Home VPN Solutions Security Why Genite How It Works About Us FAQ Contact
Legal & Compliance

Privacy Policy

How Genite LTD collects, handles, retains, and protects personal and operational information.

Last updated: 29 October 2026

Genite LTD ("Genite", "we", "us", or "our") is a company incorporated in Cyprus (Registration No. HE 498311, incorporated on 14 September 2026) with its registered office at 34 Pavlou Liasidi, Pyrgos, 4529 Limassol, Cyprus (Telephone: +357 99 780278; Email: [email protected]). This Privacy Policy explains our practices regarding the collection, processing, retention, and protection of personal information when you access geniteltd.com (the "Site") or engage with our VPN infrastructure and connectivity solutions.

1. Data Controller Information

Genite LTD acts as the Data Controller under the European Union General Data Protection Regulation (Regulation (EU) 2016/679 - "GDPR") and the Cyprus Law on the Protection of Natural Persons with regard to the Processing of Personal Data (Law 125(I)/2018). For questions regarding data processing or to exercise statutory privacy rights, contact our Data Protection point of contact at [email protected].

2. Information We Collect

2.1 Communication and Inquiry Information

When you contact us through our website contact form, telephone, or direct email, we collect the details you voluntarily submit:

  • Full name and professional contact email
  • Telephone number (if optionally provided)
  • Company or organization name (optional)
  • Service interests (e.g., Personal VPN, Business Remote Access, Office-to-Office VPN, Dedicated Server)
  • Message content and connectivity requirements

Security Warning Notice: For your protection, users must never submit passwords, VPN private cryptographic keys, payment card details, or confidential credentials through website contact forms or unencrypted communications.

2.2 Commercial and Account Administration Information

For active service subscribers and corporate clients, we collect administrative and billing details necessary to establish and maintain contractual service agreements, including invoicing details, corporate registration, authorized administrative contacts, and transaction history.

2.3 VPN Operational Connection Data & Traffic Handling

Our core operational architecture is engineered around the principle of minimal data collection necessary to maintain technical connectivity:

  • No Browsing Activity Logging: We do not inspect, record, log, or monitor user browsing histories, web destinations, visited URLs, DNS query contents, or data payloads traveling through encrypted VPN tunnels.
  • Authentication Data: To authenticate authorized connections, our servers store public cryptographic keys (e.g., WireGuard public keys) and associated client configuration profiles. Private keys remain exclusively on client devices.
  • Transient Operational Telemetry: To balance server capacity, prevent abuse, and diagnose network routing issues, servers may record transient aggregate bandwidth volume and active session indicators in volatile system memory. This operational telemetry is non-content and discarded regularly.

3. Purposes and Legal Bases for Processing

We process personal data under the following GDPR legal bases:

  • Contract Performance (Article 6(1)(b)): To process inquiries, provide formal service quotations, configure VPN tunnels, allocate dedicated resources, and fulfill service agreements.
  • Legitimate Interests (Article 6(1)(f)): To maintain network stability, prevent unauthorized intrusions, safeguard infrastructure availability, and manage client communications.
  • Legal Obligation (Article 6(1)(c)): To maintain statutory corporate, accounting, and tax records in compliance with Cyprus and EU corporate regulations.
  • Consent (Article 6(1)(a)): Where explicitly provided, such as submitting an inquiry with acknowledgement of this policy.

4. Data Retention Periods

We retain personal data only for as long as necessary to satisfy the specific purposes for which it was gathered:

  • General Inquiries: Contact form submissions and email inquiries that do not result in a commercial service agreement are retained for up to twelve (12) months from resolution to address follow-up technical queries, after which they are securely deleted.
  • Client & Account Records: Contractual documents, service schedules, order confirmations, and related correspondence are retained for the duration of active service plus up to seven (7) years following termination to fulfill statutory tax, audit, and commercial accounting requirements under Cyprus law.
  • Operational Telemetry: Server-side volatile connection states and aggregated telemetry counters are non-persistent and cycled out within 24 to 72 hours.

5. Infrastructure Providers and Relevant Data Locations

Genite operates and manages VPN infrastructure provisioned through reputable enterprise-grade datacenter and carrier partners. Server nodes and data processing facilities are established in verified jurisdictions:

  • Primary Infrastructure Locations: Germany (Frankfurt), the United Kingdom (London), the Netherlands (Amsterdam), and Cyprus (Limassol).
  • Data Residency & Pre-Order Scoping: For corporate, dedicated server, and site-to-site deployments, specific server locations, routing pathways, and physical data facilities are reviewed and formally agreed in the quotation prior to provisioning.
  • International Transfers: Where technical support or routing involves data transfer outside the European Economic Area (EEA), such transfers are governed by European Commission Adequacy Decisions or Standard Contractual Clauses (SCCs) to guarantee an equivalent level of protection.

6. Third-Party Disclosures

We do not sell, rent, or trade personal data. Information is disclosed only to vetted technical sub-processors essential to service delivery (e.g., licensed carrier facilities, secure email hosting, and certified accounting fiduciaries), under strict data processing agreements.

7. Your Statutory Rights Under the GDPR

As a data subject within the EEA or Cyprus, you hold the following rights:

  • Right of Access: Request confirmation and copies of personal data held about you.
  • Right to Rectification: Request correction of inaccurate or incomplete data.
  • Right to Erasure ("Right to be Forgotten"): Request deletion of data where retention is no longer legally justified.
  • Right to Restriction of Processing: Restrict processing under specified legal conditions.
  • Right to Data Portability: Receive your provided data in a structured, machine-readable format.
  • Right to Object: Object to processing based on legitimate interests.
  • Right to Lodge a Complaint: You have the right to lodge a formal complaint with the supervisory authority: Commissioner for Personal Data Protection of the Republic of Cyprus (Website: www.dataprotection.gov.cy).

8. Policy Updates

We may update this Privacy Policy periodically to reflect technological adjustments, regulatory developments, or infrastructure enhancements. The revised date at the top of this policy indicates when changes take effect.