ProtonVPN

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

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Transparency

Does the policy require users to be notified in case of a data breach? No

0/7

Decided May 17, 2020 (revision history). This question accounts for 8% of the final score.

Note that all companies operating in the EU are subject to Art. 33 of the GDPR, which requires companies to notify their data protection authority of a data breach within 72 hours of discovering it.

Possible Options

No0/7
Yes, eventually5/7
Yes, within 72 hours7/7
N/A (the service collects so little personal data that notification would not be possible)7/7

Note

No mention of such in this policy

Click here to suggest a change or to flag this conclusion as incorrect, or here for more information.


Will affected users be notified when the policy is meaningfully changed? No

0/5

Decided May 17, 2020 (revision history). This question accounts for 6% of the final score.

Possible Options

No0/5
Yes5/5
N/A (no personal data—or contact information—collected)5/5

Citation

The Company reserves the right to periodically review and change this Policy, and will notify users who have enabled the notification preference about any change. Continued use of the Service will be deemed as acceptance of such changes.

Click here to suggest a change or to flag this conclusion as incorrect, or here for more information.


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

3/5

Decided May 17, 2020 (revision history). This question accounts for 6% of the final score.

Possible Options

No0/5
Only the date it was last modified3/5
Yes, with revisions or a change-log5/5

Citation

Last modified: March 11, 2020

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Does the policy outline the service's general security practices? Somewhat

1/3

Decided May 17, 2020 (revision history). This question accounts for 4% of the final score.

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

Possible Options

No0/3
Somewhat1/3
Yes2/3
Yes, including audits2.5/3
N/A (no personal data collected)3/3
Yes, including independent audits3/3

Citation

We take data security very seriously. Only our employees have physical or other access to our infrastructure and Secure Core servers. Data is usually stored in encrypted format on our servers. Offline backups may be stored periodically, but these are also secured.

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Collection

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

10/10

Decided May 17, 2020 (revision history). This question accounts for 12% of the final score.

This question deals with transparency. Even if the service uses data for reasons that aren't ideal for privacy, provided they list all of those uses, the service can still receive full credit for this question. However, if they are not explicit about their uses (by employing language like "such as"), a lower score is assigned.

Possible Options

No0/10
Somewhat4/10
Mostly7/10
Yes10/10
No personal data is collected10/10

Citation

How we use this personal data: Your email address is not shared with any third parties. We mainly use it for account-related questions, communication, and recovery. By signing up to our Service, you agree to receive communications from us, which may include promotional emails too. You can stop receiving emails from us by following the unsubscribe instructions included in every email we send. Alternatively, you can login to the ProtonVPN dashboard and adjust your email preferences under the ‘Account’ tab.

Click here to suggest a change or to flag this conclusion as incorrect, or here for more information.


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

10/10

Decided May 17, 2020 (revision history). This question accounts for 12% of the final score.

All types of collected personal data are listed specifically

Possible Options

No0/10
Only summarily3/10
Yes, generally7/10
Yes, exhaustively10/10
N/A (no personal information is collected)10/10

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.

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.

Click here to suggest a change or to flag this conclusion as incorrect, or here for more information.


Does the service collect personal data from third parties? No

10/10

Decided May 17, 2020 (revision history). This question accounts for 12% of the final score.

This includes the use of data brokers and independent verification authorities (such as background check providers).

Possible Options

Yes0/10
Only for critical data7/10
No10/10

Note

No mention of such in policy

Click here to suggest a change or to flag this conclusion as incorrect, or here for more information.


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

3/5

Decided May 17, 2020 (revision history). This question accounts for 6% of the final score.

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.

Possible Options

No0/5
On an opt-out basis, but only for some non-critical data/uses1.5/5
On an opt-out basis, for all non-critical data/uses3/5
N/A (no data used for non-critical purposes)5/5
On an opt-in basis5/5

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.

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Handling

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

10/10

Decided May 17, 2020 (revision history). This question accounts for 12% of the final score.

Possible Options

Yes0/10
Yes, but you can opt-out3.5/10
Yes, but you must opt-in7/10
No10/10

Citation

We do not do any targeted advertising or any profiling.

Click here to suggest a change or to flag this conclusion as incorrect, or here for more information.


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

7/10

Decided May 17, 2020 (revision history). This question accounts for 12% of the final score.

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).

Possible Options

Yes, not all parties specified0/10
Yes, all parties specified (including non-critical service providers such as advertisers)3/10
Yes, not all parties specified (but only to critical service providers)7/10
Yes, all parties specified (only to critical service providers)8/10
No10/10

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.

Click here to suggest a change or to flag this conclusion as incorrect, or here for more information.


Does the service allow you to permanently delete your personal data? Yes, using an automated mechanism

5/5

Decided May 17, 2020 (revision history). This question accounts for 6% of the final score.

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.

Possible Options

No0/5
Yes, by contacting someone3/5
Yes, using an automated mechanism5/5
N/A (no personal information collected)5/5

Citation

Through the Service, you can directly access, edit, delete or export personal data processed by the Company in your use of the Service. [...] Data retention: We retain essential data (such as username, email, billing information) on active accounts in order to provide services. This data is deleted when your account is deleted.

Click here to suggest a change or to flag this conclusion as incorrect, or here for more information.


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

4/5

Decided May 17, 2020 (revision history). This question accounts for 6% of the final score.

Possible Options

Always0/5
Not specified0/5
When reasonably requested3/5
Only when required by a court order or subpoena4/5
N/A (no personal data to share)5/5
Never (special legal jurisdiction)5/5

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.

Note

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/)

Click here to suggest a change or to flag this conclusion as incorrect, or here for more information.



Warnings

ProtonVPN has no warnings published on PrivacySpy. PrivacySpy publishes warnings when it learns a service has announced a data breach or is found misusing user data. If you believe a warning should be published for ProtonVPN, submit one here.


Highlighted Policy Snapshot ALPHA

No highlighted policy snapshot has been created for this privacy policy. To view the policy at its original location, click here.

7.4/10

How we calculate ratings →


Version Added

May 17, 2020

Ratings Updated

May 17, 2020

Warnings

0

Maintained by

doamatto

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