Security and safety of your data is something we make an essential priority at Exoscale. We understand that trusting an external entity with your data is a difficult step to take.
Getting in touch
First and foremost, if you need to get in touch with the team in for
critical security purposes, we encourage you to send a PGP-encrypted
email@example.com which will ensure that only
security-accredited personnel at Exoscale will be be able to read it.
We ask that you also use this method to contact us should you discover any security issue with the service, as well as apply standard responsible disclosure etiquette.
Our 4096-bit RSA PGP key has
3B56 0B12 22F9 B377 816A C2AA 17CC 751B 885C 11AD
it is reproduced below:
-----BEGIN PGP PUBLIC KEY BLOCK----- mQINBGDkE0sBEADIcN+FpEVoTaPEhR89qgEgdHUIKT+TcStpFYzsKAkMEI59D1iL y+F7AD9f/VpTNPtpi3jfS+R/sR5fr3TANFfgOXs7Z/FRwGNHLgBF1Y+P9JhwypVf qNgv+KAHsvZjyraCZ2RAdn4QB4EC3oGNI3ZogvnuC+anFVowkEgwqdEMUBT1ZVMB 3h9FX+o5Aej2VDZlh1PU1MuA0cNCu32F7JP6l9xdzBv6/klkyjg4jpUklxJbpj7Z +dT/ss62asWNj2H3DZW03r9lXH9NuMSGuemVgbThvzdngZPmo911aF6AgReWagBS Y9u0PArmwo3AtxrWdup0D2DrUgD/WZJu3mQu8Iq2epcAOrKcg3rC9NhFeP+2xZT3 o6aTGpV+9jTJS77WWjXuT69wUbGGHeeN8Asdm8OSvGBdRV1EdxQFH0J0F0axlQUg jDjnUOQI5ZX8MM2ru/tXVi5dtkpAhAy6Ah+io6DA+hHuCKjONMLfVmhvSsIHeq6D E7KdHPyih9rC6qZw7B0fGJv9Dby0HPtU/SCEeY+mgZl1tqe6U17azzdHRylDUeWC 7vGtlhNo5FaGjzCgq8Z3EC53cEVTSKJCrbMjxyhwIaY25pcgF5rHqT1XmJ1iOFVs HIHpIfVV8yMQNTWXsA+4G63MLZF0BHJEkcIqEG+roSIfSHv1qf4XTTiXUwARAQAB tC1zZWN1cml0eUBleG9zY2FsZS5jb20gPHNlY3VyaXR5QGV4b3NjYWxlLmNvbT6J Ak4EEwEKADgWIQQ7VgsSIvmzd4FqwqoXzHUbiFwRrQUCYOQTSwIbAwULCQgHAwUV CgkICwUWAgMBAAIeAQIXgAAKCRAXzHUbiFwRrXhlD/4zvW+x0y1cdcgGu4SRtltK 1kBNl2Rb9GVv1qopIXMPuA4edHbu5gstZiOIB0dpLc4UVJMYViZZ4MLHUTNs3XcG Up7liMC5tS3b5p3El4IYcCNDsLsZu9PQwxtMpLftU/BEiMly29va9dPDeJdtGRNS VGJilxovqOvtNUGN5ktiq510aKl2eogzIQ00JkjyBv5cSmgcsyZus1vr8UkGkStE MuxKlLAIr6vX67F3ZXAyRebgQ6kGLXJRa61o1zsVgUqP+NdRb8gAQ5lXJAAIU2mK RPqMTRApdVq6r4A6CMZBfNecP1GP/31Z7eIJ6GY9/QaYsiV8pXbgvtZX6CPD4yaA iazbmrvP1z9d8Wx7T7mttC+xa7gMuDwxcpmcilR6k1pXWAh7e+i/uweZYnBHFjOu 1Zr9NEQtHLAB4QJbYyahXe+Vw3eRhi5JHlrGqpc+H8OhAk6q6z80o3GnYlXMzKF+ 2lcaVONg62w0M98mPs3Z8Xoraqi01QNhvJE7wwt2B5j+5MyU04nT9VTJxQgbD7pA 