal bases, depending on the specific purpose and type of data involved:

• Contractual Necessity: Processing that is necessary for the performance of the contract between you and Batman11 — including account management, transaction processing, and the delivery of gaming services.
• Legal Obligation: Processing required for compliance with applicable laws and regulations, including KYC verification, AML reporting, and the maintenance of transaction records as required by regulatory authorities.
• Legitimate Interests: Processing that is necessary for Batman11's legitimate business interests — including fraud prevention, platform security, and service improvement — provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: Where processing is based on consent — such as for marketing communications or optional analytics cookies — you have the right to withdraw that consent at any time, without affecting the lawfulness of prior processing.

Batman11 does not sell, rent, or trade your personal data to any third party for commercial or marketing purposes. We may share your data with third parties only in the following limited circumstances:

Batman11 engages trusted third-party service providers to perform functions on our behalf that are necessary for the operation of the Platform. These include:

• Payment Gateway Providers: Including processors for Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, and USDT TRC20, for the purpose of executing deposit and withdrawal transactions.
• KYC and Identity Verification Services: To conduct identity document checks, PEP screening, and sanctions list screening as required under AML regulations.
• Fraud Prevention and Risk Management Providers: To assess transaction risk and detect account compromise or fraudulent activity.
• Cloud Infrastructure and Data Hosting Providers: To securely store Platform data and ensure platform availability and resilience.
• Customer Support Platform Providers: To facilitate Live Chat and ticketing services used by our24/7 support team.
• Analytics Service Providers: To generate aggregated, anonymised insights about Platform usage for internal performance monitoring and improvement purposes.

All third-party service providers engaged by Batman11 are contractually bound to process personal data only in accordance with our instructions and applicable data protection law, and are prohibited from using your personal data for any other purpose.

Batman11 may disclose personal data to governmental authorities, law enforcement agencies, or regulatory bodies where required to do so by applicable law, court order, or regulatory mandate. Such disclosures will be made only to the extent strictly required and, where permitted by law, we will notify affected Users.

In the event of a merger, acquisition, sale of assets, or other corporate transaction involving Batman11, personal data held by Batman11 may be transferred to the relevant successor entity, subject to equivalent data protection obligations being imposed on the receiving party.

Batman11 uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain session security, and gather analytics data. Cookies are small text files placed on your device when you visit the Platform. They do not contain executable code and cannot access other files on your device.

You may manage your cookie preferences through your browser settings at any time. Disabling strictly necessary cookies may affect the functionality of the Platform. For marketing and analytics cookies, you may withdraw your consent via the Platform's cookie settings panel.

Batman11 retains personal data for the minimum period necessary to fulfil the purposes described in this Policy, subject to any longer retention periods required by applicable law or regulation.

• Account Data and Transaction Records: Retained for a minimum of five (5) years following account closure, in compliance with applicable anti-money laundering legislation which requires maintenance of transaction records for regulatory inspection.
• KYC and Identity Documents: Retained for a minimum of five (5) years after the end of the business relationship, in accordance with AML and financial services regulatory requirements.
• Customer Support Records: Retained for three (3) years from the date of the relevant interaction, for quality assurance and dispute resolution purposes.
• Marketing Preferences and Opt-In Records: Retained for the duration of the business relationship and up to two (2) years thereafter, to demonstrate compliance with consent-based marketing obligations.
• Analytics and Usage Data: Anonymised and aggregated data may be retained indefinitely for internal reporting purposes; individual-level usage data is retained for up to twelve (12) months.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised using industry-standard data destruction procedures.

Batman11 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Transport Layer Security (TLS): All data transmitted between your browser and the Batman11 Platform is encrypted using TLS 1.2 or higher, preventing interception during transmission.
• Data Encryption at Rest: Personal data stored on Batman11's servers is encrypted using AES-256 encryption standards.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. Staff with access to personal data undergo regular training on data protection obligations and are bound by confidentiality obligations.
• Two-Factor Authentication (2FA): Available for all user accounts and mandatory for administrative access to internal systems.
• Penetration Testing: Batman11's Platform and infrastructure undergo periodic security assessments and penetration testing by qualified independent security professionals.
• Incident Response: Batman11 maintains a documented data breach response procedure, including escalation protocols and notification processes for affected users and regulatory authorities where applicable.

Subject to applicable data protection law, you have the following rights in respect of your personal data held by Batman11. You may exercise any of these rights by contacting our support team via the channels listed in Section 14:

Batman11 will respond to all verified data rights requests within thirty (30) calendar days of receipt. In complex cases, this period may be extended by up to a further sixty (60) days, and you will be notified of any extension with the reason provided.

Batman11 strictly prohibits the use of its Platform by individuals under the age of 21. The Platform is intended exclusively for adults aged 21 and above. We do not knowingly collect, process, or retain personal data from individuals who are under the legal minimum age.

Age verification is conducted as part of the KYC process for all registered Users. Any account found to belong to a person under 21 years of age will be immediately closed, all deposits refunded net of any applicable regulatory deductions, and all winings voided in accordance with applicable regulations and ourTerms & Conditions.

Some of Batman11's service providers and data processors may be located in jurisdictions outside of Malaysia. Where personal data is transferred to a recipient in a country that does not provide an equivalent level of data protection, Batman11 implements appropriate safeguards to ensure that such transfers are conducted lawfully and securely.

These safeguards may include contractual clauses binding the recipient to data protection standards equivalent to those required under applicable Malaysian law and internationally recognised data protection frameworks. Batman11 does not transfer personal data to jurisdictions subject to international sanctions or known to have inadequate data protection frameworks without implementing compensating controls.

Batman11 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform services. The date of the most recent revision is displayed at the top of this page.

Where changes are material, Batman11 will provide reasonable prior notice via email or an in-Platform notification before the amended Policy takes effect. Your continued use of the Platform following the publication of an updated Policy constitutes acceptance of the revised terms.

We encourage you to review this Privacy Policy periodically to remain informed about how Batman11 collects and uses your personal data. If you disagree with any material amendment, you may close your account and request deletion of your personal data in accordance with your rights under Section 10 of this Policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or Batman11's processing of your personal data, please contact our Data Privacy team using the following channels: