bat11 Privacy Policy

1. Data Controller Information

This Privacy Policy applies to all personal data collected and processed by bat11 in connection with the operation of the bat11.club platform, including all associated web pages, mobile-optimised interfaces, customer support channels, and promotional communications directed at registered or prospective players based in Bangladesh.

bat11 acts as the data controller with respect to the personal data of its users. As data controller, bat11 determines the purposes and means by which your personal data is processed. All data-related enquiries, correction requests, and deletion requests should be directed to our support team at [email protected] — plain text, not a clickable link.

By creating an account on bat11, accessing the platform as a guest, or otherwise interacting with bat11 services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described herein, please discontinue use of the bat11 platform immediately.

2. Information We Collect

bat11 collects personal data through several channels — directly from you during account registration and ongoing platform use, automatically through technical systems as you interact with the site, and in limited cases from trusted third-party partners such as payment processors and KYC verification providers.

Information You Provide Directly

• Registration data: Full legal name, date of birth, email address, mobile phone number, and residential address (city, district, Bangladesh).
• Identity verification documents: National Identity Card (NID) number, passport details, or driving licence details submitted during KYC verification.
• Financial data: bKash account number, Nagad account number, Rocket (Dutch-Bangla Bank) account number, Upay account details, or Visa/Mastercard details provided when making deposits or requesting withdrawals. bat11 does not store full card numbers — card data is tokenised by the payment processor.
• Communication records: Messages, emails, and live chat transcripts sent to or received from bat11 customer support.
• Self-reported data: Responsible gaming preferences including deposit limits, session limits, and self-exclusion requests.

Information Collected Automatically

• Device and browser data: IP address, browser type and version, operating system, device model, screen resolution, and language settings.
• Usage and behavioural data: Pages visited, time spent on each page, games played, bet amounts, session duration, and clickstream patterns.
• Geolocation data: Approximate location derived from IP address, used to verify Bangladesh residency and detect access from restricted jurisdictions.
• Cookies and tracking identifiers: Session cookies, persistent cookies, and similar technologies as described in the Cookies section of this Policy.
• Transaction logs: Records of all deposits, withdrawals, bets placed, casino game rounds, and bonus claims with timestamps.

Information from Third Parties

• Payment partners: Transaction status, reference numbers, and payer verification signals from bKash, Nagad, Rocket, Upay, and card-processing networks.
• KYC providers: Identity verification results, document authenticity assessments, and fraud risk scores from bat11's third-party verification partner.
• Anti-fraud and AML services: Risk indicators and transaction pattern analysis from fraud-detection service providers.

Data Category	Examples	Collection Method
Identity Data	Name, NID, date of birth	Registration & KYC form
Contact Data	Email, phone, address	Registration form
Financial Data	bKash/Nagad account, card token	Deposit/withdrawal flow
Technical Data	IP address, browser, device	Automatic — server logs
Usage Data	Games played, bets, sessions	Automatic — platform events
Communications Data	Support chat, email threads	Customer support system
Verification Data	KYC result, fraud score	Third-party KYC provider

3. Legal Basis for Processing

bat11 processes your personal data only where a valid legal basis exists. The primary legal bases bat11 relies on are as follows:

• Contractual necessity: Processing required to fulfil our obligations under the bat11 Terms & Conditions — including account management, payment processing, bet settlement, and customer support.
• Legal obligation: Processing required to comply with applicable laws, including Anti-Money Laundering (AML) obligations, Know Your Customer (KYC) regulatory requirements, and the legal duty to prevent underage gambling.
• Legitimate interests: Processing necessary for fraud prevention, platform security, abuse detection, responsible gaming monitoring, and service improvement — where these interests are not overridden by your privacy rights.
• Consent: Where bat11 sends you optional marketing communications or uses non-essential cookies, we rely on your explicit consent, which you may withdraw at any time.

Where bat11 relies on legitimate interests as a legal basis, we conduct a balancing test to ensure that our interests do not disproportionately override your fundamental right to privacy. You may request details of any specific legitimate interest assessment by contacting [email protected].

