CARDBUSTER
Privacy Policy
| Malaysia Entity | KAD BUSTER COLLECTIONS SDN. BHD. Reg. No. 202401010064 (1555914-M) Level 27, Centrepoint North Tower, Mid Valley City, Kuala Lumpur, 59200 |
| Singapore Entity | KAD BUSTER PTE. LTD. UEN 202537731G 68 Circular Road, #02-01, Singapore 049422 |
1. Introduction and Scope
CardBuster ("we," "us," or "our") is committed to protecting your privacy and ensuring transparency in how we collect, use, and process your personal data. This Privacy Policy explains our data handling practices for users accessing our Trading Card Game (TCG) marketplace platform at https://cardbuster.com.
This policy is designed to comply with the data protection laws of both Malaysia and Singapore, where CardBuster operates through two distinct legal entities. The Privacy Policy applies to all users, customers, sellers, and visitors of our platform, regardless of jurisdiction.
2. Definitions
Personal Data: Information relating to an identified or identifiable individual.
Data Controller: The entity determining the purposes and means of processing personal data. CardBuster operates as a data controller for all data collected through our platform.
Data Subject: Any individual to whom personal data relates.
Processing: Any operation performed on personal data, including collection, recording, organization, structuring, storage, adaptation, retrieval, use, disclosure, and deletion.
Third-Party Service Provider: External organizations that process personal data on CardBuster's behalf, including payment gateways, shipping carriers, and analytics providers.
3. Data Controller Information
3.1 Malaysia Entity
Business Name: KAD BUSTER COLLECTIONS SDN. BHD.
Registration No.: 202401010064 (1555914-M)
Business Address: Level 27, Centrepoint North Tower, Mid Valley City, Kuala Lumpur, 59200, Malaysia
Jurisdiction: Malaysia Personal Data Protection Act 2010 (PDPA 2010)
3.2 Singapore Entity
Business Name: KAD BUSTER PTE. LTD.
UEN: 202537731G
Registered Office: 68 Circular Road, #02-01, Singapore 049422
Jurisdiction: Singapore Personal Data Protection Act 2012 (PDPA 2012)
3.3 Platform
Website: https://cardbuster.com
Brand: CardBuster
4. What Personal Data We Collect
We collect personal data in the following categories:
4.1 Account Registration Information
- Full name
- Email address
- Phone number
- Residential address
- Date of birth
- Bank account details (for sellers only)
4.2 Card Recognition and Scanning Data
CardBuster uses advanced AI-powered card recognition technology to analyze trading card images. This process involves:
- Digital images of trading cards uploaded by users
- Metadata associated with scanned cards (timestamps, device information)
- Card identification results and valuation data
4.3 Listing and Product Information
- Product photographs
- Product descriptions
- Pricing and inventory information
4.4 Transaction and Payment Data
- Purchase history and transaction records
- Payment method information (FPX, credit/debit cards, e-wallets)
- Payment gateway transaction data (processed by eGHL)
4.5 Shipping and Delivery Data
- Shipping addresses
- Shipping carrier tracking information
- Delivery status and proof of delivery
4.6 Messaging and Communication Data
- Buyer-seller communications and chat messages
- Message content, timestamps, and metadata (processed by 3rd party IM API)
- This data may be used as contextual background in dispute resolution proceedings.
4.7 Collection Album Usage Data
- Scan data and collection tracking information
- Estimated collection value and portfolio analytics
4.8 Device and Technical Data
- IP address
- Device identifiers and hardware information
- Application usage patterns and crash reports
- Browser type, operating system, and app version
4.9 Location Data
- Geographic location (for shipping estimates and regional compliance)
- Regional preferences and availability
5. How We Collect Personal Data
5.1 Direct Collection
We collect personal data directly from you when you:
- Create a user account on CardBuster
- Complete your user profile
- Upload and scan trading cards using our AI recognition feature
- Create product listings for sale
- Make a purchase or payment
- Communicate with other users
- Provide feedback, reviews, or contact our support team
5.2 Automatic Collection
We automatically collect certain data through:
- Cookies and tracking technologies
- Web server logs
- Analytics services
- Device sensors (camera, GPS for location services)
5.3 Third-Party Sources
We may receive personal data from third-party service providers, including:
- Payment processors (eGHL gateway)
- Shipping carriers
- Card pricing databases (PriceCharting.com)
- AI and image recognition providers
5.4 Social Login and Facebook Data
CardBuster offers Facebook Login as an optional way to sign in, create an account, or link an existing CardBuster account. When you choose Facebook Login, we may receive your Facebook user ID, name, profile picture, and email address, depending on the permissions you grant and the information available in your Facebook account.