4Sb3slSN47sD4mcfpfQdVwz3PnWNByGPhF3T7RBmKm0XMonHiu07IAMHCA1iWFYM h+z3NyaCR4ZKADmtpbvcxY9BN8L/1cZRmq+q8hMAElRLHvLpMfxc61L7voeri1iQ FzK8qAvlz6ZRhn3Xt5Es8LkCDQRg5BNLARAA2A2N+odfqDNt3c1xBACY/ttUuCTO 3fHJiUGXtLcjyoAruqF3ItXKeuwDJMNHYz7qyZJWRcK52Bh9oE0w5LxrhphPYrjO vAlwXQAiBsFHixcU2Fim6tfG6N9d+2zi9DsqddKSM/MozaCKxQyJXObRG8SFMUld t8B3mQbNY55xrHD5kNEGvioY7l55kS5MjLtDrUbWnI9758g9kh1eoFNiwHSXEEnV YMjeIXFDjJS/1ALhZDN5y2UF48OcI04O83G1X+t9DXRu8Op/7LyX83gzHPeX8uMX kSLJA4wDUezkze5XpRJJkCEIA9JnqtWLPtt53YumtRVsGjSAk7+5S/X9hIYvZFa3 P9/nCxEcT29hwUj9ERAKaUxVq3+S9krkwaTPLB0diIGLBs/+SK4w/UdmFu000wCI IBVx59gHOxwCLb4oWNeiY6dfQ5eSxkznAWdKpJvLpBgIvdGRfCdWSmt4DkCHszRY w66cnizX9uIduj7Nc1DCYdl0gdqXKVFzzI6T08YNeHsWEr9FWc5PmvhXSfNm/SrZ R7Jzi/uZfTyxf+hqmKOGhyiaDrNdyoiqvq7FgHznsBBPmurUh726K2cOeCjT1s83 /+MOh1oku9CW9NpI2xPRXWjMpG46Grqy+bbg+nTRQFzjjAbN7MhGurJ6SKqzQKRm 5ltB5C8C+fm84iEAEQEAAYkCNgQYAQoAIBYhBDtWCxIi+bN3gWrCqhfMdRuIXBGt BQJg5BNLAhsMAAoJEBfMdRuIXBGtgCIQALu3wUFqDR9pzY855wbwDX2UcHvdiU+R hXss2wiCvQeU0SoBvi+ViqvindUXnvPR+m/vqIhjzxgfvLMX1+rpPKIba1IJ3PIw QrtVe5azLT6k3naIZARwBThG75Xqb1iHjb5MaBB8zx64dOsv6lvUF2glVFjFFzUH JT3SjyknDjg0F4BRxkdD2HmFn0hQ0w1nzYQ4wdqcLdXgAoDoXVD2brivTTm3At0a YVFi4C5WyRe9mPmJ7sNb9uWDXBNYhJ+PkXRU/sbhP+CSyZ9IgzbMQl4Z8XoqQ9t1 Vl0u60TZgnE+iv5kjQE8gmi/EbXB+RIZfngMFGWOQaaJ4tmzdeV+W87tQmcQ6WLU fkyiNvcoZhHJKvld0k7uhACwuyE6IBjelHkXZA6E7VmeO/nC4tm4zM8hajHeMsxs Wi7skGs1JxZjc/rIcJ+HwUWNuKZ9986DOQt/SPDJi4iWrlheqT4E01PpDArqdOHz aBkK7+/E5KWQv9gyXMzrTu0KgOzo6hAaprc+4UGFRZfD+hCWLYI2Fcs/6MIvzbG3 P+v8H+0+yZlsrob4nbDiRjdqmWJSaG0VBYFD+vKQCpON2rjRd6IHamWjGrTua+x6 NVmc0Tf75nOxgtQEA23N6zgn8WSKU/xlhSsZA19xer4/BmHaQ17H8AtljuV2K5Zx 0eOFbD/ugeC9 =TQmN -----END PGP PUBLIC KEY BLOCK-----
Our security model in plain English
Who has physical access?
We only operate from locations conforming to the most restrictive security standards (ISO27001) and we are part of the Cloud Security Alliance (CSA).
Conforming to recommendations made in these frameworks and standards, we track all access to datacenters. Only Exoscale staff and accredited Datacenter personnel have physical access. We keep an audit trail of access to individual datacenter racks. We also work with trained staff for operations such as disk changes or hardware reboots.
