This Privacy Policy explains how Remoqa handles personal data in connection with https://remoqa.com, our desktop and mobile applications, the account cabinet, browser access tools, remote connections and paid services (together, the Services). It covers visitors, account holders, guests, session participants, organisation members and people who contact us.
Remoqa is in development. This is a draft for completion. Processing associated with an optional feature applies only where that feature is made available and used. Highlighted fields identify information that must be completed or confirmed for the released Services.
01Who is responsible for your data
Remoqa is operated by LIFTSOFT LLC, referred to as Remoqa, we, us or our. We act as the controller or equivalent responsible organisation for processing whose purposes and means we determine, such as account administration, our billing and service security.
Location: Krasnoyarsk, Russia. Company registration number: 1222400024329. Tax identification number: 2462073857. Privacy contact: General Director of LIFTSOFT LLC, via [email protected]. Details of any separately appointed data protection officer or jurisdiction-specific representative, where required: [NAME CONTACT DETAILS AND RELEVANT COUNTRY OR REMOVE IF NOT REQUIRED].
An organisation using Remoqa may be responsible for personal data about its members and people whose devices or sessions it manages. For account administration, billing and service security, we determine our own processing purposes. Where we process information solely on an organisation's instructions, we act as its processor or equivalent service provider, subject to applicable data-processing terms. The organisation's notice explains its own purposes and lawful basis. Contact [email protected] if you need help identifying who is responsible for a particular activity.
02Accounts organisations and sign in
When you create or manage an account, we process your name, email address, password hash, verification status, account identifiers and settings. We also process authentication sessions, recovery and verification information, security events and relevant request information such as IP address and browser details. Passwords used for account authentication are stored as hashes.
For organisation features, we process organisation and department names, membership and invitation information, roles, device assignments, administrative changes and authorised activity records. Information can be supplied by you, an organisation administrator or a person inviting you to join.
If Google sign-in is offered and you choose it, we receive your Google account identifier, name, email address and email-verification information. We exchange a temporary authorisation code for an access token to retrieve that profile; this integration does not request access to your Gmail messages or Google Drive files. This integration operates only when enabled and used. The provider also handles your interaction with its own service under its privacy notice.
03Devices and preferences
To register, identify and connect devices, the Services process device identifiers including the Remoqa ID, device name or hostname, platform, application version, public identity keys, account association, online or last-seen status, IP address and connection settings. Features such as unattended access use authentication information and configuration; device access passwords handled by our backend are hashed.
We derive an approximate location from a device's public IP address for device display, administration and security. This can include country, region, city and estimated coordinates. The current default uses a locally held DB-IP database, so that lookup does not send each device IP address to DB-IP. It does not request GPS permission. Approximate locations may be shown to authorised administrators; they are estimates, not a reliable way to identify an individual's precise whereabouts.
If Wake on LAN is available and enabled, hardware network addresses and related configuration are processed to carry out that feature. Browser settings can include language, timezone and cryptographic device identity information. For native applications, this policy applies when we make them available. Before an application processes additional categories of personal data or uses data for additional purposes, we will explain that processing in this policy or a supplementary notice available with the relevant feature. Application permissions, local logging and diagnostic controls will be explained before the relevant processing starts. Where separate consent is required, we will obtain it before that processing begins.
04Connection records and diagnostics
When you open the website, cabinet or a service endpoint, the infrastructure handling your request receives your IP address, requested URL, request time and browser information. Access and security records can include response status, referring page and errors. We use these records to deliver requests, investigate failures and protect the Services. These records are separate from the content of a remote session.
Creating or attempting a connection produces operational records such as the participating device and account identifiers, request and start or end times, status, duration, connection mode, relay selection, traffic volumes and termination or failure reasons. Network and signaling services also handle addresses and connection negotiation information necessary to establish and route the session.
When a client sends a diagnostic report, we receive the device and session identifiers, client version, collection time, connection role, protocol steps, status and error details, elapsed times and performance measurements. Reports can also contain contextual fields supplied by the client. They are associated with the relevant device and session, are available to authorised service administrators, and are not anonymous. Client-specific submission behaviour and controls are covered by the application information in section 3. Diagnostic reports are separate from the encrypted live session-content channel.
Where Extended audit is enabled, organisation records can identify the actor by name and email and record device details, connection events and membership changes. The current file-transfer audit records the reported byte count, reporting device and connection mode alongside the session details; that audit event does not contain the transferred file's name, path or contents. Authorised users can view or export records within their permissions and plan. An export saved on their own device is under their control.
05Remote session content
A remote session can carry screen images and, where supported and enabled, audio, control input, clipboard information or transferred files. This material may contain personal or confidential information belonging to you or other people. The person controlling a device and the participants determine what is exposed through the features they use.
Remoqa encrypts remote session content end to end between the connected devices, including screen images and, where supported and enabled, audio, control input, clipboard information and transferred files. This protection also applies when a relay server forwards the content. Relay servers forward encrypted traffic rather than needing its decrypted content. This does not make account information, connection metadata, billing records or separately submitted diagnostics invisible to the services that process them.
We do not record live remote session content on our servers. Screenshots, recordings or files that you deliberately send to support are handled as support material, outside the live session-content channel.
The other participant receives the information you share and may be able to save or record it on their device. Direct connections can reveal network addresses to the other endpoint. We cannot control a participant's independent use of received information. Share only what is necessary and obtain the permissions required for your use of the Services.
06Billing purchases and messages
For paid services, we process the plan and billing period, amount and currency, account balance and ledger entries, payment status and references, provider response and notification records, refunds and renewal-authorisation information. Saved-payment records can contain a provider-issued payment-method identifier, the associated payment and consent time. The international payment integration is not yet finalised. Its additional retained payment-response fields, including any masked card details, are [INTELLECTMONEY PAYMENT RESPONSE AND MASKED CARD FIELDS RETAINED].
Paid subscriptions are offered to individual purchasers. The cabinet associates purchases with your account name, email address and account identifier. Payment or tax details requested by a payment provider at checkout are subject to that provider's notice and the payment data-sharing information below.
IntellectMoney is the selected payment service provider for international payments. Payment providers and participating banks process payment credentials and transaction information to authorise and complete a payment, prevent fraud and meet their own legal duties. The contracted payment entity, enabled methods, information exchanged with Remoqa and processing countries are [INTELLECTMONEY ENTITY PAYMENT METHODS DATA SHARING AND PROCESSING COUNTRIES]. The linked IntellectMoney privacy policy applies to the selected service; any additional payment-provider or bank notice will be identified when that method is offered. Do not send full payment-card credentials to our support team.
When you contact us at [email protected], we process your contact details, correspondence and any attachments or diagnostic information you provide. We use these to answer enquiries, investigate issues and maintain appropriate records. Our authorised personnel and, where used, providers of email hosting or support-request management handle this information to deliver, store and manage your enquiry.
We use your email address and relevant account or transaction information to send service messages, including email verification, account recovery, security notices, payment and subscription notices, account-closure notices and material service updates. Plunk Cloud, the hosted service at useplunk.com, delivers these emails on our behalf and processes the recipient email address, name where included, sender and reply-to details, subject, message content and information needed for delivery. We do not enable tracking of email opens or link clicks in these messages. Delivery and failure records may still be processed to operate the email service. We do not currently send promotional emails.
07Purposes and legal bases
We use personal data for the purposes below. Where the GDPR or a law using comparable legal bases applies, the basis depends on our relationship with you and the particular activity. We do not treat acceptance of the Terms of Service or this policy as consent to every use of your information.
- Accounts, authentication, device registration, requested connections and related service messages: performance of our contract with you or steps you request before entering it. For people who are not parties to that contract, our legitimate interests are enabling authorised access and operating the service requested by the account holder, subject to their rights.
- Purchases, subscriptions and refunds: performance of the purchase contract. Required financial records, legally required disclosures and responses to valid official requests: compliance with an applicable legal obligation.
