Data Processing Agreement · Isolation Docs

How Isolation processes personal data in Customer Content as your processor under GDPR Art. 28, with the EU SCCs.

Version 1.0 — 3 October 2026

This Data Processing Agreement (the "DPA") is between Isolation Labs S.r.l., Italy ("Isolation", "we", the processor) and the Customer that uses Isolation Cloud (the "Customer", the controller), as "Customer" is defined in the Terms of Service (isolation.cloud/legal/terms). It sets out how we process personal data in Customer Content on the Customer's behalf, as Article 28 of the General Data Protection Regulation (EU) 2016/679 (the "GDPR") requires. It applies to every Organization: it is part of the Terms of Service for every Customer, and part of every Enterprise contract, which records the version it was signed under.

Words defined in the Terms of Service (Organization, Member, Sandbox, Customer Content, Agent) mean the same here. "Personal data", "processing", "data subject", "personal data breach" and "supervisory authority" have their GDPR meaning. Contact for everything in this DPA: privacy@isolation.cloud.

1. Scope and roles

This DPA covers the personal data contained in Customer Content: repositories and files in workspaces, environment values and secrets, the credentials the Customer stores (AI keys and subscriptions, Git tokens, SSH keys), Agents' prompts, conversations and memory, review comments on the Customer's running software, and whatever the Customer's Sandboxes produce (the "Customer Personal Data").

The Customer is the controller of Customer Personal Data and Isolation is its processor. For the data we handle to run accounts, sign-in, billing, metering and the security of the Service, we are the controller, and the Privacy Policy (isolation.cloud/legal/privacy) applies instead of this DPA.

2. The processing


Subject matter	providing the Service to the Customer under the Terms of Service and, where there is one, the Enterprise contract
Duration	for as long as we provide the Service to the Customer, and afterwards until Customer Personal Data is deleted under section 11
Nature	storage (encrypted), transmission, and execution in isolated Sandboxes: running the software, commands and Agents the Customer starts; showing their results to the Customer's Members and to the reviewers the Customer invites; saving workspaces and Agents' memory between Sandboxes
Purpose	only to provide the Service as the Customer configures and uses it, including support the Customer asks for, and to keep it secure
Categories of data subjects	the Customer's Members; people the Customer invites to review its work; and any person whose personal data the Customer, its Members or its Agents put into Customer Content (for example the Customer's employees, contractors, customers or end users named in code, files, data sets, tickets or conversations)
Categories of personal data	whatever the Customer chooses to put into Customer Content — typically names, email addresses and other contact details, account identifiers, credentials, and personal data inside source code, files, databases, logs and conversations. The Service is not designed for special categories of personal data (GDPR Article 9) or data about criminal convictions (Article 10); the Customer decides whether to put them in, and is responsible for the additional safeguards they need
Frequency	continuous, while the Customer uses the Service

3. Instructions

We process Customer Personal Data only on the Customer's documented instructions. The Terms of Service, the Enterprise contract where there is one, this DPA, and the Customer's use and configuration of the Service (what its Members and Agents launch, store, share, export and delete) are those instructions. If Union or Member State law requires us to process Customer Personal Data otherwise, we will tell the Customer before we do, unless that law forbids it. We will tell the Customer if, in our opinion, an instruction infringes the GDPR or other data protection law.

We do not sell Customer Personal Data, use it for advertising, or train AI models on it.

4. Confidentiality

Everyone at Isolation who can reach Customer Personal Data is bound to confidentiality, by contract or by law, and reaches it only to provide the Service, to keep it secure, or when the Customer asks us to help.

5. Security

We take the technical and organizational measures of GDPR Article 32 described in Annex II. They are the measures the Service actually runs today. We may change them over time, but never so that the overall level of protection falls.

6. Sub-processors

The Customer gives us a general authorization to engage sub-processors. The current list, with what each does and where, is at isolation.cloud/legal/subprocessors and is Annex III.

Before we add or replace a sub-processor that will process Customer Personal Data, we email the Organization's Owners at least 30 days in advance.
The Customer may object on reasonable data protection grounds by writing to privacy@isolation.cloud within that period. We will then try to resolve the objection — for example by not using the new sub-processor for that Customer's data. If we cannot, the Customer may end the affected part of the Service, and we refund any amount prepaid for the period after the end that the Customer can no longer use.
We impose on each sub-processor, by written contract, data protection obligations that protect Customer Personal Data at least as well as this DPA, and we remain responsible to the Customer for their performance.

The AI providers whose credentials the Customer gives its Agents (for example Anthropic or OpenAI), and the machines the Customer connects or runs itself, are not our sub-processors: the Customer contracts with them directly, and what an Agent sends them it sends on the Customer's instruction.

7. Data subjects' requests

The Service lets the Customer handle most requests itself: its Members can read, export (a workspace's files and its Agents' memory, from the Workspace page) and delete workspaces, Agents' memory, environment values and credentials. Beyond that, we assist the Customer, taking into account the nature of the processing, with appropriate measures to answer requests from data subjects exercising their rights under Chapter III of the GDPR. If a data subject writes to us about Customer Personal Data, we pass the request to the Customer's Owners and do not answer it ourselves unless the Customer tells us to.

8. Personal data breaches

We notify the Customer of a personal data breach affecting Customer Personal Data without undue delay, and at the latest within 48 hours after becoming aware of it, by email to the Organization's Owners. The notice describes, as far as we know at the time and then as we learn more: the nature of the breach, the categories and approximate number of data subjects and records concerned, the likely consequences, the measures taken or proposed, and a contact for more information. We take reasonable steps to contain and remedy the breach, and help the Customer with its own notifications to supervisory authorities and data subjects. Our notice is not an admission of fault.

9. Impact assessments and prior consultation

We give the Customer the information it reasonably needs, about the Service and the processing in it, to carry out a data protection impact assessment and any prior consultation with a supervisory authority (GDPR Articles 35 and 36).

10. Audits

We make available to the Customer, on request, the information necessary to demonstrate compliance with Article 28 of the GDPR and this DPA: written answers to reasonable security questionnaires, descriptions of our measures, and the sub-processor list. If that information is not enough, or a supervisory authority requires it, the Customer (or an independent auditor bound to confidentiality whom it appoints) may audit us on-site, at the Customer's cost, with at least 30 days' written notice, during business hours, at most once in any twelve months (except after a personal data breach), and in a way that does not reach other customers' data or disrupt the Service. We may charge our reasonable costs for the time an on-site audit takes.

11. Deletion and return

The Customer can export its workspaces (files and Agents' memory) at any time from the Workspace page, and delete workspaces, Agents and its Organization from the website. When the Service ends — the Organization is deleted, or the Terms or the Enterprise contract end — we delete Customer Personal Data within 30 days, unless Union or Member State law requires us to keep it. Copies in our providers' point-in-time recovery expire on their own schedule within that period. A Sandbox holds its files only while it runs; when it ends, its machine is released and its disk goes with it. On the Customer's written request before the end, we help it take a final export first.

12. International transfers

We are established in the European Union. Customer Personal Data is stored and processed in the region the Customer chooses for its Sandboxes (Europe or the United States) and by the sub-processors in Annex III, some of which are in the United States or process data there.

Where Customer Personal Data is transferred to a country outside the European Economic Area that has no adequacy decision, the transfer is made under the Standard Contractual Clauses adopted by the European Commission in Implementing Decision (EU) 2021/914 of 4 June 2021 (the "SCCs"), which are incorporated into this DPA by reference, or under an adequacy decision that covers the recipient (including the EU–US Data Privacy Framework, for a recipient certified under it):

Module Two (controller to processor) applies between the Customer, as data exporter, and Isolation, as data importer, to the extent a transfer from the Customer to Isolation is a transfer to a third country under Chapter V of the GDPR;
Module Three (processor to processor) applies between Isolation, as data exporter, and each sub-processor outside the European Economic Area, as data importer; we sign the SCCs, or ensure they are in place, with each such sub-processor;
Module Four (processor to controller) applies between Isolation, as data exporter, and the Customer, as data importer, where the Customer is established outside the European Economic Area and we transfer Customer Personal Data back to it (for example, a workspace export or the data returned at the end of the Service).

For every module: Clause 7 (docking) applies; in Clause 9 (Modules Two and Three), Option 2 (general written authorization) applies with the notice period of section 6; the optional wording in Clause 11 does not apply; in Clause 13, the competent supervisory authority is the Garante per la protezione dei dati personali (Italy); in Clause 17, Option 1 applies and the governing law is the law of Italy; in Clause 18, the courts of Milan, Italy. Annexes I, II and III of the SCCs are completed by the annexes of this DPA. Where the United Kingdom's or Switzerland's data protection law applies to a transfer, the SCCs apply with the changes that law requires (for the United Kingdom, the International Data Transfer Addendum issued by the Information Commissioner).

13. Liability

Each party's liability under or in connection with this DPA, and under the SCCs to the extent the law allows, is subject to the exclusions and limits of the Terms of Service (section 12) or of the Enterprise contract, where there is one. Nothing in this DPA limits a data subject's rights under the GDPR or the SCCs.

