Privacy notice
What personal data passes through Perkly, why it is there, who else sees it, and what you can ask us to do about it.
Last updated: 11 September 2026
1. About this notice
Perkly is a digital pass platform for local businesses: loyalty stamp cards, discounts, gift cards and membership passes that live in Apple Wallet and Google Wallet instead of in a wallet full of paper. It is operated by Perkly, an independent not-for-profit project that is not yet registered as a company.
This notice is written to meet Law No. 214/2024 of the Republic of Moldova on the protection of personal data, and the EU General Data Protection Regulation where that applies to us. It covers perkly.md, the business cabinet, and the pass pages your customers open on their phones.
2. Who decides what — controller and processor
When a café uses Perkly to run its stamp card, the café decides that it wants a stamp card, what it asks customers for, and what it does with the result. In the law’s terms the café is the controller and Perkly is the processor: we hold and move that data on the café’s instructions, and we do not use it for our own purposes.
For a different, smaller set of data, Perkly is the controller in its own right — the business accounts themselves, staff logins, applications sent through our sign-up form, and our own security records.
| Data | Controller | Perkly’s role |
|---|---|---|
| Pass holders: contact details, stamps, balances, scan history | The business that issued the pass | Processor |
| Business accounts, staff members, roles and logins | Perkly | Controller |
| Applications from the sign-up form | Perkly | Controller |
| Security, anti-abuse and platform audit records | Perkly | Controller |
3. If you hold a Perkly pass
A pass holds as little as it can. We never ask you for your name, your address, your ID number or your payment details, and nothing on a Perkly pass is used to advertise to you.
| What | Why it exists | Do you have to give it? |
|---|---|---|
| A phone number or email address | So a pass issued to you personally — a gift card, a membership — can be sent to you and restored if you lose your phone | No. A stamp card you add yourself from a QR code at the counter can be completely anonymous. |
| Your card number | The barcode a staff member scans. It is a randomly generated identifier | It is created with the pass. It is not derived from your name or number and reveals nothing about you. |
| Pass contents | Stamps collected, the balance left on a gift card, your membership level | This is the pass itself. |
| Scan history | When your pass was scanned and by which staff member, so the business can resolve a dispute about a stamp or a redemption | Recorded automatically when a staff member scans your pass. |
| Wallet device registration | If you add the pass to Apple Wallet or Google Wallet, the device identifier and push token those services need to keep the pass up to date | Only if you add the pass to your phone’s wallet. |
The public link to your own pass is protected by a secret token contained in the link itself. Anyone with the link can see that pass, so treat it as you would the card itself.
4. If you run a business on Perkly
- Account and staff: name, email address, role in the business, and the business’s own name, category, logo and brand colour.
- Sign-in security: if two-factor authentication is switched on, we email you a short-lived code. Only a hash of that code is stored, it can be used once, and it expires within minutes.
- Audit log: which staff member issued, scanned, stamped, redeemed or cancelled which pass, and when. This is what lets an owner answer "who gave that away?".
- Applications: if you applied through our sign-up form, the company name, contact person, phone, email, category, city and any message you wrote.
Staff who are not the owner see customer contact details masked. That is enforced on the server, so a cashier’s browser is never sent the full number in the first place.
5. Why we are allowed to hold it
| Data | Lawful basis |
|---|---|
| Running a business’s account and cabinet | Performance of our contract with that business |
| Issuing and updating a pass a customer asked for | The business’s contract with its customer, or the customer’s consent, as the business has set it up |
| Marketing messages pushed to a pass | Consent, given to the business when the pass was taken |
| Audit log, rate limiting, abuse prevention, keeping the service secure | Our and the business’s legitimate interest in a service that can be held to account and is not abused |
| Accounting and tax records | A legal obligation we are under |
Where consent is the basis, you can withdraw it at any time, and withdrawing it is as easy as giving it: delete the pass from your wallet, or ask the business to remove you. Withdrawing consent does not undo what was lawfully done before.
