Privacy Policy

How HoloLedger collects, uses, and protects your personal data.

Version 1.1 · Effective 10 October 2026

1. Who we are

HoloLedger is operated by HoloLedger Ltd, a company registered in England and Wales (company number 17475127), whose registered office is at 29 Blackwood Close, West Byfleet, United Kingdom, KT14 6PP (“we”, “us”). We are the data controller for the personal data described below.

2. What we collect, why, and our lawful basis

We only use your data where the law allows it. For most of what we do, that’s because it is needed to provide the service you signed up for (contract). Some things we must do by law (legal obligation), and some we do because we have a genuine need that doesn’t override your rights (legitimate interests). We don’t rely on your consent for any of the processing below.

CategoryWhatWhyLawful basis
AccountEmail, password (stored hashed by our authentication provider), username, display nameTo create and secure your accountContract
Age declarationYour answer to “Are you 18 or over?” and when you gave itHoloLedger is for adults only; buying, selling and trading involve contracts and paymentsLegitimate interests
Seller declarationWhether you sell as a private individual or a business, and when you said soTo show buyers who they are dealing with and to meet consumer-law dutiesLegal obligation; legitimate interests
AgreementsWhich version of each policy you accepted, and whenTo keep a record of what you agreed toLegitimate interests (establishing and defending legal claims)
Public profileUsername, display name, bio, avatar, general location (never a precise address)To let other collectors identify youContract
CollectionCards you own, condition, photos you uploadThe core product: your collectionContract
Card recognitionA photo of a card you ask us to identifyTo suggest which card it is (see §3)Contract
MarketplaceListings, prices, offers, ordersTo run the marketplaceContract
PaymentsPayment records, fees and Stripe identifiers. Never full card numbers.To process and record payments and payouts (Stripe handles the card details)Contract; legal obligation (financial records)
ShippingDelivery address for orders and protected tradesSo the other party can post to you. Only they can see it.Contract
MessagesConversations and message contentTo let you talk to other collectors. Moderators may review messages that are reported to us.Contract; legitimate interests (safety)
ReviewsRatings and review text, tied to a real completed order or tradeTrustworthy reviews and preventing fake onesLegitimate interests; legal obligation
Disputes, reports and moderationDispute evidence, reports, moderation decisions and appealsTo resolve disputes, keep the community safe and meet online-safety dutiesLegitimate interests; legal obligation
Identity verificationVerification status and Stripe session references only (see §4)To show an “Identity verified” markLegitimate interests
Privacy requestsRequests and complaints you send us, and our repliesTo handle your rightsLegal obligation
Notification preferencesWhich notifications and emails you've switched on or offTo respect your choicesContract
Security and admin logsRecords of admin actions and security eventsAccountability and fraud preventionLegitimate interests; legal obligation
TechnicalStandard server logs (for example IP address and browser type)Security and abuse preventionLegitimate interests

Tax reporting. UK law may require online marketplaces to report some sellers’ sales to HMRC, and to collect details such as your full name, address, date of birth and National Insurance number to do so. We don’t collect these details today. If the rules require it for your account, we’ll tell you first and explain why (legal obligation).

We don’t use analytics, advertising or marketing tracking. See our Cookie Policy. We don’t sell your data.

3. Card recognition

When you ask us to identify a card from a photo, we send that photo to OpenAI, which works for us as a processor. We ask OpenAI not to store the request. OpenAI may keep it for up to 30 days to monitor for abuse, and doesn’t use it to train its models. Please photograph only the card, not people or documents.

4. Identity verification

Identity verification is optional and provided by Stripe Identity on Stripe’s own pages. We never receive your identity document image or number, and we don’t ask for a selfie or use facial recognition. We only keep the result and Stripe’s session reference.

If you close your account, we ask Stripe to redact your verification session. Stripe keeps some information for its own legal obligations, as its own privacy policy explains, and this is outside our control.

5. Who we share data with

Other members see what you make public (your profile, listings, reviews and posts). The person you trade or buy with sees what they need for that transaction, such as the delivery address.

These service providers process data for us, under contracts that protect it:

ProviderWhat they doWhere
SupabaseDatabase, sign-in and file storageLondon, UK
VercelHosting the websiteLondon, UK, with a global content network
StripePayments, seller payouts and identity verificationUK, EU and US
ResendSending emailEU
OpenAICard recognition (§3)US

Card information and card images come from TCGdex, an open Pokémon card database. Our servers fetch and cache copies of the images and serve them from hololedger.co.uk, so your browser never connects to TCGdex and we share no information about you with it.

We may also share data where the law requires it, for example with HMRC, the police or a regulator, or to protect someone from harm.

6. International transfers

Where a provider handles data outside the UK, we rely on the UK’s adequacy regulations (including the UK–US data bridge for certified US companies) or on the UK International Data Transfer Agreement or Addendum, with an assessment of the risks.

7. How long we keep data

DataHow long
Your account, profile, collection, listings and messagesWhile your account is open. When you close it, deletion happens 30 days later (you can change your mind until then).
Orders, payments, refunds and disputesAs long as UK financial and tax law requires (typically 6 years), even after you close your account. Your name is replaced with an anonymous label.
Messages in an order or trade conversationKept with the order as evidence; other messages are deleted when you close your account
Delivery addresses180 days after the order or trade ends
Read notifications1 year
Email delivery records180 days
Card recognition records180 days
Agreements and declarationsKept as a record of what was agreed, including after closure
Moderation and security recordsAs long as needed for safety, accountability and legal claims

Backups are kept for a limited period and then overwritten. If we ever restore one, we delete again anything that had already been erased.

8. Closing your account

You can close your account in Settings → Account. Your public profile and listings disappear straight away, and your data is deleted 30 days later unless you change your mind. Unfinished orders, trades or disputes must be completed first. Some records are kept, as explained in §7.

9. Your rights

Under UK data protection law, you can ask us to:

  • give you a copy of your data (you can also download much of it yourself in Settings → Privacy)
  • correct inaccurate data
  • delete your data, unless we must keep it by law
  • restrict or stop some uses of your data, or object to them
  • give you data you provided in a portable format

Make a request in Settings → Privacy, or email support@hololedger.co.uk. We reply within one month. For complex requests we can extend this by up to two more months, and we’ll tell you if we do. We may ask you to confirm it’s you.

10. Complaints

If you’re unhappy with how we use your data, please tell us first in Settings → Privacy (choose “Make a privacy complaint”). We’ll acknowledge it within 30 days. You can also complain to the Information Commissioner’s Office (ico.org.uk).

11. Children

HoloLedger is for adults only. Everyone is asked to confirm they are 18 or over when they join. If someone tells us they are under 18, or we find out, we close the account and delete its data.

12. Contact

For any privacy question, contact support@hololedger.co.uk.
Registered office: 29 Blackwood Close, West Byfleet, United Kingdom, KT14 6PP