Effective as from 26 April 2018
- Personal Data
- Controller and Processors
- Consent and Limits to Use
- Obtaining Information and Rectification
- Data Protection
- Website Visitors
- Social Media Sites
- Integrated Third Party Website Services
- Links to Other Websites
- Notifications and Newsletter
- Product Use
- Text Messages
- Managed Private Cloud
- Self-Hosted Solution
- Anonymization and Pseudonymization
- Buying Licenses
- Customer Support
- Data Transfer to Third Parties
- Previous Product Versions
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).
- Website visitor: Any individual visiting our official websites or social media sites for informative purposes only.
- Operator: Registered user with ISL Online account (typically IT professional or helpdesk technician).
- Client: End-User, who may join remote desktop sessions without any credentials to receive technical support from Operators.
- Administrator: A privileged Operator who has permission to manage ISL Online licenses and Operators' accounts within an organization.
Controller and Processors
The ISL Online products and services are developed by XLAB d.o.o., which is a software engineering company headquartered in the European Union. Since 2003, we have been providing the ISL Online products and services to our users all around the world. The legal person who solely determines the purposes and means of the processing of personal data when using the ISL Online products and services ("Controller") 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 - subsidiaries whose controlling interest is owned by us 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 who 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 who we use in connection with the specific functions of our business process, e.g. Google Analytics
Consent and Limits to Use
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, which 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. You may withdraw your consent anytime.
Obtaining Information and Rectification
You have the right to request a report about and/or containing your personal data we store. Should you require a report on your session details, this shall be provided in a machine readable format. Such requests or other inquiries related to your personal data should be sent by email to firstname.lastname@example.org. To ensure secure handling of your request, we will need to authenticate your identity before processing your request. We will use reasonable technical and administrative efforts to provide you with an individual personal data report within 30 days after receiving a valid request.
It is our belief that children have no requirements for our software and we do not verify age or obtain parental or guardian consent for any data processing activity and we will not knowingly store any data regarding a child under the age of 16. The software has no age sensitive material nor should 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.
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 are located within the European Union in ISO 27001-certified data centers.
All our servers have disk encryption and are solely managed by the controller's OPS team (system administrators and other privileged access users). 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.
When you visit our website, we collect a limited scope of personal data transmitted to us by your browser. This enables you to access our website and helps us to create the best user experience for you. The data transmitted by your browser include your personal data such as your IP address and meta data such as time stamp, technology used (operating system, browser, network etc.), referrals (website from which the request comes), language and the country of origin.
Our website also contains cookies – small text files that are placed on your computer upon your visit. Cookies are widely used in order to make websites work, or work more efficiently. Please refer to our cookies policy for details.
Integrated Third Party Website 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 need to collect your IP address provided by your web browser.
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.
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:
- Full name
- Email address
You are only required to provide your email address during the registration process. For billing purposes, we also ask you to provide the name of the company, address, phone number and similar information which will be needed if you decide to buy a license. You are able to review and change this information at any time (log in My Account > License > Change Information).
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 who 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 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, due to auditing and licensing reasons.
Once logged in to 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 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, 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 all around the world.
We use proprietary geoDNS algorithms to distribute sessions to the nearest servers available. This means that users from a particular country will be almost certainly connected through one of our servers hosted in that country (if any of our servers is located in that country). For example, the UK users will be almost certainly connected through our UK servers, the German users will be almost certainly connected 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 beside the 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 enterprise system providers directly for their privacy and data sharing policies.
Managed Private Cloud
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, corporate environments, we offer the self-hosted models (Server License, Private Cloud), where the ISL Online system is installed on the server(s) hosted by those organizations. In this case, all remote desktop connections are established through the server 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 server's administration 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 Pseudonymization
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, making 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.
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 information needed for billing and order processing purposes, which may include your personal data such as your name, company's name and 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.
Data Transfer to Third Parties
Previous Product Versions