Batman11 Privacy Policy – Data Protection for Malaysian Members

§1 Information We Collect

Batman11 collects several categories of information from members and users of our platform. This collection is carried out directly from you, automatically as you use the platform, and in certain cases, from legitimate third-party sources.

Information you provide directly:

• Full name, Malaysian identity card number (MyKad), and date of birth collected at account registration.
• A valid Malaysian phone number and active email address.
• Bank account or digital wallet details (Touch 'n Go eWallet, GrabPay, Boost, ShopeePay, DuitNow) for deposit and withdrawal purposes.
• Identity verification documents submitted during the KYC (Know Your Customer) process, such as a copy of your MyKad or utility bill.
• Communications you send to the batman11 support team via live chat, email, or WhatsApp.

Automatically collected information:

• IP address, web browser type, device operating system and technical device information used to access batman11.
• Gaming session data including games played, bet amounts, wins and losses, and time spent playing.
• Financial transaction logs including the date, time, amount, and method of each deposit and withdrawal.
• In-platform activity data including pages visited, buttons clicked, and time spent in each section.
• Information on cookies and similar tracking technologies as further described in Section 6.

§2 How We Use Your Information

All information collected by batman11 is used responsibly and solely for legitimate purposes. The following are the primary purposes for which batman11 member data is used:

Batman11 will not use your personal data for any purpose beyond those stated above without first obtaining your renewed consent. If you no longer wish to receive marketing communications from batman11, you may opt out at any time by contacting our support team.

§3 Legal Basis for Data Processing

Batman11 processes member personal data on one or more legal bases recognised under Malaysia's Personal Data Protection Act 2010 (PDPA). It is important for you to understand these bases, as they determine your rights in relation to that data.

• Contract Performance: The majority of batman11's data processing is necessary to fulfil the service contract between batman11 and you as a member — including account management, financial transaction processing, and the provision of gaming services.
• Legal Obligation: Certain data processing activities such as KYC procedures, suspicious transaction reporting, and financial record retention are mandated by applicable Malaysian law, including the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001.
• Legitimate Interests: batman11 processes certain data on the basis of legitimate business interests — such as fraud detection and prevention, platform security enhancements, product analytics, and improving user experience — provided these interests do not override your fundamental rights.
• Consent: For marketing communications and the use of non-essential cookies, batman11 obtains your explicit consent. You have the right to withdraw this consent at any time without affecting your access to batman11's core services.

§4 Data Sharing with Third Parties

Batman11 does not sell, rent or disclose members' personal data to third parties for marketing purposes. However, there are limited circumstances in which batman11 needs to share data with certain parties in order for our services to function properly.

Parties that may receive batman11 member data:

• Certified Game Providers: Providers such as Pragmatic Play, PG Soft, Evolution Gaming and other licensed game providers may receive the minimum session data required to operate their games on the batman11 platform. These providers are bound by strict data protection agreements.
• Payment Processors: Malaysian payment service providers such as Touch 'n Go, DuitNow, FPX, and other eWallets receive the transaction information required to process your deposits and withdrawals. All of these payment processors are licensed entities that comply with Bank Negara Malaysia's regulations.
• Malaysian Authorities: Batman11 will disclose personal data to legal authorities, regulatory bodies, or law enforcement agencies in Malaysia when required by law, court order, or valid official directive.
• Technical Services & Infrastructure: Technical service providers such as cloud hosting, cybersecurity services and system management vendors that assist batman11 in operating the platform on a technical level. All such vendors are subject to binding confidentiality and data protection agreements.

In all of the data-sharing scenarios described above, batman11 ensures that only the minimum necessary data is shared, and that recipients are bound by data protection obligations equivalent to batman11's own standards. Batman11 takes full responsibility for data processing carried out by third-party processors on our behalf.

§5 Data Security & Encryption

Batman11 invests seriously in cybersecurity infrastructure to ensure members' personal data is protected at all times — whether in transit, during processing, or at rest.