4. How We Use Your Data

bat11 uses the personal data it collects for clearly defined purposes. We do not use your data for purposes incompatible with those stated at the time of collection. The primary purposes are:

• Account creation and management: Setting up your bat11 account, verifying your identity, maintaining your account profile, and enabling you to log in securely.
• Processing bets and transactions: Accepting deposits via bKash, Nagad, Rocket, Upay, and card; settling winning bets; processing withdrawal requests; and maintaining an accurate transaction history.
• KYC and age verification: Confirming that you are at least 18 years of age and that the personal data you have provided is accurate and authentic.
• Responsible gaming compliance: Monitoring your gameplay for signs of problem gambling behaviour; enforcing self-exclusion requests and deposit limits you have set; detecting accounts that may require intervention.
• Fraud prevention and platform security: Detecting and preventing account takeover, bonus abuse, collusion, money laundering, and other prohibited conduct; investigating suspicious activity.
• Customer support: Responding to your enquiries, complaints, and dispute submissions; maintaining records of support interactions for quality assurance.
• Service improvements: Analysing anonymised usage data to identify bugs, improve the platform experience, optimise game and sports-market loading, and develop new features.
• Marketing communications: Sending you personalised bonus offers, cricket match previews, BPL promotions, and casino game launch notifications — but only where you have given consent and have not subsequently opted out.
• Legal and regulatory compliance: Retaining records as required by AML legislation; responding to lawful requests from authorities; enforcing bat11's Terms & Conditions.

5. Data Sharing & Third Parties

bat11 may share your personal data with a limited set of trusted third-party organisations where sharing is necessary to deliver our services or to comply with legal obligations. All third-party data processors engaged by bat11 are subject to binding data processing agreements that restrict their use of your data to the specific purpose for which it was shared.

Categories of Third-Party Recipients

• Payment service providers: bKash, Nagad, Rocket (Dutch-Bangla Bank), Upay, and Visa/Mastercard card-processing networks — to process deposits and withdrawals.
• KYC and identity verification providers: Third-party services that verify the authenticity of identity documents and confirm player age.
• Game and sports-data providers: Game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi receive anonymised session identifiers to deliver their game software. They do not receive your full identity data.
• Cloud infrastructure providers: Hosting and database providers that store bat11 platform data on encrypted servers under strict access controls.
• Anti-fraud and AML services: Specialist providers that analyse transaction patterns for suspicious activity.
• Customer support tooling: Secure helpdesk software used to manage support tickets and live chat — subject to data processing agreements.
• Legal and regulatory authorities: bat11 will disclose personal data to law enforcement, financial intelligence units, or courts where required by a lawful order or where bat11 reasonably believes disclosure is necessary to prevent serious harm or illegal activity.

bat11 does not transfer your personal data to countries outside the operating jurisdiction unless the receiving country offers an equivalent level of data protection, appropriate contractual safeguards are in place, or the transfer is necessary to perform the contract between you and bat11 (for example, processing a Visa payment through an international card network).

6. Cookies & Tracking Technologies

bat11 uses cookies — small text files stored in your browser — and similar tracking technologies to operate the platform, remember your preferences, keep your session secure, and understand how users interact with the site. The cookies bat11 uses fall into the following categories:

Cookie Type	Purpose	Consent Required
Strictly Necessary	Session authentication, CSRF protection, load balancing, security tokens	No — essential to site function
Functional	Language preference, display settings, remembering last game category	No — core user experience
Analytics	Anonymised page-view and event tracking to improve platform performance	Yes — opt-in
Marketing / Retargeting	Personalised bonus and promotion delivery based on browsing behaviour	Yes — opt-in

You can manage your cookie preferences at any time through your browser settings. Blocking strictly necessary cookies may impair core platform functionality, including your ability to log in and place bets. Disabling analytics or marketing cookies will not affect your ability to use bat11 services. To withdraw consent for optional cookies, adjust your browser settings or contact [email protected].

7. Data Retention

bat11 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account data (active accounts): Retained for the lifetime of the account plus a minimum of 5 years after account closure, to comply with AML record-keeping obligations.
• KYC and identity verification records: Retained for a minimum of 5 years from the date of account closure, as required by financial crime prevention legislation.
• Transaction records (deposits, withdrawals, bets): Retained for a minimum of 5 years from the date of each transaction for accounting, tax, and regulatory compliance purposes.
• Customer support correspondence: Retained for 3 years from the date of the last interaction, unless the records relate to an unresolved dispute in which case they are retained until the dispute is fully resolved.
• Marketing consent records: Retained for as long as you are an active subscriber plus 2 years after opt-out, to demonstrate that consent was properly obtained and subsequently honoured.
• Server and access logs: Retained for 12 months from the date of creation for security and fraud investigation purposes, then securely deleted.

