ProtonVPN

ProtonVPN is a virtual private network service provider operated by the Swiss company Proton Technologies AG.

8.1/10

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

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

Support: When you submit support requests or bug reports, we will collect the data that you choose to share with us about the issue being reported. Bug reports sometimes rely on third parties, such as Zendesk.

Payment: The Company relies on third parties to process credit card and PayPal transactions, and we do not save your full credit card details. For example, if you make a payment with a credit card, your name and the last 4 digits of the credit card number will become part of the invoice and saved by us. Anonymous cash or Bitcoin payments and donations are also accepted.

When does the policy allow law enforcement access to personal data? Only when required by a court order or subpoena

4/5

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 when compelled by law for the purposes of the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including the safeguarding against and the prevention of threats to public security. Foreign authorities' data requests must be approved by competent Swiss authorities.

Under Swiss law, it is obligatory to notify the target of a surveillance request, although such notification may come from the authorities and not from the Company.

Notes

As mentioned on their Warrant Canary: "To be counted here as a legal request for information, the request must come through official channels foreign or domestic (either a court order, directly from a government entity, or from legal/security departments of corporations). The only legally binding requests are ones from the Swiss courts that we are legally obligated to comply with. Under Swiss data protection regulations, we cannot legally comply with foreign requests that are not supported by a Swiss court order." (https://protonvpn.com/blog/transparency-report/)

Transparency

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

We take data security very seriously. Access to our infrastructure and Secure Core servers is tightly controlled. All of the ProtonVPN servers are encrypted and we do not log VPN session data. Offline backups may be stored periodically, but these are also secured. For users with heightened security needs, it is possible to optionally i) enable 2FA on account access ii) enable login history so that suspicious login attempts can be tracked iii) remove the linked recovery email iv) pay anonymously with cash or bitcoin.

Notes

All ProtonVPN apps are now open source and audited.

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? Not necessarily

0/7

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

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

Does the service allow the user to control whether personal data is collected or used for non-critical purposes? On an opt-out basis, for all non-critical data/uses

6/10

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 use analytics software to help us deliver a higher quality of service. For instance, looking in aggregate at the geographic distribution of the Service's users allows us to understand which countries have the most need for the Service and allocate development resources towards providing the best service in those countries. Viewing longer term trends in the number of visitors from different countries also allows us to identify quickly which countries have started to block the Service and take measures to counteract those blocks. Finally, analytics also helps with our outreach and growth initiatives, which are efforts to help our Company reach and protect the largest number of people possible.

How do we collect non-personal website data: We may use various cookies to collect and store information when you visit our website. Users can control the use of cookies at the individual browser level.

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

Account creation: To create an account, in order to use our Service, we do not ask your name or surname. All you need to do is select your username, then provide the email address and choose your password. You can also register with your existing ProtonID.

We do store the email address (or ProtonID) you have entered when creating an account for communication and anti-abuse purposes. If you are referred to the Service by a friend or some other third-party who is participating in our referral program, we may associate your account with the referrer to appropriately credit the referrer.

Last Updated

June 16, 2021

Sources

Source #1 ↗

Contributors

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