Privacy Policy
Effective Date: March 31, 2026
The controller of your personal data collected through this website is Pearl Electric Motors Vadym Podkopaiev (Tax Identification Number NIP: 1133182578), with its registered office at: ul. Ostrobramska 73C/159, 04-175 Warszawa, Poland.
For all matters related to the protection of personal data, information processing via the waitlist, and the exercise of your rights, you can contact us by email at: privacy@pemeu.com.
1. What personal data do we collect
During your interaction with our website and the use of the waitlist / preorder page form, we may collect and process the following categories of personal data:
Data provided directly in the form: email address, first and last name, customer type (Personal / Business), country / location, as well as information about the product parameters you selected (within the waitlist configurator).
Request, consent and confirmation data (Logs): information confirming your request to join the waitlist and receive the product release notification, any optional consent to receive further personalized offers, confirmation of having read the Terms & Conditions and the Privacy Policy, as well as the date, time and basic system details related to these actions. We collect these data in order to demonstrate compliance with legal obligations, the proper conclusion of the electronic service agreement and, where applicable, the lawful collection of consents.
Technical and tracking data (Cookies): information automatically collected during your visit to the website using cookies and local storage (e.g., saving your privacy settings choices in the Framer system, as well as analytical data via Google Analytics, provided you have given your prior consent). A detailed description of how these technologies work is provided in Section K of this Policy.
2. For what purposes and on what legal basis the data is processed
We process users' personal data to manage the waitlist, maintain a database of individuals who have expressed interest in the product, for internal launch planning, and for electronic communication regarding the product release and subsequent offers.
Detailed information on the purposes, scope of data, legal bases, and retention periods is provided in the table below:
1. Joining the waitlist and providing the waitlist service
For the purpose of registering the user on the waitlist and providing the electronic waitlist service requested by the user, we process the following data: email address and, if provided voluntarily, first and last name, customer type and country / location. The legal basis for this processing is Article 6(1)(b) GDPR, i.e. taking steps at the request of the data subject and the performance of a contract for the provision of an electronic service. These data are stored until the waitlist service is completed, i.e. until the product release notification is sent, or until the user resigns from the waitlist earlier. After that, limited data may be stored for the period necessary to demonstrate compliance, handle complaints and defend against potential claims.
2. Internal analytics and planning
For the purpose of internal analytics and planning, including demand research, logistics, and market evaluation, we process country/location data in an aggregated or anonymized form, without identifying a specific person. The legal basis for this processing is the legitimate interest of the controller under Article 6(1)(f) GDPR, combined with processing rules applicable to statistical purposes. These data are stored until they are aggregated or anonymized, after which the information ceases to be personal data.
3. Sending an email with information about the product release
For the purpose of sending a release notification to the user, we process the email address and, if provided, the first name. The legal basis for this processing is Article 6(1)(b) GDPR, because sending the release notification constitutes the core element of the waitlist service requested by the user. The use of the user’s email address for this purpose is based on Article 398(2) of the Polish Electronic Communications Law (PKE), i.e. the address is provided specifically for receiving this communication. These data are stored until the release notification is sent or until the user resigns from the waitlist earlier.
4. Sending individualized offers (profiling)
If the user separately chooses to receive additional individualized offers after the product release, we may process the following data: email address, first name, customer type, country / location and selected product parameters. The legal basis for the processing itself, including profiling for offer selection, is the legitimate interest of the controller under Article 6(1)(f) GDPR, in the form of direct marketing. The legal basis for sending such offers by electronic means is a separate voluntary consent under Article 398(1) point 2 of the Polish Electronic Communications Law (PKE). These data are stored until an objection to processing for direct marketing purposes is submitted or until consent to electronic communication is withdrawn.
Important details regarding processing:
Waitlist communication: Joining the waitlist means that the user requests to receive a product release notification as the core element of the waitlist service. If the user resigns from the waitlist before the launch, we will stop providing this service and remove the user from the active waitlist database. In contrast, receiving additional personalized offers remains entirely voluntary.
Profiling for offer selection: If you have consented to receive an offer, we use your data (selected product parameters, country, and customer type) for the automated selection of this offer (profiling). The consequence of this is that you will receive an offer that best matches your interests. This does not produce any legal or financial effects concerning you. You have the absolute right to object to such profiling at any time.