The technical security measures batman11 employs include:

• 256-bit SSL/TLS Encryption: All communications between your device and batman11's servers are encrypted using TLS 1.3 protocol with 256-bit key length, ensuring that data cannot be intercepted or tampered with during transmission.
• Stored Data Encryption: Sensitive data such as banking information, KYC documents and passwords are stored in encrypted form using industry-recognised encryption algorithms. Passwords are never stored in plain text — we use salted hashing.
• Two-Factor Authentication (2FA): Batman11 supports and encourages the use of 2FA on all member accounts to provide an additional layer of protection against unauthorised access.
• Continuous Security Monitoring: Batman11's systems are continuously monitored by an in-house cybersecurity team to detect and respond to any anomalies or security threats in real time.
• Data Segregation: Members' personal data is stored in isolated environments, separated from public-facing systems, with strict access controls based on the least privilege principle.
• Periodic Security Audits: Batman11 conducts regular vulnerability assessments and penetration testing by independent third parties to identify and address potential security weaknesses.

§6 Cookies & Tracking Technologies

Batman11 uses cookies and similar tracking technologies to enhance the user experience and ensure the platform functions properly. This section explains the types of cookies used and how you can manage them.

Types of cookies used by batman11:

• Essential Cookies: These cookies are essential for the batman11 platform to function — including login session management, account security and authentication. Essential cookies cannot be disabled without affecting core platform functionality.
• Performance & Analytics Cookies: Used to understand how members use the batman11 platform — which pages are visited most, which features are used frequently, and where users may encounter difficulties. This data is collected anonymously and used for ongoing platform improvements.
• Functional Cookies: Allows batman11 to remember your preferences and settings — such as your preferred language, location, and display options — so you do not need to reconfigure them each time you log in.
• Marketing Cookies: Used to display relevant batman11 promotions and offers based on your previous activity on the platform. You may opt out of marketing cookies without affecting your gaming experience.

You can manage and control cookies through your web browser settings at any time. Disabling certain cookies may affect some features of the batman11 platform. For guidance on managing cookies across different web browsers, please refer to your respective browser's help documentation.

§7 Cross-Border Data Transfers

In the course of operating the batman11 platform for Malaysian members, some personal data may be processed or stored outside Malaysia by trusted technical service providers and cloud infrastructure partners. This is standard practice in modern digital platform operations.

Batman11 ensures that any transfer of personal data outside Malaysia is only carried out when:

• The recipient country or region provides an adequate and comparable level of data protection.
• Appropriate safeguards are in place, including data processing agreements and standard contractual clauses that bind recipients to batman11's data protection standards.
• The transfer is necessary for the execution of the service contract between batman11 and you as a member.
• You have provided explicit consent for the transfer.

§8 Data Retention Period

Batman11 does not retain member personal data for longer than is necessary for the stated purpose or as required by Malaysian law. The following are the data retention guidelines applicable to key data categories:

• Active Account Data: Retained for as long as your batman11 account remains active, and for a reasonable period following account closure to allow for the resolution of any outstanding disputes.
• Financial Transaction Records: Retained for a minimum of 7 years after a transaction occurs, in accordance with Malaysian financial and accounting legal requirements.
• KYC Documents: Retained for a minimum of 5 years after the business relationship ends, in accordance with Malaysia's Anti-Money Laundering Act requirements.
• Support Communication Logs: Retained for 2 years after the last interaction, for quality control and dispute resolution purposes.
• Anonymised Analytics Data: May be retained indefinitely as it contains no information that could identify any specific individual.

Once the designated retention period has ended, batman11 will securely delete or destroy your personal data using industry-recognised methods to ensure it cannot be recovered or reused.

§9 Your Rights as a Data Subject

As a batman11 member and data subject under Malaysia's PDPA 2010, you hold several important rights in relation to your personal data. batman11 is committed to respecting and facilitating the exercise of these rights.