Mullvad

Mullvad is a free and open-source commercial virtual private network service based in Sweden.

9.3/10

How we calculate ratings →

Handling

Does the policy allow personally-targeted or behavioral marketing? No

10/10

Does the service allow you to permanently delete your personal data? Yes, by contacting someone

3/5

Even if there is a reasonable delay before the data is fully deleted (as is common), the data still counts as "permanently deleted" and satisfies the parameters for this question.

Score

Yes, by contacting someone

60%

Yes, using an automated mechanism

100%

N/A

The service doesn't collect any personal information.

100%

Citation

You have the right, in certain situations, to request us to correct or delete incorrect personal data regarding you and/or limit the processing. You also have the right to request for a copy of your personal data and a registry extract. However, we cannot give out payment data since the purpose of the processing of the payment data do not require identification of the data subject and would require disproportionate effort for us to further acquire or process additional information to identify the data subject (article 11 in the GDPR).

The registry extract and the copy of personal data will be provided to the data subject (if the personal data are not subject to article 11 in the GDPR) without undue delay and in any event within one month of receipt of the request. If the request is particularly complex or if we receive number of the requests, the period may be extended where necessary. In this event we will inform the data subject of any such extension within one month of receipt the request together with the reason for the delay.

Where the legal basis for the processing is based on a weighing of interests you are as a data subject entitled to object at any time to the processing of your data.

If you are displeased with our processing of your personal data, please contact us or submit a complaint to the supervisory authority (The Swedish Data Protection Authority, www.datainspektionen.se).

If you would like to exercise your rights, please contact support@mullvad.net for more information.

Please note that exercising some rights may limit our ability to provide support that requires such information, for example issuing a refund or finding a lost account. We are also unable to approve some request due to legal requirements or that the processing of personal data might be based on a legal basis to which the right do not apply.

Does the service allow third-party access to private personal data? Yes, all parties specified (only to critical service providers)

8/10

This may come in the form of outright data sharing or by using local third-party analytics software (such as Google Analytics, which collects a plethora of user information).

Note that whether the policy allows sharing aggregated user data does not affect this question.

If the personal data is encrypted when it passes through the third-party, it does not count as third-party access (as the data is inaccessible to that party).

If personal data has been made public by, for example, posting it to a blog, it does not count as private personal information (and is therefore not considered by this question).

Score

Yes

The policy allows sharing personal data with third parties (not just critical service providers), and does not explicitly list the third parties.

Yes, all parties specified (including non-critical service providers such as advertisers)

30%

Yes, not all parties specified (but only to critical service providers)

70%

Yes, all parties specified (only to critical service providers)

80%

100%

Citation

For credit card, PayPal, Swish, and bank wire, we do use third parties: Stripe, PayPal, and our bank SEB (which handles both Swish and bank wire).

Notes

This is in their "No Logging Data Policy" which is linked via their privacy policy (https://mullvad.net/help/no-logging-data-policy/#payments)

When does the policy allow law enforcement access to personal data? N/A (no personal data to share)

5/5

Score

Always

This includes cases in which law enforcement either runs the service or has a known backdoor into (or relationship with) the service.

Not specified

When reasonably requested

60%

Only when required by a court order or subpoena

80%

N/A (no personal data to share)

The service would have no personal data to share with law enforcement.

100%

Never (special legal jurisdiction)

The service operates in a jurisdiction in which sharing data with law enforcement is never required.

100%

Citation

The data must be kept for the statutory retention period described in applicable local laws such as the Swedish Accounting Act (some information must be stored for seven years from the end of the fiscal year). If not required by law, the data will be stored for no longer than necessary for the purpose. After the periods, the data will be permanently deleted.

Transparency

Does the policy outline the service's general security practices? N/A

3/3

Score

Somewhat

The policy provides only a very vague overview of its security practices.

30%

Yes

60%

Yes, including audits

"Reviews," "monitoring," etc. also count as audits.

80%

Yes, including independent audits

Independent "reviews," "monitoring," etc. also count as independent audits.

100%

N/A

The service doesn't collect any personal information.

100%

Notes

Excluding payment data (which is deleted "after six months" at most), no personal data is collected nor stored to warrant the need to disclose security measures for data handling.

Is the policy's history made available? Only the date it was last modified

3/5

Does the policy require users to be notified in case of a data breach? N/A

7/7

Will affected users be notified when the policy is meaningfully changed? N/A

5/5

Collection

Does the service collect personal data from third parties? No

10/10

Is it clear why the service collects the personal data that it does? Yes

10/10

Score

Somewhat

30%

Mostly

70%

Yes

100%

N/A

The service doesn't collect any personal information.

100%

Citation

Payments
Payment information are processed for the purpose of providing you with the service we offer, to pay out refunds and for accounting purposes. The processing of payment data for the first two purposes are based on a legitimate interest where our rights to process the data for such interest overrides your rights to your personal data. Payment information processed for accounting purposes are necessary for the compliance of a legal obligation to which we are subject.

Support and problem report
Processing of e-mails and problem reports via our app/client are made for the purpose of answering questions, resolve problems, and provide general support to customers. The processing is necessary for the purpose of the legitimate interests where such interest overrides your rights to your personal data.

Categories of personal data
We are processing the following categories of personal data. Mullvad can access the personal data below through our payment service providers but that does not necessarily mean that Mullvad are storing the data anywhere else than in the service. See our No-logging of user activity policy to see details about what data we store.

Payments

Bank wire: sender name, address, bank account number and Mullvad account number
PayPal: transaction-ID, sender name, origin country and e-mail address
Swish: Swish-ID, name and phone number
Stripe: Stripe charge ID, expire date, last 4 digits of the card, card type and origin country

Please avoid making payments through bank wire if you do not want your Mullvad account to be traceable to you. When making such payments, the Mullvad account number will exist in the "message" field of the transaction.

Support and problem report

Support by e-mail: your e-mail address and other information which you have written in the e-mail.
Problem reported by the app/client: (program logs, email, IP-addresses and sensitive path are removed). Please refrain from entering any personal data when reporting a problem by the app/client.

Does the service allow the user to control whether personal data is collected or used for non-critical purposes? N/A (no data used for non-critical purposes)

10/10

Does the policy list the personal data it collects? Yes, exhaustively

10/10

Score

The policy does not claim to not collect personal data, but it also doesn't provide any meaningful insight into the types of personal data it collects.

Only summarily

The policy uses overly vague language to provide a summary of the types of collected personal data.

30%

Yes, generally

All general categories of collected personal data are listed, though not all types of personal data are explicitly mentioned (for example, the list might use a phrase like 'such as' when listing types of personal data).

70%

Yes, exhaustively

All types of collected personal data are listed specifically

100%

N/A (no personal data is collected)

100%

Citation

Payments

Bank wire: sender name, address, bank account number and Mullvad account number
PayPal: transaction-ID, sender name, origin country and e-mail address
Swish: Swish-ID, name and phone number
Stripe: Stripe charge ID, expire date, last 4 digits of the card, card type and origin country

Last Updated

June 24, 2020

Sources

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Contributors

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