Aggregated analytics: Data regarding your country/location, used for internal planning (e.g., logistics), is immediately separated from your email address (anonymized), turning into general statistics that make it impossible to identify a specific person.
3. Is the provision of data mandatory (Consequences of failing to provide data)
The provision of personal data via the form on the website is voluntary. However, providing certain data is necessary if you want us to provide the waitlist service requested by you.
In accordance with data protection regulations, we clearly distinguish between mandatory and voluntary data:
1. Mandatory data (Email address) Providing an email address is necessary for us to identify your request, register you in our system and provide the waitlist service.
Consequence of failing to provide data: If you do not provide an email address, we will be unable to add you to the waitlist and provide the requested service.
2. Voluntary data (Name, Customer type, Country / Location, Product configuration) Providing any other data in the form (customer type Personal/Business, first and last name, country, and the product parameters you selected) is entirely voluntary and is not a condition for joining the waitlist.
Consequence of failing to provide data: Failure to provide this data does not prevent your registration on the waitlist. The only consequence of not providing this data is that we will not be able to personalize our communication with you (e.g., address you by name), we will not be able to adapt the future offer to the specifics of your market or business needs, and your location will not be included in our overall internal logistics planning statistics.
3. Request to receive the release notification as part of the waitlist service Joining the waitlist means that you request us to send the product release notification to the email address you provided. This is an element of the waitlist service itself and not a separate optional consent for additional marketing communication.
Consequence of failing to request this service / provide the required email address: we will not be able to register you on the waitlist.
4. Consent to individualized offers (Optional) Granting consent to receive additional personalized offers selected on the basis of your location, customer type or product configuration is completely voluntary.
Consequence of failing to provide consent: This is not a condition for joining the waitlist. If you do not check the appropriate box, you may still successfully join the waitlist and receive the release notification, but you will not receive additional individualized offers.
4. To whom data may be transferred (Recipients of the data)
To ensure the proper operation of the website, the waitlist, and our internal organization, we use the services of trusted third-party entities. In accordance with legal requirements (Art. 13(1)(e) GDPR), your personal data may be disclosed to the following categories of recipients:
Entities processing data on our behalf (Processors) We transfer data to providers of technical, cloud, analytical, and organizational solutions who process it exclusively on our behalf and according to our instructions based on appropriate data processing agreements (in accordance with Art. 28 GDPR). At the current stage, such entities include:
Framer B.V. – provider of the technical environment for website hosting, registration form operation, and the consent management mechanism;
Google Ireland Limited / Google LLC – provider of Google Workspace cloud solutions (including Google Drive and Google Sheets) as tools for secure internal storage and database organization, as well as the provider of the
Google Analytics tool (data is transferred only provided you give your prior consent to the use of analytical cookies).
Celonis Inc. (Make.com) – provider of automation and data integration services; used to automate the delivery of confirmation emails and synchronize waitlist data with internal storage systems (Google Sheets).
Professional advisors and consultants As needed, your data may be transferred to entities that provide the controller with legal, accounting, technical, or consulting support (e.g., law firms or IT support services), provided this is necessary for the proper functioning of the project and these individuals are bound by a statutory or contractual obligation of confidentiality.
Public authorities Your personal data may be disclosed to competent public authorities (e.g., courts, police, tax authorities) if such an obligation arises directly from applicable law (in accordance with Art. 6(1)(c) GDPR). When receiving such data in the context of a specific investigation, these authorities are not considered typical recipients but process the data as independent controllers under the relevant laws (Recital 31 GDPR).
Important reservation regarding production and logistics partners: Please note that your personal data provided via the waitlist form (such as your email address or name) is not transferred to our potential production or logistics partners. For the purposes of demand planning, production, logistics, and determining priority markets, we use exclusively consolidated, statistical, or aggregated data (e.g., the total number of requests from a specific country). In accordance with Recital 26 GDPR, such anonymized data is not considered personal data, as it does not allow for the identification of a specific individual in any way.
5. Are data transferred outside the EEA (European Economic Area)?
Due to the use of solutions from trusted international providers (in particular, Google Workspace services, Google Analytics from Google LLC, and Framer technical infrastructure), your personal data may in certain cases be transferred to third countries outside the European Economic Area (EEA), in particular to the United States of America.
