Effective as from 27 February 2020
- Controller and Processors
- Consent and Limits to Use
- Data Protection
- Website Visitors
- Notifications and Newsletter
- Product Use
- Text Messages
- Customer Support
- Third Party Content
- Managed Private Cloud
- Self-Hosted Solution
- Anonymization and Pseudonymization
- Previous Product Versions
- Your Rights
- Contact Us
ISL Online Headquarters ("we", "us", "our") has prepared this policy to provide information about the collection and processing of personal data when using the "ISL Online" products and services offered on the official websites (islonline.com and islonline.net). The main purpose of the ISL Online software is to allow IT professionals and helpdesk technicians ("Operator") to establish remote desktop sessions over the Internet for their business purposes, i.e. to provide technical support to their customers ("Client") remotely or to access unattended remote computers.
We address the personal data protection in accordance with the General Data Protection Regulation (EU) 2016/679, which is a European regulation on data protection and privacy (GDPR).
- Controller: means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data pursuant to Article 4 paragraph 7 of GDPR.
- Processor: means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller pursuant to Article 4 paragraph 8 of GDPR.
- Personal Data: refers to any information that relates to an identified or identifiable natural person pursuant to Article 4 paragraph 1 of GDPR. Or any information which can be used to uniquly identify a Website visitor, Operator, Client or Administrator.
- Website visitor: refers to any individual visiting our official websites or social media sites for informative purposes only.
- Operator: refers to any individual registered with an ISL Online account. Typically, this refers to an IT professional or helpdesk technician who offers support to a Client.
- Client: refers to an End-User who joins remote desktop sessions, usually without any credentials, to receive technical support from Operators.
- Administrator: refers to a privileged Operator who has permission to manage ISL Online licenses and accounts of other Operators within an organization.
Controller and Processorslink
While using ISL Online products and services the legal person collecting and processing personal data is:
- ISL Online Headquarters
- XLAB d.o.o.
- Pot za Brdom 100
- SI-1000 Ljubljana
- Slovenia, European Union
- VAT ID: SI15779092
- Reg. Number: 1639714
- +386 1 2447760
The processor of personal data may be:
- the controller,
- companies affiliated with us (our subsidiaries, whose controlling interest is owned by us and thus shall not be regarded as third parties):
- ISL Online Limited, 22 Basepoint Business Centre, Rivermead Drive, Westlea, Swindon, Wiltshire, SN5 7EX, United Kingdom
- ISL Online DACH GmbH, Aargauerstrasse 250, 8048 Zürich, Switzerland
- Third parties:
- Authorized Partners (our distributors and resellers which assist us in performing certain customer care functions such as marketing activities, sales, customer support and similar business activities on our behalf)
- external contractual service providers which we use in connection with the specific functions of our business process, e.g. Google Analytic
Processing details are the following:
Description Details Purpose of processing Enabling the use of ISL Online products and services in accordance with the Terms of Service and License Agreement. Duration of processing Duration of contractual relationship which commences when a user account is created. Nature of processing
Types of Personal Data processed
- Names (optional)
- Email address (optional)
- IP addresses
- Device information
Data retention The majority of personal data is collected for as long as is necessary to fulfil the purpose of processing under which it was collected. Certain personal information is kept for a longer period of time in order to comply with European and local legislation.
ISL Online implores the users to be careful when entering personal or confidential data into session chats, end-of-session dialogs and other places which allow unmoderated user input. This information becomes a subject of data processing, however it is technically infeasible to exercise your data subject rights upon such data.
Consent and Limits to Uselink
By giving us your consent and providing your personal data to ISL Online you indicate that we may collect, process, store or use the provided personal information for the legitimate purpose of enabling you to access our products and services and for related business activities. This may include contacting you, processing your requests and orders, answering your sales or technical support inquiries or promoting ISL Online's products and services. Your personal data will not be used for any other purpose and you may withdraw your consent at anytime.
It is our belief that children have no requirements for our software and therefore, we do not verify age or obtain parental or guardian consent for any data processing activity. We will not knowingly store any data regarding a child under the age of 16. ISL Online software has no age sensitive material, nor should it pose any risk to children.
ISL Online Headquarters (XLAB d.o.o.) holds the ISO/IEC 27001:2013 certificate, which proves our commitment to information security. We use globally recognized ISO 27001 standard as a framework for implementing the information security management systems (ISMS) which helps us keep information assets secure.
All our servers have disk encryption and are solely managed by the controller's OPS team (system administrators and other privileged access users). Data is encrypted in rest as well as in flight. We have physical and logical access procedures and controls in place, and we conduct training for our employees and contractors in order to enforce conformity with our data protection and privacy policies.