We use this information only to authenticate you, create or link your CardBuster account, protect account security, and provide account support. CardBuster does not post content to Facebook on your behalf and does not sell personal data received through Facebook Login.
You may remove CardBuster from the Apps and Websites section of your Facebook settings. To request deletion of your CardBuster account and associated Facebook Login data, follow our User Data Deletion instructions.
6. Purposes for Processing Personal Data
CardBuster processes personal data for the following legitimate purposes:
6.1 Platform Operations
- Creating and maintaining user accounts
- Processing transactions and payments
- Facilitating buyer-seller interactions
- Managing shipping and delivery services
6.2 AI and Card Recognition Services
- Identifying trading cards through image recognition
- Providing valuation estimates and market data
- Training and improving AI recognition accuracy
6.3 User Communication
- Responding to inquiries and support requests
- Sending transaction confirmations
- Providing notifications about orders, shipping, and platform updates
6.4 Analytics and Improvement
- Analyzing platform usage and user behavior
- Optimizing website and app performance
- Developing new features and services
6.5 Security and Compliance
- Detecting and preventing fraud
- Enforcing terms of service
- Protecting against illegal activities and security breaches
6.6 Legal Obligations
- Complying with regulatory requirements and data protection laws
- Responding to legal requests and law enforcement inquiries
- Maintaining records for auditing and compliance purposes
6.7 Marketing (Consent-Based)
- Sending promotional materials and special offers
- Conducting market research and customer surveys
- Personalizing your experience based on preferences
7. Legal Basis for Processing
CardBuster processes personal data based on the following legal grounds:
7.1 Consent
We obtain your explicit consent for processing personal data not otherwise justified by contractual necessity or legal obligation. You may withdraw consent at any time by contacting us (see Section 16).
7.2 Contractual Necessity
Processing is necessary to perform our contract with you, including account creation, payment processing, order fulfillment, and dispute resolution.
7.3 Legitimate Interests
We process personal data to pursue legitimate business interests, including fraud prevention, cybersecurity, analytics, and service improvement, provided this does not override your fundamental rights and freedoms.
7.4 Legal Obligation
Processing is required to comply with applicable laws, regulatory requirements, and government requests in Malaysia and Singapore.
8. Cookies and Tracking Technologies
8.1 What Are Cookies?
Cookies are small text files stored on your device that help us recognize you, remember your preferences, and improve your experience on CardBuster.
8.2 Types of Cookies We Use
- Essential Cookies: Required for platform functionality (authentication, security)
- Performance Cookies: Measure how users interact with the platform
- Preference Cookies: Store user preferences and settings
- Marketing Cookies: Track behavior for personalized advertising (requires consent)
8.3 Controlling Cookies
You can control cookie preferences through your browser settings. However, disabling essential cookies may impair platform functionality. We will seek your consent before deploying non-essential cookies in compliance with PDPA 2010 and PDPA 2012 requirements.
8.4 Third-Party Tracking
Our analytics partners and service providers may use cookies and tracking technologies. For details on their practices, please review their privacy policies.
9. Third-Party Service Providers and Data Sharing
CardBuster shares personal data with selected third-party service providers to deliver platform services. These organizations are contractually obligated to process data only as necessary and in accordance with this Privacy Policy.
9.1 Payment Processing
- Provider: eGHL (Malaysia) — processes FPX, credit/debit card, and e-wallet payments
9.2 Card Recognition and AI Services
- Provider: Advanced card recognition technology — analyzes card images for identification and valuation
9.3 Shipping and Logistics
- Integrated shipping carriers
9.4 Messaging and Communication
- Provider: Third-party IM API — facilitates user-to-user messaging
9.5 Market Data and Analytics
- PriceCharting.com — provides card pricing and market data
- Standard analytics platforms
9.6 Cloud Hosting and Infrastructure
- Cloud service providers for data storage and processing
9.7 No Unauthorized Sales
CardBuster does not sell personal data to third parties for their independent marketing or commercial purposes. We only share data as necessary to deliver platform services or comply with legal obligations.