In accordance with the requirements of Art. 13(1)(f) GDPR, we guarantee that such transfer takes place only on the condition that an adequate level of protection of your rights and freedoms is ensured. To legalize such transfers, we rely on the following legal mechanisms:
Adequacy decision (Art. 45(3) GDPR) The transfer of data to certain organizations in the USA (in particular to Google LLC) is carried out on the basis of a valid implementing decision of the European Commission, which confirms an adequate level of protection. This mechanism (known as the EU-U.S. Data Privacy Framework – DPF) applies provided that the specific service provider holds a valid certification under this framework and has committed to complying with European privacy standards.
Standard Contractual Clauses (Art. 46(2)(c) GDPR) In cases where an adequacy decision cannot be applied (e.g., if the provider is not a DPF participant or if data is transferred to its sub-processors in other third countries), the transfer is carried out subject to appropriate safeguards, in particular by signing Standard Contractual Clauses (SCC) adopted by the European Commission. These clauses legally oblige the provider to ensure data protection at the level required in the EU.
Right to obtain a copy: The user has the right to obtain detailed information about the specific third countries to which their data is transferred, as well as to receive information about the appropriate security safeguards or a copy of these safeguards by contacting us at: privacy@pemeu.com.
6. How long is the data stored (Retention period)
In accordance with the principle of storage limitation (Art. 5(1)(e) GDPR), we keep your personal data in a form which permits identification for no longer than is necessary for the purposes for which they were collected.
The criteria and retention periods depend on the specific purpose of processing:
Waitlist data and internal contact database Your data is stored for as long as necessary to provide the waitlist service, i.e. until the product release notification is sent or until you resign from the waitlist earlier. After completion of the service, limited data may be stored for the period necessary to demonstrate compliance with legal obligations, handle complaints and defend against potential claims.
Data for direct marketing purposes (release email and offers) If you separately consented to receive additional individualized offers, your data will be kept for this purpose until one of the following events occurs:
you withdraw your consent to electronic communication, or
you object to the processing of your data for direct marketing purposes. Upon the occurrence of either of these events, we will stop sending such messages and remove your data from the relevant marketing mailing lists.
Data for internal analysis and planning (Country / Location) Information about your country is stored in connection with your email only until its technical aggregation or anonymization. Once this information is converted into general statistics (e.g., "100 requests from France") and irreversibly separated from your identity, it ceases to be personal data and can be stored indefinitely.
Data collected via cookies and tracking technologies Data collected via analytical tools (e.g., Google Analytics) is stored for the lifespan of the specific cookie on your device, as determined by the technology provider, or until you withdraw your consent via the privacy banner settings on our website.
7. Rights of the data subject (Your rights under the GDPR)
Under the provisions of the General Data Protection Regulation (GDPR), you have a wide range of rights regarding the control of your personal data. You have the right to request from us:
Right of access (Art. 15 GDPR): You have the right to obtain confirmation as to whether or not we are processing your personal data, and, where that is the case, access to the personal data and detailed information about the purposes of the processing, the categories of data concerned, and the envisaged retention period.
Right to rectification (Art. 16 GDPR): You may request the immediate rectification of inaccurate personal data concerning you, or to have incomplete personal data completed.
Right to erasure / "right to be forgotten" (Art. 17 GDPR): You have the right to request the erasure of your personal data, in particular where the personal data are no longer necessary in relation to the purposes for which they were collected, or if you have successfully objected to their processing for direct marketing purposes.
Right to restriction of processing (Art. 18 GDPR): You may request the temporary suspension of the processing of your data (except for storage), for example, if you contest the accuracy of the data or the lawfulness of the processing.
Important clarification regarding the right to data portability (Art. 20 GDPR): The right to receive personal data in a structured, commonly used and machine-readable format applies where the processing is based on consent or on a contract. Therefore, this right may apply to data processed for joining and operating the waitlist. It does not apply to processing carried out solely on the basis of our legitimate interest, such as certain direct marketing and profiling activities.
Right to lodge a complaint (Art. 77 GDPR): If you consider that the processing of your personal data infringes the GDPR, you have the absolute right to lodge a complaint with a competent supervisory authority. In Poland, this authority is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych - PUODO).
8. Right to withdraw consent to electronic communication
If you separately consented to receive additional individualized offers by email, you have the right to withdraw this consent at any time. Withdrawal does not affect the lawfulness of communication carried out before the withdrawal. You can withdraw consent as easily as you gave it, for example by using the unsubscribe link included in such messages or by contacting us at: privacy@pemeu.com. Withdrawal of this consent does not by itself remove you from the waitlist service; however, if you also resign from the waitlist, we will stop providing the release notification service as well.