When drives are decommisioned they are destroyed or cryptographically locked.
Some of our locations are hosted in datacenters operated by Equinix, a US-based multinational company. Equinix has published a statement regarding the non-applicability of the US Cloud Act legislation in regards to Equinix EMEA activity stating that, by their nature, data center services do not fall within the scope of the activities covered by the Freedom Act and related legislation. The full statement is available here.
Who has logical access?
The operations team at Exoscale is the only team which has actual access to hypervisors and storage nodes. Strict access control is maintained and tracked, as well as regular credentials cycling.
We rely on very few external services to maintain the highest possible level of security and reduce our threat-model to a minimum. We still can’t do everything by ourselves, so we rely on a few external providers.
We rely on two services which are PCI-DSS for processing payments:
- Adyen which processes credit cards.
- PostFinance which processes legacy credit card records and postcard payments.
- Paypal which processes Paypal payments.
We do not store any credit card information - only anonymized tokens, as provided by these services.
We additionally use the online accounting solution provided by Bexio, a Swiss company with a dedication to security similar to ours, to provide faster reconciliation of wired payments. As such, invoice information is duplicated on Bexio.
We only gather website analytics for our public websites (this website, as well as https://community.exoscale.com). No activity within our web portal is ever tracked. Our provider for website analytics is Matomo.
We use Mailchimp to send email campaigns and newsletters. We do not store address lists at Mailchimp, but synchronize on a per-campaign basis to avoid storing your email addresses permanently there.
Below this point, we dive in deeper detail on the exact frameworks and standards we adhere to. You can read on if you are interested in the fine print.
Exoscale has elected the Cloud Security Alliance (CSA) framework in order to structure and enforce the compliance controls regarding all aspects of security with 100 control points dealing with:
- Data Governance
- Information Security
- Risk Management
- Security Architecture
We conform to the OCF Level 1, having completed our Cloud Control Matrix which maps to the following selected frameworks:
- HIPAA / HITECH Act
- ISO/IEC 27001-2005
- PCI DSSv2.0
- BITS Shared Assessments
Roles and responsibilities
Roles and responsibilities vary upon the cloud model chosen. These are defined by the SPI stack, as defined in the CSA guidance:
“The lower down the stack the cloud service provider stops, the more security capabilities and management consumers are responsible for implementing and managing themselves.”
Therefore, please note that as an IaaS provider with Exoscale, most responsibilities and data access control enforcement are on the customer’s side. Nevertheless, we impose on ourselves a high level of security on all infrastructure layers, as described in the following sections.
Laws and Regulation
At general level, concerning data and activities conducted in our Swiss datacenters, we are mainly subject to the Swiss Code of Obligations.
The purpose of this section is to answer general questions within the context of Exoscale, providing IaaS Cloud Computing Services to the customer. We want to bring to your attention in particular the Data Protection and Export Control obligations.
Concerning data and activities conducted in our Swiss datacenters, we are mainly subject to the Swiss Federal Data Protection Act (“DPA”) and the Swiss Federal Data Protection Ordinance (“DPO”). Unlike most other countries, the Swiss data protection laws and regulations apply not only to individuals, but also legal entities.
Collecting and Processing Personal Data
When collecting data, the collector shall ensure that he
- informs data subjects about the data processing and its intended purpose;
- informs data subjects about whether the data will be disclosed to third parties and whether a transfer outside Switzerland is contemplated; and
- obtains any consents required for the data processing.
The DPA provides that the mere act of collecting personal data constitutes the processing of personal data. Therefore, all legal requirements which apply to the processing of personal data also apply to the collection of personal data. Among others, the following provisions shall be complied with in the processing of personal data:
- Personal data must be processed in good faith; Personal data must not be collected by misrepresentation or deception; The processing of personal data must be proportionate.
- Personal data may only be used for the purpose intended at the time of collection.
- The collection of personal data and the purposes for which the personal data is processed must be obvious to the person/entity from whom personal data are collected.
- Anyone who processes personal data must not breach the privacy of the data subjects.
- As a rule, no justification for processing personal data is required if the data subjects have made the data generally available and have not expressly restricted the data processing.