14. Precedence, term and changes

This DPA is part of the Terms of Service and of every Enterprise contract. For the protection of personal data, this DPA prevails over the Terms of Service and the Enterprise contract where they conflict, and the SCCs prevail over this DPA, the Terms and the Enterprise contract. This DPA lasts as long as we process Customer Personal Data. We may update it to reflect changes in the law, in the Service or in our sub-processors; we publish each version at isolation.cloud/legal/dpa with its date and email the Organization's Owners before a change that reduces the Customer's protection takes effect. An Enterprise contract stays under the version it records until both parties agree to a newer one.

Annex I — Description of the processing and the transfers

A. The parties

	data exporter	data importer
Module Two	the Customer, as identified in its Organization and, where there is one, its Enterprise contract; contact: the Organization's Owners; role: controller	Isolation Labs S.r.l., Italy; contact: privacy@isolation.cloud; role: processor
Module Three	Isolation Labs S.r.l., Italy; contact: privacy@isolation.cloud; role: processor	each sub-processor in Annex III that is outside the European Economic Area; role: (sub-)processor
Module Four	Isolation Labs S.r.l., Italy; contact: privacy@isolation.cloud; role: processor	the Customer, where it is established outside the European Economic Area; contact: the Organization's Owners; role: controller

Activities relevant to the transfers: providing, securing and supporting Isolation Cloud. The parties sign the SCCs by accepting the Terms of Service or signing the Enterprise contract.

B. Description of the transfer

Categories of data subjects, categories of personal data, nature and purpose: as in section 2.
Sensitive data: none intended; if the Customer puts any into Customer Content, it is protected by the measures in Annex II, which apply to all Customer Content alike.
Frequency: continuous.
Retention: as in section 11 — for the duration of the Service, then deleted within 30 days.
Transfers to sub-processors: the subject matter, nature and duration are those in Annex III for each sub-processor, for the duration of the Service.

C. Competent supervisory authority: the Garante per la protezione dei dati personali, Italy.

Annex II — Technical and organizational measures

Encryption.

Every connection to the Service uses TLS.
A workspace's files and its Agents' memory are encrypted (AES-256-GCM) with a key specific to that workspace before they are written to storage.
Credentials and secret environment values are encrypted (AES-GCM) in our database.
Secrets travel to a Sandbox sealed for that Sandbox alone, and are never written to logs, URLs, command lines or repositories.
Where the Service can, a credential's real value never enters the Sandbox: the Sandbox gets a scoped, revocable stand-in that the Service exchanges for the real value on the way out (AI provider keys through our gateway, Git through our Git gateway, other credentials through the Sandbox's outbound proxy).

Isolation.

Each Sandbox runs in its own virtual machine or micro-virtual machine, on its own branch of the workspace; Sandboxes of different Customers never share one.
Nothing listens for inbound connections on a Sandbox's machine: each Sandbox opens one outbound, mutually authenticated connection to us, and every view reaches it through that connection.
The addresses of a Sandbox's previews are derived from a secret of that Sandbox and cannot be guessed; opening a view needs a token issued for that view. A preview is private to its Member unless the Member shares it, at a level the Member chooses.
A Sandbox's outbound proxy decrypts only connections to hosts where a stored credential must be substituted; every other connection passes through unread.
Where Sandboxes of several Customers run on one of our machines, every Customer's keys are derived separately and every request is checked against the Customer it belongs to, failing closed.

Access control.

Sign-in by one-time code sent by email, with a bot check on the login form; tokens for apps, MCP clients and the command line are scoped to one Organization, listed, and revocable.
Roles (Owner, Admin, Member) decide what each person may do, checked on every action the same way whichever way it is called. A Member's workspaces and Sandboxes are that Member's own: other Members, including Admins, cannot open them (Admins can list and stop Sandboxes).
Our staff reach Customer Content only to provide the Service, to keep it secure, or when the Customer asks for help, on a need-to-know basis.

Logging and accountability.

Every action — by a Member or by an Agent, through the website, a chat app, an MCP client, the command line or inside a Sandbox — is logged with who did it, through which channel, and when, and the Organization can read its log. The log is kept 90 days.

Availability and resilience.

Workspaces and Agents' memory are saved to durable storage at the documented points (save, pause, finish, and periodically), each Sandbox on its own branch with conflict detection, so losing a Sandbox's machine loses nothing that was saved.

Secure development and operations.

Our software is released through a signed release chain; our hosts verify a release before they apply it.
Vulnerabilities can be reported to security@isolation.cloud.

Annex III — Sub-processors

The sub-processors the Customer authorizes are those listed at isolation.cloud/legal/subprocessors on the date this DPA takes effect, as that list is then updated under section 6. For each one the list states what it does for the Service and where it processes data.