Privacy Policy and Personal Data Processing Notice

Last updated: October 2026

This Privacy Policy is provided pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR), Legislative Decree 196/2003 as amended, and in compliance with Google Play Store Developer Policies regarding the use of high-risk permissions (Default SMS Handler, READ_SMS, SEND_SMS, RECEIVE_SMS, READ_CONTACTS, READ_PHONE_STATE).


1. Data Controller

The Data Controller is the entity that determines the purposes and means of the processing of personal data:

2. Data Processors and Data Sovereignty

Pursuant to Article 28 of the GDPR, the Data Controller utilizes third parties designated as Data Processors:

3. Pure-Bridge Operating Architecture and "Zero Local Storage" Policy (Stateless)

The GenioSms application is designed to operate as a local SIM-based SMS Gateway (SIM-based SMS Gateway / App Bridge) with bidirectional communication (A2P and P2A) between the mobile device and the Cloud/CRM server.

A. "Zero Local Storage" Policy (Stateless Pure-Bridge)

The application does not store, save, or maintain any historical archive of SMS messages or contacts in the internal memory or local databases of the mobile device. The App receives sending commands and processes incoming messages on the SIM exclusively in volatile memory (RAM) for the sole purpose of forwarding them via API/Socket to the server, clearing the memory immediately after execution.

B. Background Operation and WakeLock

To ensure real-time synchronization, the App uses resilient background services and system WakeLock management (operating even in Deep Doze state when the screen is off). These system resources are used exclusively to maintain network connectivity and process SMS messages, without tracking geographical location or collecting unrelated data.

4. Sensitive Permissions and Justification

To fulfill its primary functions as an SMS Gateway and Bridge, GenioSMS requires the activation of the following high-risk Android permissions:

5. Security, Encryption, and Routing

6. P2A Flows, Opt-In, Opt-Out, and CRM Automations

For incoming messaging flows (P2A - Person to Application): SMS messages received on the SIM (e.g., survey responses or opt-out commands like "STOP") are forwarded to the CRM server. Data is processed solely to execute the automated action requested by the user (e.g., Opt-In subscription or Opt-Out list removal).

7. Purposes and Retention Policy

8. Data Subject Rights (Arts. 15–22 GDPR)

Users may at any time exercise their rights under the GDPR regarding the Data Controller (Access, Rectification, Erasure/Right to be Forgotten, Data Portability, and Revocation of permissions by uninstalling the app or removing it as the default SMS app).

To exercise these rights, users may write to: geniosms.com@gmail.com. Users also have the right to lodge a complaint with the Data Protection Authority (www.garanteprivacy.it).

9. Changes to this Privacy Policy

The Data Controller reserves the right to update this Privacy Policy to adapt it to regulatory developments or technical changes in the App. Updates will be published on the official web page with the revised date.