- Security, abuse prevention, service reliability and necessary diagnostics: our legitimate interests in preventing unauthorised access, investigating failures and protecting users and infrastructure, where those interests are not overridden by individuals' rights.
- Organisation features: the organisation establishes the basis for processing it instructs us to carry out. Our own access administration and security processing serves the legitimate interests described above.
- Language and timezone preferences: performance of our contract when needed to provide your requested service, or our legitimate interest in remembering a visitor's requested settings. Support correspondence: performance of our contract or steps requested before it, or our legitimate interest in answering other enquiries. Relevant records may also be needed to establish, exercise or defend legal claims.
- Optional analytics and any other processing for which consent is required: your separate consent. The current website's analytics behaviour and available controls are explained in section 8 and the Cookie Policy; this draft does not assert that a consent control is already operating.
Legitimate interests are not permission to disregard your privacy: the processing must be necessary and proportionate, and you may object as described in section 12. If another applicable law requires consent or a different legal condition, that condition must be met before the activity takes place. Information needed to authenticate an account, establish a requested connection or complete a purchase is necessary for that function; without it we may be unable to provide that function.
09Who receives information
DigitalOcean provides hosting infrastructure and processes information needed to store, deliver and protect the Services. The informational landing uses DigitalOcean's standard content delivery network (CDN), which uses Cloudflare for delivery and security. That network receives website request information such as IP addresses, requested resources and browser information, and uses a security cookie described in the Cookie Policy. CDN delivery is used for the informational landing only. Infrastructure providers and their authorised subprocessors may handle hosting, network delivery, backup and security operations. Processing locations are described in section 10.
Plunk Cloud handles service emails as described in section 6. Other recipients include the payment providers and banks used for a purchase, email-hosting or support-management providers handling an enquiry, Google for landing analytics and optional sign-in. The default administrator map uses OpenStreetMap tiles: its tile server receives the administrator's browser requests and requested map areas; device markers are rendered within the cabinet. The default DB-IP location lookup is local as described in section 3.
Other connection participants receive the content you share and the information needed to connect. Organisation owners and authorised administrators can receive member, device, history, audit and billing information within their permissions. If a customer operates a Private relay, the customer and its hosting provider handle the connection information and encrypted traffic routed through that infrastructure and are responsible for its operation and their own processing.
Authorised Remoqa personnel in Russia can access personal data and operational records for support, administration and security. The cabinet includes an administrator sign-in-as-user function, which allows a service administrator to access the account interface without asking for your password. This function provides access to the account interface; it is separate from the encrypted live session-content channel. We may disclose relevant information to professional advisers, competent authorities or other recipients when necessary and lawful for an obligation, investigation or legal claim.
10Where information is processed
We use DigitalOcean to host the primary application and database in Singapore. Our backups are also stored in Singapore. Authorised Remoqa personnel access personal data from Russia for support, administration and security.
Remoqa relay servers currently operate in Singapore and the Netherlands. They forward encrypted session traffic and process the connection information needed to route it. When a relay is needed, the service automatically selects an available node with the aim of providing a low-latency, reliable connection for both participants, using network measurements, location and availability. It does not guarantee use of a particular country or the geographically closest server.
We may add, replace or retire relay locations as demand and service needs change. The current locations describe the network in operation and do not limit its future geographical coverage. We will keep the processing-location information in this policy up to date and provide any notices and safeguards required by applicable law before changes take effect. The other participant in a remote session may also be in another country.
The informational landing is delivered through DigitalOcean's CDN using Cloudflare's global network. Website request and security information can therefore be processed at network locations outside Singapore or your country. This CDN is not used for the cabinet, Core API or remote-session relay services.
For service emails, Plunk Cloud states that contact and email data are stored in Germany and that delivery through Amazon SES may involve transit outside the European Economic Area. Its published data-processing terms identify subprocessors and transfer safeguards. The provider and processing countries for the support mailbox are [SUPPORT MAILBOX PROVIDER AND PROCESSING COUNTRIES].