6. Who else processes it
We do not sell personal data, we do not share it with advertising networks, and Perkly carries no third-party analytics or tracking scripts of any kind. The services below are the complete list of companies that handle data on our behalf in order to make the product work.
| Service | What it does for us |
|---|---|
| Supabase | Database, sign-in, and storage for business logos and pass artwork |
| Vercel | Runs and serves the application |
| Resend | Sends transactional email — sign-in codes, password resets, pass links |
| Apple | Issues passes into Apple Wallet and delivers pass updates to iPhones. Apple receives the push token for a device that has added a pass |
| Issues passes into Google Wallet and keeps them updated on Android devices |
Each of these is bound to process data only on our instructions. We do not use any of them to profile pass holders.
7. Where the data is
Perkly’s database, sign-in and file storage run in Ireland, and the servers that run the application itself are in Frankfurt, Germany and Paris, France. All of it is inside the European Economic Area; no part of the platform is hosted outside it.
Apple and Google operate globally, so a pass added to a phone’s wallet involves a transfer to those companies’ infrastructure outside Moldova and outside the European Economic Area.
Transfers out of the Republic of Moldova are made under the safeguards the law provides for, including transfers to countries recognised as offering an adequate level of protection and, where that does not apply, standard contractual clauses with the recipient.
8. How long it is kept
| Data | Kept for |
|---|---|
| An active pass and its contents | As long as the business keeps the pass live. Cancelling a pass marks it cancelled and stops it working immediately |
| Audit log entries | For the life of the business’s account — see the note below |
| Two-factor sign-in codes | Minutes. They are single-use and expire |
| An application that never became a customer | one month after the application is decided |
| A business account after it leaves Perkly | one month after the account is closed |
9. How it is protected
- Every business’s rows are isolated from every other business’s at the database level, not merely in application code.
- Customer contact details are masked for staff below owner level, on the server.
- Card numbers and pass links use random, opaque tokens — never sequential numbers that could be guessed or counted.
- Two-factor authentication is available on every account, and sign-in codes are stored only as hashes.
- Uploaded images are checked byte by byte to confirm they really are images.
- Everything travels over HTTPS.
No system is perfect. If you believe you have found a security problem, please write to us before disclosing it publicly, and we will work with you.
10. Your rights
Under Moldovan data protection law you may ask to:
- know whether we hold data about you, and get a copy of it;
- have something inaccurate corrected;
- have your data erased;
- restrict what is done with it while a dispute is resolved;
- object to processing we base on legitimate interests;
- receive the data you gave us in a portable, machine-readable form;
- withdraw a consent you previously gave.
Write to privacy@perkly.md and say what you want. We will answer within the time the law allows and will not charge you for it. We may have to ask you something that confirms the request really comes from you — which for a pass usually means the card number or the contact detail on it.
Perkly does not make automated decisions about individuals that produce legal effects or anything similarly significant. The counts and lists in a business’s dashboard are a tool for staff to read, not a decision the system makes on its own.
11. Complaints
Please raise it with us first — most things are faster to fix directly. But you are entitled to go straight to the supervisory authority, and you can complain to it at any time regardless of what we say.
In the Republic of Moldova that is the National Centre for Personal Data Protection (Centrul Național pentru Protecția Datelor cu Caracter Personal), Chișinău — datepersonale.md.
13. Children
Perkly is a tool for businesses and is not directed at children. We do not knowingly collect data from a child. If you believe a child’s data has reached us through a pass, tell us and we will remove it.
14. Changes to this notice
When this notice changes, the date at the top changes with it. If a change materially affects what we do with your data, we will tell the businesses using Perkly directly rather than relying on you to re-read this page.
15. Contact
Data protection questions and requests: privacy@perkly.md. Anything else: support@perkly.md.
This notice exists in Romanian, Russian and English. If the versions disagree, the Romanian version is the one that governs.