Draft — not in force
This is a draft. It has not been reviewed by a lawyer and it binds nobody.
It was written from how the Perun system actually behaves today, so that counsel has something accurate to correct instead of a blank page or a generic template. It is not the published document, it creates no rights and no obligations, and it must not be relied on. Nothing here is legal advice.
Highlighted text marks a fact about the company that has deliberately not been invented. Every one of them must be replaced before this page is published.
Privacy policy
How Perun collects, uses and stores your personal data, and the rights you have over it under the GDPR.
Draft 0.1 — prepared 1 September 2026 — not in force
1.Who is responsible for your data
The controller of your personal data is COMPANY LEGAL NAME, a COMPANY LEGAL FORM registered under number COMPANY UIC at COMPANY REGISTERED ADDRESS.
For anything about data protection, write to DPO CONTACT. Ordinary support questions go to support@perun.green.
2.The short version
- We hold your phone number or Apple sign-in because that is how you sign in; your name and picture if you give them; your rentals; and a reference to your customer record at Stripe.
- We never see your card number. It goes from your device to Stripe.
- Your location never reaches us. The app asks for location so the map can centre on where you are. That happens on your phone; the coordinates are not sent to us and the station list the app draws is the same for everyone.
- We do not sell your data, we do not profile you, and we make no automated decisions about you.
- Deleting your account blanks your name and scrubs your phone number and email. Your rentals are kept, because they are financial records — section 8 explains exactly what that means.
3.What we collect, why, and on what legal basis
| What | Where it comes from | Why | Legal basis | How long |
|---|---|---|---|---|
| Mobile phone number | You, when you sign in | To sign you in, to send the one-time code, and to reach you about a rental | Performance of a contract, Art. 6(1)(b) | Until you delete your account, then scrubbed by our authentication provider |
| Email address | You, or Apple’s private relay if you use Sign in with Apple | The same as above | Art. 6(1)(b) | As above |
| First name, last name, profile picture | You, optionally, in the app | To show whose account it is and help support recognise you | Art. 6(1)(b) | Blanked when you delete your account |
| Marketing preference | You, in the app | To record whether you agreed to marketing | Consent, Art. 6(1)(a); Art. 6(1)(c) for keeping the record of it | Cleared when you delete your account |
| Payment preference (whether you use Apple Pay or Google Pay) | The app | To show the right payment button | Art. 6(1)(b) | Until you delete your account |
| Stripe customer reference | Created the first time you pay | The link between a rental and the payment that settled it | Art. 6(1)(b); Art. 6(1)(c) for accounting | Kept after deletion — see section 8 |
| Rental records: which station, which battery, start and end times, the tariff applied, the amount held and the amount taken, and the Stripe payment reference | Generated when you rent | To run the rental, bill it, answer disputes about it, and meet accounting and tax obligations | Art. 6(1)(b) and Art. 6(1)(c) | ACCOUNTING RETENTION PERIOD |
| Push notification token and device platform (iOS or Android) | Your device, if you allow notifications | To send the three rental messages in section 5 | Art. 6(1)(b) | Switched off when you delete your account |
| Notification records — what we sent and when | Generated | So each message is sent once and only once, and so support can see what you were told | Art. 6(1)(b) and Art. 6(1)(f) | With the rental |
| Audit records — which rental changed state, when, and whether a person or the system did it | Generated | Security, fraud prevention, and resolving disputes about money | Legitimate interests, Art. 6(1)(f) — an accurate and tamper-evident record | OPERATIONAL LOG RETENTION PERIOD |
| Messages from the cabinets, relayed by the vendor’s cloud | Carku | To know that a bank actually came out, and that one actually went back in | Art. 6(1)(b) and Art. 6(1)(f) | OPERATIONAL LOG RETENTION PERIOD. They name a station, a battery and a rental number — not you |
| Crash and performance diagnostics from the app | Your device | To find and fix faults | Legitimate interests, Art. 6(1)(f) | Per Sentry’s retention — section 6 |
| Visits to perun.green | Your browser | To count page views | Legitimate interests, Art. 6(1)(f) | See section 4 |
We do not collect your location. The app asks for location permission only so the map can centre on where you are, and that calculation happens on your phone. The venue list the app draws is the same list for every user, so there is nothing for us to learn from it.
5.The notifications we send
If you allow notifications, we send exactly three kinds, and all three are about a rental you have started:
- a bank has been released and the rental has started;
- the rental has ended, with the amount charged;
- a reminder shortly before we have to take payment on a rental that is still running — see section 8 of the terms.
These are service messages, not marketing. You can switch them off in your phone’s settings; the rental works either way.