For international transfers subject to legal restrictions, the applicable transfer destinations and safeguards are [TRANSFER DESTINATIONS APPLICABLE LEGAL MECHANISMS AND SAFEGUARDS]. Contact [email protected] for information about those safeguards and a copy where the law gives you that right.
11Retention and account deletion
We retain personal data only for as long as needed for the stated purpose and applicable legal requirements. Different categories have different retention periods depending on their purpose and the obligations that apply. The retention periods are:
- Active account, organisation and device records are retained while needed to provide and administer those accounts, memberships and registered devices. Closing an account starts the restoration process below; removing a member or unlinking a device does not necessarily erase independent session, audit or financial records.
- Closed account profiles: the current application default is five years from a closure you request, or one year from automatic closure for an unverified email address. Eligible profiles are permanently deleted by a daily cleanup task after the deadline. These periods support restoration and do not establish a legal requirement to keep every data category or override applicable rights to earlier erasure.
- Guest browser-host devices: inactive devices with no open session are normally retired after 30 minutes of inactivity by a periodic cleanup. Their records become eligible for permanent deletion after one year from retirement, or from the last recorded activity for an unretired record. Retirement is logical deletion, not immediate erasure of every related record.
- Diagnostic reports are deleted once older than one calendar month by a daily cleanup. Extended audit events expire one year after recording and are removed by daily cleanup. These schedules do not apply to all connection history or traffic records. Retention of connection history and traffic records: [CONNECTION AND TRAFFIC RECORD RETENTION].
- Authentication and request-security data: login sessions expire under the storage settings in section 8; account closure also ends its server-side login sessions and clears reset and remember-me tokens. Password-reset and verification links expire after 60 minutes by default. Expiry limits use of a token; it is not a promise that all related logs have been erased. Access, security and infrastructure log retention: [SECURITY AND INFRASTRUCTURE LOG RETENTION].
- Financial records and evidence of purchases or renewal authorisation are retained for the accounting, tax and claims periods applicable to the transaction. The record-specific periods and their starting events are [FINANCIAL AND CONTRACT RECORD RETENTION].
- Support correspondence is retained for twelve months after the enquiry is closed, then deleted. Attachments are deleted within thirty days after they are no longer needed to resolve or follow up the enquiry; they are not automatically retained for the full correspondence period. Material required by an applicable legal obligation or for a particular legal claim or investigation may be retained for that matter, with access limited to that purpose, and deleted when that need ends. Copies in backups follow the separate backup-retention rules below.
- Google Analytics is configured to retain event data for two months and user data for fourteen months; Google also applies the latter period to key-event data. New activity restarts the user-identifier retention period. Expired data is removed through Google's monthly deletion process; standard aggregated reports are not limited by these settings. Cookie lifetimes and further details are in the Cookie Policy. Reports you export to your own device remain under your control. The current landing has no early-access sign-up form; any retained historical submissions require a separate retention and deletion review.
- Service email content, contact and delivery/failure records: [PLUNK AND REMOQA SERVICE EMAIL RETENTION]. Disabling open and click tracking does not erase delivery records or message content.
- Backups and replicated copies: [BACKUP RETENTION AND DELETION DELAY]. Any restoration process must respect applicable erasure requests rather than reintroduce data for ordinary use after it should have been deleted.
Closing an account does not immediately erase every record. Account closure deactivates the profile, ends its login sessions and unlinks its devices. Successfully signing in to an eligible closed account before its restoration deadline restores the profile; blocked accounts and accounts whose deadline has passed cannot be restored this way. Restoration does not automatically relink devices or restart a cancelled subscription. An individual profile closure does not necessarily erase records independently held by an organisation or another session participant. You may separately request erasure; the restoration period does not override applicable rights to earlier deletion.
Information needed for a specific legal obligation, fraud investigation or legal claim may be retained for the appropriate period with restricted access. After the relevant purpose ends, it should be deleted or anonymised. You can separately request erasure or other rights at [email protected]; we will explain any lawful reason for retaining particular information.