We use the latest technologies and administrative procedures to safeguard your personal data. ISL Online servers are hosted by professional, industry-proven data centers with modern facilities and equipment such as redundant or backup power supplies, redundant data communication connections, environmental controls (e.g. air conditioning, fire suppression) and security devices.
ISL Online’s master servers, which hold the data upon which ISL Online acts as a Controller, are located within the European Union in ISO 27001-certified data centers. Session meta-data upon which ISL Online acts as a Processor is replicated across our worldwide network of servers and gets processed in a location selected by our load balancing system, which includes locations outside the EU. Server locations are shown here: About Us.
If you wish to have a full control over server locations and data transfer, consider setting up a Server License (ISL Online service is hosted on your server(s) and managed by you) or using a Managed Private Cloud solution (ISL Online service is hosted on servers selected in accordance with your preferences and managed by ISL Online professionals).
When you visit our website, we collect a limited scope of personal data transmitted to us by your browser. This helps us provide the service as well as improve the user experience. Data collected consists of your IP address and metadata (such as timestamp), technology used (operating system, browser etc.), referrals (website from which the request comes), language and the country of origin.
In addition, your IP Address is collected by our systems for security reasons in order to detect anomalous activity. Anomalous activity includes, but is not limited to, DNS attacks, scam detection and other activities that could compromise the security or availability of our systems. Browser metadata, language and country of origin are used to serve the correct version of our website regarding your location and language of choice. Referral address, if obtained, is used by ISL Online to understand where the traffic is coming from.
If you decide to sign up for a free trial of the ISL Online software, we will ask you to provide the following personal information:
- Email address
- User name
- Full name
You are only required to provide your email address during the registration process. We process this information to complete the contractual obligation. The username is chosen by you and can be used as an alternative to an Email address when logging into ISL Online products and services. Full name is optional and can be specified in order to personalize the user experience when using ISL Online products and services.
According to your country of origin and the cookie information, your account information may only be processed by the ISL Online Headquarters, our subsidiaries or Authorized Partners which have signed information sharing agreements with us. These processors have access to the personal data needed only to perform their customer care functions related to ISL Online's products and services and may not use it for any other purpose. You have the power to choose your preferred point of contact at any time (log in to My Account > License > Change Local Partner).
When you register for a free trial, your account will be activated for the product use. Upon the registration, and all subsequent successful log in attempts, we will collect your IP and MAC addresses for auditing and licensing purposes.
Once logged into your account, ISL Online allows you to establish a remote desktop session with a remote computer or mobile device. The session may include different services such as text-chat, screen sharing, video call and file transfer.
All remote desktop sessions are encrypted using symmetrical AES 256-bit keys. A secure SSL end-to-end tunnel is established between a local and a remote computer or device. This means that even the ISL Online servers cannot decrypt the content of the sessions, but only transfer packets from one side to another. This means that we do not collect any personal data transmitted during remote desktop sessions.
However, we do collect and store metadata of the remote desktop sessions. This is needed for the legitimate purpose of enabling access to the ISL Online products and services explicitly requested by you. The list of metadata stored on ISL Online’s servers may include your personal data:
- User name
- Email address
- IP address
- MAC address
A detailed list of basic session parameters (metadata) is available in our Security Statement. The metadata is stored on ISL Online servers, which are located worldwide. The locations are mostly in the European Union, Japan and the United States. A distributed data allocation allows us to guarantee 24/7 availability and reliability of the remote desktop software as a service around the world.
We use proprietary geoDNS algorithms to distribute sessions to the nearest servers available. This means that users from a particular country are most likely to be connected through one of our servers hosted in that country (if any of our servers are located in that country). For example, the UK users will be almost certain to connect through our UK servers, the German users will be almost certain to connect through our German servers etc.
While we prioritize remote desktop connections to be established through the server located closest to you, some service and product features require that data is transferred to servers located outside of your country for technical reasons. The collection, encrypted transfer and storage of this data on the encrypted disks is managed according to the ISO/IEC 27001:2013 information security standards.
Some organizations may decide to enable optional features provided by ISL Online in order to enhance their remote desktop sessions, for example:
- ISL Pronto, which is a text-chat solution that can be published on their websites, and allows Clients to join a remote support session directly from the respective websites.
- End-of-Session dialogs, which pop up to Operators or Clients once the remote desktop session is finished for the purpose of collecting the users’ feedback.
- Integration into third-party solutions, such as service desk or ticketing products, CRMs, ERPs and other enterprise systems.
Enabling such optional features may result in collecting text messages (the transcript of the chat between the Operator and the Client) related to a remote desktop session, and storing this data on ISL Online servers alongside metadata. Chat transcripts are available to Operators and Administrators of the respective organizations. You are advised not to enter any sensitive or personal information into a chat window.
