Privacy Policy
This Privacy Policy explains how GenRDP collects, uses, stores and shares personal data when you visit the website, create an account, place an order, make a payment, contact support or use the Services.
For privacy-related questions or requests, contact assistenza@genrdp.com.
1. Data controller
GenRDP acts as the data controller for the personal data processed in connection with customer accounts, orders, billing, support and provision of the Services, except where a third-party provider acts as an independent controller under its own privacy terms.
2. Personal data we collect
Depending on how you interact with GenRDP, we may process:
- Account and identity data: name, surname, company name, email address, telephone number, billing address, country and tax information.
- Account-security data: password hashes, authentication information, account status and security events.
- Order and service data: products ordered, selected country, plan, operator, connection type, service status, activation and expiry dates, assigned technical identifiers and support history.
- Billing data: invoices, amounts, currency, payment method, payment status, transaction references, account-credit movements and tax records.
- Technical data: IP address, timestamps, browser and device information, request logs, security logs and information necessary to operate, protect and troubleshoot the Services.
- Communications: support tickets, emails, complaint details and other messages sent to GenRDP.
- Verification data: verification status, provider session identifiers, outcome and information needed to investigate mismatches, fraud or account abuse.
- Website-usage data: page visits, interactions, approximate location derived from IP address, browser information and analytics identifiers, subject to applicable cookie and consent requirements.
Please do not send passwords, private keys, complete payment-card details or unnecessary identity documents through ordinary email or support tickets.
3. How data is collected
Personal data may be collected:
- directly from you when you register, order, pay or contact support;
- automatically when you use the website or Services;
- from payment, identity-verification and authentication providers;
- from technical infrastructure and mobile-network providers;
- from fraud-prevention and security checks;
- from competent authorities where legally permitted or required.
4. Purposes and legal bases
GenRDP may process personal data for the following purposes:
| Purpose | Typical legal basis |
|---|---|
| Creating and administering customer accounts | Performance of a contract or steps requested before entering a contract |
| Processing orders, payments, renewals and account credit | Performance of a contract and compliance with legal obligations |
| Provisioning, maintaining and troubleshooting Services | Performance of a contract and legitimate interests in reliable service delivery |
| Customer support and complaint handling | Performance of a contract and legitimate interests in resolving requests |
| Accounting, taxation and record keeping | Compliance with legal obligations |
| Preventing fraud, identity theft, abuse and security incidents | Legitimate interests and, where applicable, compliance with legal obligations |
| Requesting and reviewing identity verification | Legitimate interests in fraud prevention, account security and prevention of unlawful use |
| Responding to lawful requests from authorities | Compliance with legal obligations or establishment, exercise or defence of legal claims |
| Website analytics and non-essential measurement | Consent where required by applicable law |
| Essential website operation, session security and language preferences | Performance of the requested service and legitimate interests in operating a secure website |
Where processing is based on legitimate interests, GenRDP considers the necessity and proportionality of the processing and the rights and expectations of affected individuals.
5. Account registration and service provision
Account information is used to identify the Customer, administer the contractual relationship, generate invoices, provide the ordered Service and communicate operational or security information.
Certain information is necessary to create an account or fulfill an order. If it is not provided or cannot be verified where reasonably required, GenRDP may be unable to create the account, accept the order or provide the Service.
6. Identity verification
GenRDP may request identity verification where reasonably necessary to prevent fraud, identity theft, payment abuse or unlawful use of the Services.
The current verification process may use Stripe Identity. Depending on the verification requested, Stripe may process an identity document and a real-time selfie.
GenRDP does not ordinarily download or locally retain the document or selfie images. GenRDP may receive and store the verification status, result, session identifier, timestamps and information necessary to review inconsistencies or manage the account.
Stripe processes verification information according to its own technical, security and retention arrangements. Additional information is available in Stripe’s privacy documentation.
Identity verification is used for fraud prevention and account security. It is not described as a direct anti-money-laundering obligation arising from GenRDP acting as a crypto-asset service provider.
7. Payments
GenRDP may offer payment methods provided by third parties, including Stripe, PayPal, CoinGate, bank-transfer providers and other methods displayed at checkout.
Payment providers may collect and process payment credentials directly. GenRDP generally receives information required to reconcile the transaction, including the amount, currency, payment status, transaction reference, invoice identifier and limited payment-method information.
7.1 Card payments and Stripe
Stripe may process payment-card details, payment authentication information, fraud signals and transaction data. GenRDP does not ordinarily receive complete card numbers or card-security codes.
7.2 PayPal
Where PayPal is selected, PayPal processes the payment under its own terms and privacy policy. GenRDP receives the transaction information needed to reconcile the invoice and provide support.
7.3 Cryptocurrency payments and CoinGate
Cryptocurrency payments are processed by CoinGate. Under the current merchant configuration, GenRDP requests settlement in EUR.