12Your rights and choices
Depending on the applicable law, you may have rights to receive information, access or correct your data, request erasure, restrict or object to processing, receive portable data, withdraw consent, or seek review of certain automated decisions. Consent withdrawal does not affect processing that was lawful before withdrawal. Mandatory rights do not depend on having a paid plan.
You can manage available profile, device, organisation and billing settings in the cabinet. For a privacy request, contact [email protected]. We may ask for information reasonably necessary to identify the relevant records and verify your authority, without requesting unnecessary sensitive documents. We will respond within the period required by the law that applies and explain any lawful refusal or limitation.
Where GDPR rights apply, you may request access, correction, erasure, restriction and, where its conditions are met, portability. You may object to processing based on legitimate interests and withdraw consent to consent-based processing. You may complain to a supervisory authority, including in the country where you live or work or where the alleged infringement occurred. Other applicable privacy laws may provide comparable or additional rights. If an organisation controls the relevant activity, contact its privacy contact; we will assist as required by our role. Contacting us first is not a condition for making a complaint to an authority.
We currently send service notifications only. Necessary account, transaction, security and material service messages may continue while they are needed to provide the Services or meet legal obligations. Contact [email protected] with questions about a notification or your communication preferences.
13Security
We use password hashing, authenticated device identities, account and role-based access checks, request throttling and encrypted remote-session channels. Browser device identity keys are stored separately in the browser's identity storage. These measures protect different parts of the service; end-to-end encryption of session content does not mean that all account or billing data is end-to-end encrypted. We limit access according to the function being performed and maintain measures appropriate to the information and risks involved.
No internet service or endpoint can guarantee absolute security. Protect your credentials and devices and authorise only trusted participants. Report a suspected personal-data incident to [email protected]. We will make notifications to affected people or authorities where required by applicable law.
14Children and sensitive information
Minors may use Remoqa with permission from a parent or legal guardian where local law permits, subject to the requirements in our Terms of Service. Parents or guardians are responsible for permitting and supervising that use. Remoqa does not provide a dedicated in-product process for collecting or verifying parental permission to use the Services. This family permission is separate from the lawful basis or consent required for processing a child's personal data. Where applicable law requires Remoqa to obtain or verify parental consent for a particular processing activity, that activity may take place only after the requirement is met. Acceptance of the Terms does not itself constitute consent to optional analytics or other processing requiring a separate choice.
Where GDPR rules on consent for online services offered directly to children apply, the age below which parental authorisation is required is set by the relevant country between 13 and 16. That rule concerns consent-based processing; it is not a universal account-age rule or proof of capacity to purchase. Other countries may impose different requirements. A parent or guardian can contact [email protected] about a child's use or data. We will assess requests concerning missing required consent or unlawful processing and restrict the relevant processing or erase data where required.
Remote content and support attachments may contain health, financial, biometric or other sensitive information even when we do not request it. Share only what is necessary and lawfully authorised. Do not include passwords, full card credentials or unrelated sensitive information in a support request. An organisation processing sensitive data through Remoqa must identify the additional legal condition and safeguards applicable to its activity; ordinary contract acceptance does not remove those requirements.
15Automated controls
Automated service checks verify credentials and device identity, limit repeated requests, apply plan quotas and determine whether a connection or renewal can proceed. A failed check may temporarily block an attempt, deny a connection or leave a purchase or renewal pending. These are service-access and billing rules, rather than decisions based on an assessment of your personality or behaviour for advertising. If a check affects you incorrectly, contact [email protected] for review by a person. Any additional rights concerning solely automated decisions with legal or similarly significant effects remain available under applicable law.
16Changes and contact
We may update this policy when the Services, processing activities or applicable requirements change. We will post the updated policy with its effective date and notify account holders by service email about material changes. Where a new purpose or activity requires consent or another legal condition, we must meet it before starting that processing. A notice of a change does not itself supply consent.
For questions or requests, contact [email protected]. The Terms of Service, including the software licence and payment terms, are available at remoqa.com/terms.