When personal data is no longer required, bat11 deletes or anonymises it in a manner that prevents reconstruction of the original data. Where deletion is not immediately possible due to technical constraints (such as data held in backup systems), bat11 will isolate the data from further active processing until deletion is feasible.

8. Your Privacy Rights

As a bat11 player based in Bangladesh, you hold a set of rights with respect to the personal data bat11 holds about you. bat11 is committed to honouring these rights promptly and without unnecessary barriers. Requests can be submitted to [email protected].

bat11 will respond to all verifiable privacy rights requests within 30 days of receipt. In complex cases, this period may be extended by up to a further 60 days, in which case bat11 will notify you of the extension and the reason for it within the initial 30-day window.

Please note that certain data retention obligations under AML law may prevent bat11 from deleting specific records even upon an erasure request. Where this is the case, bat11 will explain the legal basis for retention in its response to your request.

9. Data Security Measures

bat11 takes the security of your personal data seriously and has implemented a layered set of technical and organisational safeguards designed to protect your data against unauthorised access, accidental loss, destruction, and disclosure.

Technical Safeguards

• All data transmitted between your browser and the bat11 platform is encrypted using 256-bit TLS (SSL) encryption. Look for the padlock icon in your browser address bar when accessing bat11.club.
• Passwords are stored as salted cryptographic hashes — bat11 employees cannot read your password in plain text and bat11 will never ask you for your password via email or chat.
• Financial data is tokenised by payment processors — bat11 does not store raw card numbers or full mobile financial service account credentials on its own servers.
• Platform infrastructure is hosted on servers with restricted access controls, intrusion detection systems, and real-time security monitoring.
• KYC documents are stored in an encrypted document vault with access limited strictly to personnel who require it for verification purposes.

Organisational Safeguards

• Access to personal data is limited to bat11 staff on a strict need-to-know basis. Role-based access controls are reviewed periodically.
• All bat11 staff who handle personal data receive data protection training and are contractually bound by confidentiality obligations.
• bat11 conducts periodic security reviews of its systems and data handling processes.
• In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected players, bat11 will notify affected users without undue delay and take immediate steps to contain and remediate the breach.

10. Minors & Privacy Protection

bat11 is strictly an adult platform. The bat11 service is not directed at, and must not be used by, any person under the age of 18. bat11 does not knowingly collect personal data from minors.

All accounts are subject to age verification as part of the KYC process. If bat11 discovers or is notified that it has collected personal data from a person under 18 years of age, bat11 will immediately close the account, delete the minor's personal data (subject to any minimum retention obligations required by law), and return any deposits made to the payment source from which they originated.

If you are a parent or guardian and believe that your child has created a bat11 account or submitted personal data to bat11, please contact [email protected] immediately. bat11 will investigate and take appropriate action promptly.

11. Changes to This Policy

bat11 may update this Privacy Policy from time to time to reflect changes in our data practices, updates to applicable law, or improvements in the way we describe our data processing activities. When material changes are made, bat11 will:

• Update the "Last Updated" date displayed at the top of this page and in the hero section;
• Send an email notification to all registered bat11 accounts at the email address on file; and
• Display a prominent notice on the bat11 platform for a minimum of 14 days following publication of the updated Policy.

Your continued use of the bat11 platform after the effective date of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with any change, you must stop using bat11 and may request account closure by contacting [email protected].

bat11 recommends reviewing this Privacy Policy periodically. Previous versions are available upon request.

12. Contact & Data Queries

For any questions, concerns, or requests relating to this Privacy Policy or bat11's data handling practices, please contact the bat11 data support team. All enquiries are handled in English and responses will be provided within the timeframes stated in the relevant section of this Policy.

Contact details for data-related matters:

• Email (plain text — not a link): [email protected]
• Subject line to use: "Privacy Enquiry" or "Privacy Rights Request"
• Response time: Within 5 business days for general enquiries; within 30 days for formal rights requests
• Postal enquiries: Not accepted — please use email only

bat11 takes all data protection enquiries seriously. If you are not satisfied with bat11's response to a privacy complaint, you retain the right to escalate the matter to the relevant data protection authority in your jurisdiction.