Coveted Collection

Privacy Policy

Version 0.1.0-draft

Draft for owner and attorney review. Not in effect. Highlighted items are open decisions.

Effective date: [DECISION LD-13: effective date]

About this policy

This policy explains how [DECISION LD-01: legal entity name and type] ("Coveted Collection", "we", "us") handles personal information in connection with the Coveted Collection website and client portal (the "Portal").

It applies to clients and to people invited to the Portal. [DECISION LD-30: whether staff data is covered here or by a separate notice]

[DECISION LD-09: launch jurisdictions, and whether additional regional sections are needed]

Information we collect

Information we hold about clients

Our staff create your client record, usually before you have a Portal account. It can include:

Account and sign-in information

Our authentication provider, Clerk, handles sign-up, sign-in and multi-factor authentication. Clerk holds your name, email address, sign-in credentials and second-factor details. [DECISION LD-22: confirm the second factor at launch; if SMS, state here that Clerk holds your phone number and sends codes to it]

Our own database keeps only a Clerk account identifier linked to your client account, not your password. Our administrators can view your name, email address, last sign-in and whether multi-factor authentication is on.

Cards and services

Billing, sales and commission records

See "Payment and transaction data" below.

Activity records

When you use the Portal, we record an audit trail: the time, your account, the action, the page or function used, the outcome and the client account involved. Our application audit records do not store your IP address or browser details. Our hosting provider may log these separately. [DECISION LD-33: confirm hosting log content and retention]

Legal, privacy and account security records

What we do not collect

Our Portal does not collect date of birth, government ID numbers, bank account details or payment card numbers, and it does not use your device location. [DECISION LD-16: revisit this statement if identity documents are ever used for account recovery] [DECISION LD-24: revisit this statement if tax or payout details are collected]

How we use information, and legal grounds

We use personal information to:

[DECISION LD-09: if required in a launch jurisdiction, the legal ground for each purpose above]

[DECISION LD-19: whether marketing email is used; if not, state that we do not send it]

AI card identification

We may use OpenAI to help identify cards. When we do, front and back photographs of a card are sent to OpenAI, which returns suggested card details such as year, set and player. Your name and contact details are not included in the request. A suggestion is not final until our staff verify it.

[DECISION LD-11: final AI disclosure, including whether consent or an opt-out applies, and what OpenAI retains]

Service providers and other parties

We share information with the providers below, and only as described. [DECISION LD-10: confirm the contract and data-processing terms with each provider]

Clerk

Identity, authentication, multi-factor authentication and sessions. Clerk receives the sign-in information described above. When we invite you by email, Clerk receives your email address, your activation link, your Client ID and an invitation reference, and it sends the email.

Vercel

Hosts the website and Portal. All web requests pass through Vercel, and our application logs are kept there. Those logs can include Client IDs, Item IDs and card details. [DECISION LD-33: log content and retention]

Neon

Provides our PostgreSQL database, which holds the client, card, billing, sales and audit records described in this policy. [DECISION LD-29: confirm the production database provider]

Cloudflare

Cloudflare R2 stores card photographs, along with labels such as the Client ID, batch and card references. The storage is private. Photographs are shown through links that expire.

OpenAI

Receives card photographs, as described in "AI card identification".

eBay

Status at this draft: test (Sandbox) environment only. Live eBay use is planned and not active. When we list a card for sale, eBay would receive the listing title, description, condition, price, Item ID and card photographs. Your name and contact details are not part of a listing. We receive order, payment-status and finance facts from eBay, and we do not store buyer names, addresses or contact details from eBay orders. [DECISION LD-28: update when live eBay use starts]

PSA

Status at this draft: disabled by default. Where enabled, we send PSA a certification number or PSA submission number and receive certification or submission progress details. Your name and contact details are not part of those requests. Cards you send for grading are physically delivered to PSA. [DECISION LD-28: what PSA receives outside the Portal]

QuickBooks

Status at this draft: planned only. No client or invoice data is sent to QuickBooks by the Portal. QuickBooks is intended to be our accounting system for invoices and payments. [DECISION LD-24: update when any QuickBooks integration starts]

Others

[DECISION LD-29: confirm whether any legacy system, such as Airtable, holds client data]

We may also disclose information if the law requires it, to protect rights and safety, or as part of a business transfer. [DECISION LD-10: attorney wording for legal and business-transfer disclosures]

[DECISION LD-23: where data is hosted, and any international transfer disclosure]

Payment and transaction data

The Portal does not take card payments and does not collect payment card or bank details.

We keep records of:

[DECISION LD-24: how clients pay, which provider processes payments, and how proceeds are paid out]

Retention and deletion

We keep personal information for as long as needed for the purposes above. Our current practices are:

Retention periods:

[DECISION LD-07: how deletion requests are met, given soft deletion and add-only records, and what exceptions apply]

Cookies and analytics

We use only the cookies and browser storage needed to run the Portal. We do not currently use analytics, marketing or advertising technologies. Our Cookie Policy has the details, and you can review your choices at Privacy/Cookie Settings.

Security practices

No system is perfectly secure. [DECISION LD-32: final wording of security statements, and how we tell users about an incident] [DECISION LD-31: confirm each practice above is live in production]

Your privacy rights and requests

Depending on where you live, you may have the right to:

[DECISION LD-09: which rights apply at launch]

To make a request, contact [DECISION LD-18: privacy request address or form]. We will need to verify who you are. [DECISION LD-18: verification steps, authorised agents, response deadline and appeals]

We will not treat you differently for using your privacy rights.

Children

[DECISION LD-04: statement on children and minors, aligned with the minimum age]

California

[DECISION LD-08: whether CCPA/CPRA applies; the thresholds are for attorney review, and this section stays or changes accordingly]

Notice at collection

[DECISION LD-08: how and when this notice is given, given that staff create client records before an account exists]

The categories below are a draft mapping for attorney review. For each category, retention is stated under "Retention and deletion".

Sale and sharing

On our current inventory of technologies, we do not appear to sell personal information or share it for cross-context behavioural advertising. [DECISION LD-20: confirm that no sale or sharing occurs]

Global Privacy Control

We honour the Global Privacy Control signal. See the Cookie Policy. [DECISION LD-20: how the signal is applied]

California rights

[DECISION LD-08: final list of California rights, request methods, and any required metrics]

Changes to this policy

Each version has a version number and effective date. [DECISION LD-13: what counts as a material update, and how notice is given]

Contact

Legal entity: [DECISION LD-01: legal entity name]

Address: [DECISION LD-01: postal address]

Privacy requests: [DECISION LD-18: privacy request address or form]

General contact: [DECISION LD-01: contact email and phone]