My Card Grader
My Card Grader

Privacy Policy


My Card Grader – Privacy Policy

Last updated: [24.04.2026]

1. Introduction

1.1 This Privacy Policy describes how [Company Legal Name], a company registered in Malta with registered address at [Company Address] (“Provider”, “we”, “us”, or “our”), processes personal data in connection with the My Card Grader mobile application (“App”).

1.2 This Privacy Policy is drafted to comply with:

  • Regulation (EU) 2016/679 (GDPR)
  • The Maltese Data Protection Act
  • Apple App Store privacy requirements
  • Google Play Data Safety policies


2. Scope

2.1 This Privacy Policy applies to all users of the App.

2.2 The App:

  • Does not require account creation
  • Does not collect login credentials
  • Uses subscription‑based access only


3. Categories of Data Collected

3.1 User‑Submitted Data

3.1.1 Images of Trading Cards
Users may upload photographs or scans of Pokémon Trading Card Game cards for AI analysis.

  • These images are not linked to user identities
  • Images are not used for biometric identification
  • Images are not shared publicly

(Apple classification: User Content → Photos or Videos)
(Google classification: Photos and videos)

3.2 Automatically Collected Data

3.2.1 Device & App Information
Collected automatically for functionality, stability, and security:

  • Device type and model
  • Operating system version
  • App version
  • Crash logs and diagnostics

(Apple classification: Diagnostics)
(Google classification: App info and performance)

3.2.2 Subscription Status

  • We receive subscription entitlement status only
  • Payment details are processed solely by Apple or Google
  • We cannot access card numbers or billing information

(Apple classification: Purchases)
(Google classification: Financial info → Purchases)


4. Data We Do Not Collect

4.1 The App does not collect:

  • Names
  • Email addresses (unless you contact support)
  • Phone numbers
  • Usernames or passwords
  • Precise location data
  • Contacts
  • Advertising identifiers
  • Sensitive personal data

4.2 The App does not use:

  • Tracking for advertising
  • Cross‑app tracking
  • Third‑party ad networks


5. Purpose of Processing

5.1 Data is processed solely to:

  • Provide AI‑based grading functionality
  • Improve AI accuracy and quality
  • Ensure app stability and prevent abuse
  • Validate subscription access
  • Provide customer support when contacted

5.2 Data is never used for:

  • Advertising
  • User profiling
  • Data brokerage
  • Marketing communications


6. Legal Basis for Processing (GDPR – Article 6)

6.1 Processing is based on:

  • Performance of a contract (providing the App’s functionality)
  • Legitimate interests (service improvement, fraud prevention)
  • Legal obligations (accounting, consumer law compliance)

6.2 Where consent is legally required, it will be obtained explicitly.


7. Artificial Intelligence & Image Processing

7.1 Uploaded images are processed automatically by AI systems only.

7.2 No human review is performed unless required for:

  • Technical debugging
  • Legal compliance

7.3 Images are not used to identify individuals.

7.4 Images may be retained in anonymised or aggregated form for AI model improvement.


8. Data Retention

8.1 Images are retained only as long as necessary to:

  • Generate grading output
  • Improve AI models
  • Comply with legal obligations

8.2 Diagnostic data is retained for a limited period.

8.3 Subscription confirmation data is retained as required by Apple and Google platform rules.


9. Data Sharing

9.1 We do not sell or rent personal data.

9.2 Data may be shared only with:

  • Apple App Store or Google Play (subscription validation)
  • Cloud hosting providers (infrastructure)
  • Legal authorities when required by law

9.3 All processors are contractually bound to GDPR‑compliant safeguards.


10. International Transfers

10.1 Data may be processed within the EU or in third countries.

10.2 Where transfers occur outside the EU, they rely on:

  • EU adequacy decisions, or
  • Standard Contractual Clauses (SCCs)


11. Security Measures

11.1 We implement reasonable technical and organisational safeguards, including:

  • Encryption in transit
  • Restricted access controls
  • Secure cloud infrastructure
  • Regular monitoring and updates

11.2 No system is completely secure, but we take appropriate precautions.


12. Your Rights (GDPR)

12.1 You have the right to:

  • Access your personal data
  • Request deletion or restriction
  • Object to processing
  • Withdraw consent where applicable
  • Lodge a complaint with the Maltese Data Protection Authority


13. Children’s Privacy

13.1 The App is not intended for children under 13.

13.2 We do not knowingly collect data from children.


14. Third‑Party Platforms

14.1 Apple and Google process data in accordance with their own privacy policies.

14.2 Use of the App is subject to their platform terms.


15. Changes to This Policy

15.1 We may update this Privacy Policy from time to time.

15.2 Continued use of the App indicates acceptance of the updated version.


16. Data Controller Contact Details

16.1 Data Controller:
[My Card Grader]

16.2 Registered Address: Malta

16.3 Contact Email:
mycardgradersupport@gmail.com


✅ APPLE APP STORE – APP PRIVACY QUESTIONNAIRE ALIGNMENT

You can answer YES / NO exactly like this:

Data Collected

✅ User Content – Photos or Videos (card images)
✅ Purchases – Subscription entitlement
✅ Diagnostics – Crash data

All others: NO

Purpose of Collection

✅ App Functionality
✅ Analytics (non‑tracking)
✅ Product Improvement

Tracking

❌ No tracking
❌ No cross‑app tracking
❌ No advertising identifiers

Data Linked to User

❌ No (no account, no identifiers)

Data Used for Advertising

❌ No

✅ GOOGLE PLAY – DATA SAFETY FORM ALIGNMENT

Data Collected

✅ Photos and videos (user‑submitted card images)
✅ App info and performance (diagnostics)
✅ Financial info → Purchases (handled by Google Play)

Purpose

✅ App functionality
✅ Analytics
✅ Fraud prevention / security

Data Shared

✅ With service providers (cloud hosting only)

Data Encrypted in Transit

✅ Yes

Data Deletion

✅ Users can request deletion via support email

Children’s Safety

✅ App not designed for children
✅ No child‑specific data collection

Copyright © 2026 My Card Grader - All Rights Reserved.

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