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:
- first and last name, and company name
- email address and phone number
- postal address
- your Client ID and account status
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
- photographs of the front and back of your cards, which can incidentally show handwriting, hands or a background
- card details such as year, set, player, card number and serial number
- condition notes, grading records and estimated grades
- your instructions about a card
- submission details, including the service you asked for, approximate card count, your notes, delivery method, carrier and tracking reference
- location and status of cards in our workflow
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
- which version of a website document you accepted, and when
- the cookie choices you save while signed in
- account security actions taken on your account, such as account recovery or suspension, including who acted, why, and how your identity was checked
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:
- create and secure your account, and confirm who you are
- receive, identify, photograph, track and return your cards
- provide grading submission, listing and sale services you have asked for
- prepare invoices and statements, and record commissions under a signed agreement
- respond to you and provide support
- keep the Portal secure, investigate misuse, and keep an audit trail
- meet legal, tax and accounting duties, and establish or defend legal claims
[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:
- declared values, grading and preparation fees, and invoices, including amounts and dates paid
- sales, including order references, sale amounts, and fees
- commission and balance entries calculated under a signed agreement
[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:
- Audit records are kept and cannot be edited or removed through the application.
- Business histories, such as card, submission, billing and sale histories, are kept as permanent, add-only records.
- Deletion in the Portal hides a client, batch or card record from normal use. The underlying record and images are kept and can be restored by an administrator.
- Invitations expire. We keep only a scrambled form of the invitation secret.
Retention periods:
- Client and account records: [DECISION LD-06: retention period]
- Card records and photographs: [DECISION LD-06: retention period]
- Invoices, billing, sale and commission records: [DECISION LD-06: retention period]
- Signed agreement records: [DECISION LD-06: retention period]
- Audit records: [DECISION LD-06: retention period]
- AI identification records: [DECISION LD-06: retention period]
- Acceptance, cookie-choice and account security records: [DECISION LD-06: retention period]
- Application logs and provider-held copies: [DECISION LD-06: retention period]
[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
- Multi-factor authentication is required for Portal access, for clients and staff.
- Every request is checked for an authorised account, and your client account must be active.
- Staff access is controlled by role and permission.
- An audit trail records access and changes, and it cannot be edited through the application.
- Connections to our database use verified encryption in transit.
- Card photographs are stored privately and shown through links that expire within minutes.
- Invitation secrets are stored only in a scrambled form.
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:
- know what personal information we hold, and get a copy
- correct it
- delete it, subject to legal exceptions and to "Retention and deletion" above
- object to or limit certain uses
- appeal our decision
[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".
- Identifiers and customer records: name, company, email, phone, postal address, Client ID. Used to provide and secure services. Disclosed to providers named above as described.
- Commercial information: cards, services, invoices, sales and commissions. Used to provide services, keep records and meet legal duties.
- Visual information: card photographs. Used to identify and manage cards. Disclosed to Cloudflare and OpenAI, and to eBay if live listing starts.
- Internet or network activity: Portal activity records and session data. Used for security and audit.
- Account credentials: handled by Clerk. Used to sign you in. [DECISION LD-08: treatment as sensitive personal information]
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]