6.Who else processes your data
| Who | What they do for us | What they receive |
|---|---|---|
| Supabase | Our database, sign-in, and the server functions that run rentals | Everything in section 3, except card details |
| Stripe | Payments and card storage | Your name if you gave one, your phone number and email address, your Perun user identifier, and the rental amounts. Your card details go from your device straight to Stripe and never reach us |
| Vonage | Sends the SMS carrying your one-time sign-in code | Your phone number and the code |
| Apple | Sign in with Apple; push delivery to iPhones; the map on iPhone | An Apple account identifier if you use Sign in with Apple; your device push token and the text of the message; map requests made by your device |
| Push delivery to Android phones; the map on Android | Your device push token and the text of the message; map requests made by your device | |
| Sentry | Crash and performance reports from the app | Diagnostic data about the app and the device and which screens you were on. We do not send your name, phone number or email address |
| Vercel | Hosts perun.green and counts page views | Your IP address, your browser’s user agent, and the page you visited |
| Carku | Runs the cabinets’ own cloud, which relays "release a bank" and "a bank came back" | A station identifier, a battery identifier and the rental’s internal number. Not your name, phone number, email address or card |
Our database and server functions run inside the EU — the Supabase project is hosted in Ireland.
7.Transfers outside the EEA
Some of the providers above are established outside the EEA, or use teams outside it, so your data may be transferred there.
Where that happens the transfer relies on either a European Commission adequacy decision or the Commission’s standard contractual clauses, together with any additional safeguards required. Ask DPO CONTACT for the details for a particular provider.
8.How long we keep things
The table in section 3 gives a period for each item. Two things deserve setting out on their own.
- What deleting your account does
- It blanks your first name, last name and profile picture, clears your marketing preference, marks the account deleted, and switches off every push registration on it. Your phone number and email address are then scrubbed by our authentication provider — which frees the number, so you can sign up again later with the same one. Your sign-in stops working immediately.
- What is kept, and why
- Your rentals. They record what was held, what was taken and which Stripe payment settled it, and we have accounting and tax obligations over them. They stay attached to your now-blank account record, and we keep your Stripe customer reference, because it is the only link from a kept rental to the payment behind it. The personal data behind that reference is Stripe’s own record, kept under Stripe’s retention rules; you can ask Stripe about it directly.
Being plain about what that means: a kept rental is not anonymous. It no longer carries your name, number or email address, but it can still be connected back to you through Stripe. So we treat it as personal data, and your rights in section 9 apply to it, within the limits described there.
Our audit records and the raw messages from the cabinets are append-only: our own systems cannot alter or delete an individual entry. They are removed wholesale at the end of OPERATIONAL LOG RETENTION PERIOD.
9.Your rights
Under the GDPR you have the right to:
- Access
- A copy of the personal data we hold about you, and an explanation of what we do with it.
- Rectification
- Correction of anything inaccurate. You can edit your name and picture yourself in the app.
- Erasure
- Deletion. It is in the app under Settings. It will refuse while a rental is unfinished, and it does not extend to the rental records we are required to keep — see section 8.
- Restriction
- To have us stop using data while a dispute about its accuracy or our grounds is resolved.
- Portability
- The data you gave us, in a structured, commonly used, machine-readable form, where we process it on the basis of consent or a contract.
- Objection
- To processing we base on our legitimate interests — the audit records, the app diagnostics and the website counts. Tell us your reasons and we will stop unless we have compelling grounds that override them.
- Withdraw consent
- At any time, for anything you consented to. Withdrawing does not affect what was done before you withdrew.
Ask at DPO CONTACT, or at support@perun.green. We answer within one month, and may extend that by two months for a complex request — we will tell you if we do, and why. There is no charge, unless a request is manifestly unfounded or excessive.
We may need to satisfy ourselves that you are who you say you are before we answer. For an account that has already been deleted the phone number and email address are gone, so identifying you may not be possible — say so when you write and we will explain what we can and cannot do.
If you are unhappy with how we handle it, you can complain to a supervisory authority: SUPERVISORY AUTHORITY.
10.Automated decisions and profiling
We do not make decisions about you by automated means alone that produce legal effects or similarly significantly affect you, and we do not profile you. Whether a rental can start depends on two things only: whether your card issuer authorises the hold, and whether you already have a rental open.
11.Children
Perun is not for people under 18, and we do not knowingly collect data about children. If you believe a child has an account, write to support@perun.green and we will remove it.
12.Keeping data safe
Card details never reach our systems. Access to the database is restricted per account by the database itself, so a signed-in customer can read their own rows and nothing else. Everything that moves money runs on the server, never in the app. Audit records cannot be altered after the fact.
13.Changes to this notice
Any new version is published here with a new date at the top. Where a change matters to you, we will tell you in the app before it takes effect.
14.Contact and complaints
- Data protection contact
- DPO CONTACT
- Support
- support@perun.green
- Post
- COMPANY LEGAL NAME, COMPANY REGISTERED ADDRESS
- Supervisory authority
- SUPERVISORY AUTHORITY