9. RIGHT TO OBJECT (SPRZECIW) – Important information
In accordance with Article 21 GDPR, you have the right to object at any time to the processing of your personal data where such processing is based on our legitimate interest. In particular, this applies to processing for direct marketing purposes, including profiling carried out in order to select individualized offers.
Consequences of objecting: If you object to the processing of your data for direct marketing purposes, including profiling related to such marketing, we will immediately stop processing your data for those purposes.
You can exercise this right by simply sending a request to the email address: privacy@pemeu.com.
10. Information about cookies and tracking technologies (Tracking tools)
Our website uses cookies, Local Storage technology, and other similar technologies. Since we do not create a separate Cookie Policy, all necessary information about how and why we use these technologies is provided in this section.
In accordance with Art. 399(1) of the Polish Electronic Communications Law (PKE), storing information on your terminal equipment or gaining access to it is permitted only with your prior, informed, and unambiguous consent. The only exception applies to technologies that are technically necessary to provide you with the service you are requesting (Art. 399(3) PKE).
Given the above, we divide the technologies used on our website into two categories:
Technically necessary technologies (No consent required) These technologies are critical for the proper functioning of the website and for remembering your privacy settings.
Framer (Local Storage): Our website is built and hosted on the Framer platform (Framer B.V., Netherlands). We use your browser's local storage (specifically, the technical record framerCookiesConsentMode) solely to remember your decision regarding cookie consent (whether you accepted or rejected them).
Legal basis: According to Art. 399(3) PKE, the use of this technology does not require your consent, as it is technically necessary for the website to function correctly and respect your privacy choices.
Analytical and statistical technologies (Consent required) We use these tools only if you actively give your consent by clicking the appropriate button (e.g., "Accept") on our privacy banner. Until consent is granted, all analytical scripts remain blocked.
Google Analytics: A tool provided by Google (Google Ireland Limited / Google LLC) that allows us to collect anonymous website traffic statistics, analyze user behavior, and evaluate the effectiveness of our waitlist form.
Framer Analytics: Internal analytics from the Framer platform (technical connections to events.framer.com), which helps us understand the technical performance metrics of the website.
Data transfer outside the EEA: If you consent to the use of Google Analytics, data about your use of the website (including your IP address) may be transferred to Google LLC servers in the USA. As stated in Section F of this Policy, such transfer is protected by the EU-U.S. Data Privacy Framework (adequacy decision of the European Commission pursuant to Art. 45(3) GDPR).
Legal basis: Your voluntary consent (Art. 6(1)(a) GDPR and Art. 399(1) PKE).
Marketing tools (Meta Pixel, etc.) At the time of publishing this Policy, we do not use marketing tracking technologies (such as Meta Pixel) to display targeted advertising. If we decide to integrate such tools in the future, they will only be deployed subject to obtaining your separate and prior consent, and this Policy will be updated accordingly.
How to change settings or withdraw consent? In accordance with Art. 7(3) GDPR, you have the right to withdraw your consent to the use of analytical cookies at any time. The law requires that withdrawing consent must be as easy as giving it.
Management via the website: You can change your settings or withdraw your consent at any time by using the "Manage Cookies" link available in the footer of every page on our website. Clicking this link will reopen the privacy banner, allowing you to modify your choices.
Browser settings: You can also block or delete cookies and clear Local Storage directly through your web browser settings. Please note, however, that managing consents via our banner is the most accurate way to control which scripts are executed during your visit to our website.
11. Contact with the controller
The controller of your personal data is Pearl Electric Motors Vadym Podkopaiev (Tax Identification Number NIP: 1133182578), with its registered office at: ul. Ostrobramska 73C/159, 04-175 Warszawa, Poland.
We strive to ensure maximum transparency and ease of communication regarding your privacy matters. In accordance with the requirements of data protection legislation (GDPR), we have established a dedicated communication channel for our users.
You can contact us with any questions concerning:
the processing of your personal data collected via the waitlist form;
the exercise of your rights guaranteed by the GDPR (in particular, the right of access to information, rectification, erasure, or restriction of processing);
the withdrawal of your consent to receive marketing emails;
the submission of an objection (sprzeciw) to the processing of your data based on our legitimate interest or to profiling.
For a quick and effective resolution of your requests, please send them by email to our dedicated address: privacy@pemeu.com.