Splynx GDPR compliance

From May 25th 2018, the EU’s General Data Protection Regulations (GDPR) came into effect.

As part of our commitment to transparency, and in preparation for the new data protection laws, we’ve updated our Software solution. We encourage you to read the GDPR Splynx compliancy document in full and to contact us if you have any questions.

Splynx is a management software for Internet Service Providers (referred to as ISP in the following text). It means that our company doesn’t work directly with data of individuals.

However, our clients operate in the B2C market and use our software to store their customers’ data. In this situation, Splynx s.r.o. works as a solution provider. The areas and situations described below are when Splynx software works with the data of individuals and how our software complies with GDPR regulations.

Storing personal information

-> Storing data of individuals in general

Splynx software is installed in the premises of an ISP company. In this case. all data is physically stored in the office or datacenter of our client. This means that our client is in charge of the physical security aspects of the server where the software runs.

Basic information that is stored in a Splynx database about customers is not sensitive. Data such as a customer’s address, phone number, passport/ID number or bank account are requested by ISP based on the customer’s agreement. For example, the ISP cannot provide services without being able to contact the customer and is not able to receive payments if it does not have the customer’s bank details. Technical information regarding a customer’s data tariff plan and a customer’s IP/MAC address is needed by the ISP to provide the service itself. There is no additional confirmation needed by the ISP from the customer to store this data.

-> Customer’s information

The information that is stored by default in Splynx software about a customer is as follows.

ISP administrators can create additional fields and store information about customers in these fields. In the case where these fields feature sensitive data, the ISP company should gain permission from the customer to use this data, Splynx is not responsible for gaining this permission, this is the total responsibility of ISP company.

-> Communication

Splynx software automatically sends emails and SMS to ISP customers in certain situations –  when an invoice is created, when payment is received or when an invoice is overdue and the service is put on hold. These emails are sent to end customers by the ISP because they are needed in order to provide the service and operate its business and as such they  are covered by the main service agreement. No additional confirmation from customers is needed in this instance.

Splynx does not provide a newsletter or similar service. If an ISP wishes to send promotion emails or SMS, they should obtain further confirmation from customers and this confirmation should be stored in the  newsletter/promotions platform.

Splynx stores all emails sent  to customers. Splynx also stores replies from customers in the Tickets section. Tickets can be displayed to customers or can be hidden and available only for administrators.

-> Passwords

Splynx stores all passwords in an SQL database in encrypted format. Any field that is defined as a password is automatically encrypted before saving to the database. The passwords are not displayed in logs or API calls. All customers’ passwords are by default hidden  to administrators. Customers can reset the passwords to their portals using the email reset form.

-> IP addresses

IP addresses and MAC addresses are important for an ISP company to provide access to the internet. IP addresses are stored in the Splynx database in section IPAM – IP address management. IP address and MAC address are unique and can be assigned to one customer at the same time.

-> Logs of sessions

Splynx stores information about IP sessions. The system stores a combination of IP address, the start session date time and the end session date time. This allows an ISP company to find out quickly which customers were using an IP address in a certain period of time.

Administrative access to Splynx software

-> Access to the system

Our software operates with two different access portals. The first is for administrative access and the second is for customer access.

Administrative access allows the administrators of an  ISP company to manage and work with customers’ information. Administrative access can be given by an  ISP to its own employees or to third-parties (for example resellers.) When a third-party receives access to Splynx software, administrative access can be limited and the third-party will only be able to view and work with customers that have a contractual relationship with the third-party.

The customer portal allows customer to login to an ISP system and view information about their services, invoices, payments, payment methods, statistics of internet usage and to  check the durations and cost of telephone calls

-> Access levels, roles and permissions

Access roles  – To achieve more granularity and tighten the security of user accounts, Splynx billing software supports access roles. The software makes it easy for an ISP administrator to assign permissions by providing pre-defined “roles” to choose from. These roles and their permissions are fully customizable at the administrator level.  By selecting one of the pre-defined roles (Super administrator Administrator, Customer creator, Financial manager, Manager, New Role) during user account creation, the billing system applies the relevant permission settings for that role.

Permissions – while the roles are predefined level of permissions, the Permissions themselves define which parts of the system can be displayed to or edited by administrator.

-> Logs of operations

Each single action of administrator in Splynx is tracked. View, Edit, Save, Delete, Rename, Change – anything an administrator does in the system is always saved in logs. All information is located in Administration -> Logs -> Operations. A search by customer, administrator or action is available in this section.

Technology description

-> SSL communication

Our platform is web-based. Administrators and customers access it via web browsers. Preferred communication is HTTPS. Our team helps to setup the SSL communication on ISP

-> Two factor authentication

Splynx software supports two-factor authentication. This is a configuration security feature that enables system administrators to implement customized access to Splinx software tools by setting Google authenticator or similar software.

-> Encryption of passwords

The passwords of administrators, customers, pppoe logins, routers etc are all  encrypted in the SQL database with the server’s key. Passwords are not sent in plaintext in any type of client-server communication (HTTP, HTTPS, API, Exports)

-> Remote backups

Splynx s.r.o. provides a remote backup service to its clients. This means that a client’s server connects to our cloud storage once every 6 hours and pushes the changes from database and application. All data from our clients and their customers is transferred over an OVPN encrypted tunnel. Data is transferred via Burb protocol which is also encrypted. The data is stored in the server in encrypted format. You can read more about our backup platform here – http://burp.grke.org/

Splynx support access

-> Administrative access

We have our own proprietary software solution that is used by our company for license management, backup management and which allows our employees to access client’s servers, provide assistance, resolve issues and restore data in the case of failure.

When the system is installed, our clients can request remote support. Splynx has a tool – splynx-remote-support – and when this tool is installed, the client’s Splynx server establishes an OVPN encrypted tunnel to our cloud platform. This allows us to access the client’s server on a private IP address.

When our employees access the web administration of a client’s Splynx server, they use the  administrator’s name, “splynx-remote-support”. They also use the password that is generated once every day. To access the client’s server, our administrator must also enter a one time code that is created every 30 seconds. This strict authentication allows us to ensure that in the situation where one of  our employees leaves the company and is therefore removed from the authentication system, they will not be able to access a client’s servers.

-> SSH remote access

Similar to administrative access is our SSH access. We connect to a client’s servers via a private IP address of the OVPN tunnel. Our support people connect to the client’s servers with Public Keys and no password. The Key is created based on the private key of the authentication server once every day. The sudo password is also changed once per day.

-> Splynx internal sub-system logs

All access by our employees to a client’s servers is logged. We store information about web access and SSH access. In addition, we also  store the history of commands that are run on the server and web actions are stored in each Splynx server under “Administration -> Logs -> Operations”