In the case of the integration of ISL Online software into third-party solutions, the chat transcript may be transferred to service desk or ticketing products, CRMs, ERPs or other enterprise systems. We do not control the personal data collected and managed by these enterprise systems. We recommend that you contact the enterprise system providers directly for their privacy and data sharing policies.
When the organization decides to purchase the ISL Online licenses, those licenses are assigned to a specific ISL Online account. These accounts are normally managed by Administrators (license owners). During the purchasing process, we will collect the information needed for billing and order processing purposes, which may include your personal data such as your name, company name, company address, email address, and telephone number. We will keep purchase orders and invoice records as long as requested by tax authorities. Please refer to the terms of service for details.
When you contact our service desk via live chat, email or phone, we may collect your email address, your name, and your telephone number in order to respond to your inquiry. Your message will also be stored and might be shared with our Authorized Partners in order to provide a prompt and localized customer service to you. Any personal data and other information intentionally or unintentionally provided by you whilst communicating with our support staff will be processed by us based on our legitimate interest to fulfill your support request.
Third Party Contentlink
Google Tag Manager
- Google Analytics
reCAPTCHA is used by ISL Online to protect our websites from abuse. It uses advanced risk analysis techniques to tell bots and humans apart. More information regarding reCAPTCHA can be found here: https://developers.google.com/recaptcha/.
Third Party Services
In order to provide the services and improve our official websites, we may engage the services of third-party vendors, such as Vimeo, YouTube and Google Maps. In the process of supplying such website services through our official website, these third-party vendors may collect your IP or other information provided by your browser.
Besides disabling third party cookies, it is beyond the control of ISL Online to determine and dictate in what way the third parties will store and handle your personal data. Requests to exercise your rights in regards to personal data processing should be directed directly at the respected third parties.
Social Media Sites
Our official websites feature social media plugins like Facebook, Twitter and LinkedIn, to enable you to share information with others. If you are logged into a social media site while visiting our website, the social plugins may allow that social media website to receive information that you have visited our website and to share information about your activities on our website with other users of their social media website. We do not control any of the content from the social media plugins. We recommend that you contact those sites directly for their privacy and data sharing policies.
Beside the official websites, we use a blog to publish the content created by us. The blog is hosted at WordPress.com, which offers features like "Subscribe to blog" and "Reply to a blog post". We do not control the personal data collected and managed by these blog features. If you wish to use these features and have any concerns, we recommend that you contact WordPress.com directly for their privacy and data sharing policies.
Links to Other Websites
Our official websites contain links to other websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation to that third party. We do not exercise control over third party websites. We recommend you contact those sites directly for their privacy and data sharing policies.
Managed Private Cloudlink
To organizations which wish to use the cloud solution but want to have total control over the locations of the ISL Online servers hosting their data and remote desktop connections, we offer a special plan called Managed Private Cloud (MPC). This allows users to enjoy all the benefits of cloud computing in a PRIVATE cloud, without investing in hardware or human resources (sysops) for setting up, configuring, monitoring and maintaining the system. Please contact us for details.
To most security delicate organizations such as banks, national agencies or corporate environments, we offer the self-hosted models (Server License, Private Cloud). With these models, the ISL Online system is installed onto the server(s) hosted by those organizations. In this case, all remote desktop connections are established through the server(s) controlled by those organizations. As the self-hosted installation is a stand-alone system, where all data (including metadata) remains in a closed corporate environment, the organization is responsible for the administration of the server(s) and for protecting personal data of their users (Operators and Clients). If you are using a self-hosted system and have concerns, inquiries or requests related to your personal data, you need to contact Administrators of those respective organizations. ISL Online helps the organizations using our self-hosted system to meet the personal data protection requirements by tailoring the ISL Online products to their needs. Please contact us for details.
Anonymization and Pseudonymizationlink
We strive to minimize the collection of your personal data. A vast majority of data collected by ISL Online is anonymized, stripped of any identifiable information, which makes it impossible to derive insights into a discrete individual. On the other hand, the personal data we do collect and store may be pseudonymized:
- upon your explicit request, or
- according to the set retention periods.
You have the right to be forgotten. Pseudonymization means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately. Your personal data will be rendered in such a way that it should be nearly impossible to reidentify you.
We use reasonable efforts and deidentification techniques to pseudonymize your personal data. We provide pseudonymization support tools to Administrators of self-hosted systems.
Previous Product Versionslink
Any data subject whose personal data we process, may, at any time:
- Know which types of personal data we have in our possession, how we obtained it, how we protect it, and how we process it.
- Request a copy of their personal data in our possession.
- Rectify/complete any incorrect/incomplete parts of their personal data in our possession.
- Request the erasure of their personal data in our possession.
- Restrict the processing of their personal data in our possession or object to it.
- Request the transmission of their personal data to a third party.
If you have any additional questions about the collecting and processing of your personal data, please contact our Data Protection Officer at firstname.lastname@example.org.