10. Data Localisation (No Cross-Border Transfer)
10.1 Data Localisation by Jurisdiction
CardBuster stores and processes your personal data within your own country of residence. The personal data of users in Malaysia is collected, stored, and processed in Malaysia by KAD BUSTER COLLECTIONS SDN. BHD., and the personal data of users in Singapore is collected, stored, and processed in Singapore by KAD BUSTER PTE. LTD. We do not transfer your personal data between Malaysia and Singapore, nor between our Malaysian and Singapore entities. Each entity independently maintains data protection standards compliant with the Personal Data Protection Act 2010 (Malaysia) or the Personal Data Protection Act 2012 (Singapore), as applicable to your jurisdiction.
10.2 No Cross-Border Transfer
We do not transfer your personal data to any country outside your country of residence. Where we engage technical service providers to operate the Platform, we require by contract that any processing of your personal data takes place within your own jurisdiction and is protected to a standard no lower than the applicable PDPA. We will not introduce any cross-border transfer of your personal data without first updating this Policy and, where required by law, obtaining your consent.
10.3 Adequate Safeguards
- Data Processing Agreements requiring in-jurisdiction processing
- Contractual data-protection clauses binding all service providers to PDPA-equivalent standards
- Regular review to ensure no personal data is transferred outside your country of residence
11. Data Retention
CardBuster retains personal data only for as long as necessary to fulfill the purposes for which it was collected or to comply with legal obligations.
11.1 Retention Approach
- Account Information: Retained for as long as your account is active and for a reasonable period thereafter to fulfil legal, tax, and regulatory obligations
- Transaction Records: Retained for the period required by applicable tax laws (up to 7 years under Malaysian tax law)
- Communications: Retained for as long as necessary to resolve disputes, and for a reasonable period thereafter
- In-app messaging data between buyers and sellers may be accessed and reviewed by CardBuster’s dispute resolution team if a formal dispute is opened. This data is retained for the duration of the dispute process and for a reasonable period thereafter.
- Marketing Data: Retained until consent is withdrawn or the purpose of collection is no longer served
- Scanned Card Images: Retained for as long as necessary for service improvement purposes, deletable upon request
11.2 Secure Deletion
Upon expiration of retention periods, personal data is securely deleted or anonymized. We do not retain personal data longer than necessary unless required by law.
12. Data Security
12.1 Security Measures
CardBuster implements industry-standard technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, and destruction:
- Encryption (SSL/TLS) for data in transit
- Encryption at rest for sensitive data
- Access controls and role-based permissions
- Regular security audits and penetration testing
- Firewall and intrusion detection systems
- Employee training on data protection and confidentiality
12.2 Data Breach Notification
In the event of a personal data breach, CardBuster will notify affected individuals and relevant regulators (PDPC in Singapore, Commissioner in Malaysia) without undue delay, as required by applicable data protection laws.
12.3 Limitation of Liability
While we implement reasonable security measures, no method of transmission over the internet or electronic storage is completely secure. CardBuster cannot guarantee absolute data security but commits to maintaining security standards consistent with applicable laws.
13. Your Rights
Depending on your jurisdiction (Malaysia or Singapore), you have the following rights concerning your personal data:
13.1 Universal Rights (Malaysia & Singapore)
Right to Access
You may request a copy of the personal data we hold about you and request information on how it is being processed.
Right to Rectification
You may request that we correct, update, or complete inaccurate personal data.
Right to Erasure ("Right to Be Forgotten")
While neither the Malaysia PDPA nor the Singapore PDPA currently provides a statutory right to data deletion equivalent to the GDPR’s “right to be forgotten,” CardBuster voluntarily commits to deleting or anonymising your personal data within a reasonable period of your request, except where retention is required by law, tax obligations, or ongoing dispute resolution.
Right to Withdraw Consent
You may withdraw consent for processing at any time. Withdrawal does not affect the lawfulness of prior processing.
Right to Lodge a Complaint
You have the right to lodge a complaint with the relevant data protection regulator.