- A lawful justification for data processing exists if the data subject has consented to it, the law provides for it, or the data processor has an overriding interest in the data processing.
- The data processing must comply with technical and organizational security requirements, especially when processed electronically. Personal data must be protected against intentional or accidental deletion, accidental loss, technical errors, falsification, theft and unlawful use, unauthorized access, changes, copying, or other unauthorized processing.
- Data processing may be delegated to a third party under an agreement, provided that the third party data processor processes data only to the same extent as the person employing the third party data processor was authorized to do and that no legal or contractual confidentiality obligation prohibits the outsourcing.
Disclosing of Personal Data
The DPA does not permit the disclosure of sensitive data or personality profiles to third parties without lawful justification. The consent of the data subject can constitute a lawful justification. Companies within the same group as the disclosing entity, i.e. the parent company or subsidiaries are considered third parties and the sharing of personal data within a group is deemed to be a disclosure to third parties for the purposes of the DPA.
The DPA prohibits a transfer of personal data abroad if it could seriously endanger the personal rights of the data subjects. If the legislation of the foreign country does not afford adequate protection for the personal data to be transferred or accessed, under Swiss data protection laws and regulations, transfer or access outside Switzerland is not allowed, except in certain restricted cases which have to meet specific requirements with respect to such disclosure abroad. In the latter case, the Federal Data Protection and Information Commissioner must be informed of the safeguards or rules used before the first transfer of data is made, or if that is not possible, immediately after the disclosure has occurred. Please note that we do NOT transfer data outside of the country where it was initially uploaded. For example, data uploaded in one of our Swiss zones is stored in Switzerland only.
Products, software or technical information provided or used in connection to the services may be subject to export laws and regulations of Switzerland and other countries. Any use or transfer of the products, software or technical information must be in compliance with all such applicable regulations.
Disclosure Procedures and Policies
The procedures and policies for responding to a request for data or information disclosure from governmental authorities depends mainly on the treaties entered into with the requesting country. In broad terms, exchange of information between countries may be requested within the context of:
- criminal proceedings or
- tax fraud or tax evasion.
- In case of criminal proceedings, information can be exchanged by way of mutual legal assistance in criminal matters (“MLA”) based on multi- or bilateral agreements or in accordance with the Federal Act on International Mutual Assistance in Criminal Matters. For instance, with respect to the Schengen States, the Federal Law on Exchange of Information between Criminal Proceedings Authorities between Switzerland and the Schengen States shall apply.
- In case of tax fraud or tax evasion, when foreign tax authorities are involved, the exchange of information is carried out by means of administrative assistance within the legal framework of bilateral double taxation agreements (“DTAs”). In the case of tax related criminal proceedings, information can be exchanged also, alternatively, according to section (i) above. In particular, the OECD has concluded a model double taxation agreement with Switzerland, which provides pursuant to Article 26 for a system of administrative assistance among the tax authorities of the signatory countries, according to which States shall exchange information that is foreseeably relevant to the correct application of a tax convention as well as for purposes of the administration and enforcement of “domestic tax laws” of the contracting States upon specific request. Any information received thereunder by a contracting State shall be treated as secret. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions. To date, Switzerland has adopted or renegotiated over 35 Article 26-friendly DTAs. However, the cases where we would be requested directly to transfer data that is stored on our cloud, but that is owned by the customer, seem to be extremely limited. One possiblity would be a case where the customer refuses to transfer data stored by us as requested by competent authorities and such authorities would then request us to provide the relevant information directly. In such an event we would obviously comply with the request, but would promptly inform the customer of the situation to the extent legally possible.
The USA Patriot Act
The USA Patriot Act applies to
- US entities,
- affiliates and subsidiaries of US entities throughout the world,
- servers located in the US independently from the nationality of the entities which operate them, and
- data hosted in Europe by US entities.
Our company is based in Switzerland and does not have any affiliate or subsidiary in the United States. Furthermore, our cloud is hosted in leading data center companies in Switzerland. The data is stored in Switzerland and not in the US. Thus, we are not subject to the USA Patriot Act. However, if a customer is related to entities in the US or servers located in the US, the customer’s data may be subject to the USA Patriot Act.