ProtonMail

Secure email service with End-to-End Encryption based in Switzerland.

7.3/10

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, using an automated mechanism

5/5

When does the policy allow law enforcement access to personal data? When reasonably requested

3/5

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

We will only disclose the limited user data we possess if we are instructed to do so by a fully binding request coming from the competent Swiss authorities (legal obligation).

ProtonMail may from time to time, contest requests if there is a public interest in doing so. In such situations, the Company will not comply with the request until all legal or other remedies have been exhausted. Therefore, not all requests described in our Transparency Report will lead to data disclosure.

Notes

ProtonMail is willing to disclose just enough personal data that they think will help authorities investigate a criminal activity, given enough reasons to do so.

Does the service allow third-party access to private personal data? Yes, not all parties specified (but only to critical service providers)

7/10

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

The Company relies on third parties to process credit card, PayPal, and Bitcoin transactions so the Company necessarily must share payment information with third parties. Anonymous cash or Bitcoin payments and donations are accepted however. The legal basis of this processing is the necessity to the execution of the contract between you and us.

Notes

They don't explicitly list the actual third-parties involved.

Transparency

Does the policy require users to be notified in case of a data breach? Not necessarily

0/7

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

3/5

Will affected users be notified when the policy is meaningfully changed? Yes

5/5

Does the policy outline the service's general security practices? Yes, including independent audits

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%

Citation

All servers used in connection with the provisioning of the Service are located in Switzerland and wholly owned and operated by the Company. Only employees of the Company have physical or other access to the servers. Data is ALWAYS stored in encrypted format on our servers. Offline backups may be stored periodically, but these are also encrypted. We do not possess the ability to access any user encrypted message content on either the production servers or in the backups.

Notes

[All ProtonMail apps are now open source and audited. See: openPGP library Android, iOS, bridge.

Collection

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

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%

Notes

ProtonMail includes an extensive list of data that it collects, and the reasons why.

Does the service allow the user to control whether personal data is collected or used for non-critical purposes? No

0/10

Some services allow users to opt-out or opt-in to of non-critical collection or use of personal data, such as collecting data for personalized advertisements.

Score

On an opt-out basis, but only for some non-critical data/uses

30%

On an opt-out basis, for all non-critical data/uses

60%

On an opt-in basis

60%

N/A (no data used for non-critical purposes)

100%

Citation

We employ a local installation of Matomo, an open source analytics tool. Analytics are anonymized whenever possible and stored locally (and not on the cloud).

When you use our native applications, we (or the mobile app platform providers) may collect certain information in addition to the information mentioned elsewhere in this Policy. We may use mobile analytics software (such as fabric.io app statistics and crash reporting, Play Store app statistics, App Store app statistics, or self-hosted Sentry crash reporting) to send crash information to our developers so that we can fix bugs rapidly.

Any personal data acquired during this process is anonymized.

Does the service collect personal data from third parties? No

10/10

Last Updated

June 16, 2021

Sources

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Contributors

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