13.2 Malaysia-Specific Rights (PDPA 2010)
- Access to Personal Data: Request your personal data in a format intelligible to you
- Correction of Personal Data: Request correction of inaccurate, incomplete, or misleading data
- Withdrawal of Consent: Withdraw consent to stop processing (except where contractually necessary)
- Complaint to Commissioner: File a complaint with the Malaysian Data Protection Commissioner
13.3 Singapore-Specific Rights (PDPA 2012)
- Access to Personal Data: Request access to your personal data held by us
- Correction of Personal Data: Request correction of inaccurate, incomplete, false, or misleading personal data
- Withdrawal of Consent: Withdraw consent to stop collection, use, or disclosure
- Complaint to PDPC: File a complaint with the Personal Data Protection Commission (PDPC)
13.4 Exercising Your Rights
To exercise any of these rights, please contact us at the details provided in Section 16. We will respond to your request within statutory timeframes (typically 14-30 days depending on jurisdiction and request complexity). We may require identity verification before processing your request.
13.5 Right to Opt-Out of Marketing
You may opt out of marketing communications by clicking the "Unsubscribe" link in any promotional email or by contacting us directly.
14. Children's Privacy
CardBuster is not intended for children under 18 years of age. We do not knowingly collect personal data from children below this age. If we become aware that a child under 18 has provided personal data, we will take steps to delete such information and terminate the child's account. Parents or guardians who believe their child has provided personal data should contact us immediately.
15. Updates to This Policy
CardBuster may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated policy on our website and updating the "Last Updated" date. Continued use of CardBuster following notification of changes constitutes your acceptance of the updated Privacy Policy.
16. How to Contact Us
If you have questions, concerns, or wish to exercise your data rights, please contact CardBuster at:
Malaysia Operations
KAD BUSTER COLLECTIONS SDN. BHD.
Level 27, Centrepoint North Tower
Mid Valley City, Kuala Lumpur, 59200
Malaysia
Registration No.: 202401010064 (1555914-M)
Singapore Operations
KAD BUSTER PTE. LTD.
68 Circular Road, #02-01
Singapore 049422
UEN: 202537731G
General Inquiries
Website: https://cardbuster.com
Email: contact@cardbuster.com
17. Jurisdiction-Specific Provisions
17.1 Malaysia — Personal Data Protection Act 2010 (PDPA 2010)
Data Protection Principles
CardBuster complies with the seven data protection principles under PDPA 2010:
- Notice and Choice: Users are informed of data collection and use purposes
- Disclosure: Personal data is not disclosed to third parties without consent, except as required by law
- Security: Personal data is protected against unauthorized loss, alteration, and destruction
- Retention: Data is retained only as long as necessary for stated purposes
- Accuracy: Data is kept accurate and up-to-date
- Access: Individuals can request access to and correction of their personal data
- Function Limitation: Data is used only for the stated purpose and not further processed in a manner incompatible with that purpose
Malaysian Data Protection Commissioner
For complaints regarding PDPA 2010 compliance, contact:
Personal Data Protection Commissioner
Malaysian Communications and Multimedia Commission (MCMC)
63000 Cyberjaya
Selangor, Malaysia
Website: https://www.pdp.gov.my
17.2 Singapore — Personal Data Protection Act 2012 (PDPA 2012)
PDPA 2012 Compliance
CardBuster complies with the Singapore PDPA 2012 requirements, including:
- Consent: Collection and use of personal data requires informed, voluntary consent
- Purpose Limitation: Data is used only for stated purposes
- Notification: Users are notified about data collection and processing practices
- Access and Correction: Users can access and correct their personal data
- Accuracy and Protection: Data is kept accurate and protected against misuse
- Retention and Localisation: Data is retained only as long as necessary and is stored and processed within your own country; we do not transfer personal data across borders
- Openness: Policies are transparent and accessible
Data Breach Notification
CardBuster notifies the Personal Data Protection Commission (PDPC) and affected individuals of data breaches without undue delay as required by PDPA 2012.
Singapore Personal Data Protection Commission (PDPC)
For complaints regarding PDPA 2012 compliance, contact:
Personal Data Protection Commission
Singapore
Website: https://www.pdpc.gov.sg
END OF PRIVACY POLICY
Related Policies
Terms of Service · User Data Deletion
General inquiries: contact@cardbuster.com