GenRDP processes the payment result and billing information needed to reconcile the invoice, such as the EUR amount, payment status, transaction reference and invoice identifier.
GenRDP does not request or store Customer private keys and does not operate a Customer cryptocurrency wallet. CoinGate may process additional blockchain, wallet-address, network and transaction information under its own privacy terms.
8. Account credit
Where the Add Funds function is used, GenRDP processes the amount added, payment transaction, current balance, credit movements, descriptions and related invoice references.
The current billing system may not technically distinguish every form of purchased, promotional or administratively adjusted credit through a dedicated classification field. Relevant movements may therefore also be identified through transaction records, descriptions and related billing records.
9. Service and technical logs
GenRDP may process connection identifiers, service configuration, access status, expiry dates, IP addresses, ports, protocol information, timestamps and technical error information needed to provide, secure and troubleshoot the Services.
Technical logs must not be interpreted as continuous monitoring of the content of Customer communications. GenRDP may nevertheless preserve and review relevant technical information where reasonably necessary to investigate abuse, fraud, security incidents or lawful authority requests.
10. Recipients and service providers
Personal data may be disclosed, where necessary, to:
- billing and customer-management technology providers;
- payment providers, including Stripe, PayPal and CoinGate;
- identity-verification providers, including Stripe Identity;
- technical infrastructure and mobile-connectivity providers;
- hosting, security, monitoring and email providers;
- Google, where Google Sign-In or Google Analytics is used;
- accountants, legal advisers and other professional advisers;
- competent courts, authorities or law-enforcement bodies where legally required;
- successors involved in a lawful sale or transfer of the relevant business.
Providers receive only the information reasonably necessary for their function, subject to applicable contractual and legal safeguards.
11. International transfers
Some providers may process data outside the European Economic Area or in countries that do not provide the same level of data protection.
Where required, GenRDP relies on an adequacy decision, approved contractual safeguards or another lawful transfer mechanism. Additional information may be requested at assistenza@genrdp.com.
12. Retention
GenRDP applies the following general retention criteria:
- Invoices and fiscal records: generally retained for ten years where required by applicable Italian accounting and tax obligations.
- Account and contractual records: retained for the duration of the relationship and subsequently for the period reasonably necessary to establish, exercise or defend legal claims.
- Technical service logs: generally retained for up to six months, unless a longer period is reasonably necessary for security, investigation, dispute handling or a lawful authority request.
- Support communications: retained for the time necessary to resolve the request and manage related contractual or legal issues.
- Payment records: retained according to accounting obligations, dispute periods and the applicable provider’s retention rules.
- Identity-verification data: verification images and underlying documents are managed by Stripe according to its retention arrangements. GenRDP retains the verification result and related account records only for as long as reasonably necessary.
- Analytics data: retained according to the configured analytics retention period and applicable consent choices.
Specific records may be preserved for longer where required by law, a dispute, fraud investigation, security incident or lawful authority request.
13. Account closure
Closing an account does not require immediate deletion of information that GenRDP must retain for accounting, taxation, fraud prevention, security, dispute resolution or other legal purposes.
Data no longer required will be deleted, anonymised or isolated in accordance with applicable retention procedures.
14. Security
GenRDP uses reasonable technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration or disclosure.
No online service can guarantee absolute security. Customers must protect their credentials, use appropriate passwords and promptly report suspected compromise.
15. Automated decisions
GenRDP may use automated signals to identify potential fraud, payment risk or technical abuse. Material account restrictions and identity-verification issues may be reviewed or applied manually.
GenRDP does not intend to make decisions based solely on automated processing that produce legal or similarly significant effects unless permitted by applicable law and accompanied by the required safeguards.
16. Your rights
Subject to applicable law, you may have the right to:
- request access to your personal data;
- request correction of inaccurate or incomplete data;
- request deletion of data where the legal conditions are met;
- request restriction of processing;
- object to processing based on legitimate interests;
- receive certain data in a portable format;
- withdraw consent at any time, without affecting earlier lawful processing;
- lodge a complaint with the competent data-protection authority.
Requests may be submitted to assistenza@genrdp.com. GenRDP may request reasonable information to verify the requester’s identity.
17. Cookies and similar technologies
The website uses cookies and similar technologies for essential sessions, language preferences, authentication, payment functionality and analytics. Detailed information is provided in the Cookie Policy.
18. External links
The website may contain links to external services, including Telegram and YouTube. Visiting an external website is subject to that provider’s own privacy and cookie practices.
19. Changes to this Privacy Policy
GenRDP may update this Privacy Policy to reflect legal, technical or operational changes. The current version and its effective date will be published on this page.
20. Contact
For privacy questions or to exercise your rights, contact assistenza@genrdp.com.
