Proton - Privacy policy

Last modified: 15 March 2023

At Proton, we strongly believe in an internet where privacy is the default.

Proton’s Privacy Policy describes how Proton collects, uses, and deletes your data. In addition to this Privacy Policy, we provide data and privacy information specific to our products that use your personal data. This product-specific information can be found in the following privacy policies :

By using the proton.me website and making use of a Proton Account (the “Account”) and all its related features, including Proton Mail, Proton Calendar, Proton Drive and Proton VPN (the “Services”), you understand that your data in relation with your use of our Services is processed according to the following privacy policy and its product-specific privacy policies (together, the "Privacy Policy"). The Privacy Policy states (i) what data we collect through your access and uses of the Services; (ii) the use we make of such data; and (iii) the safeguards put in place to protect your data. The Privacy Policy is to be read and understood as being a complement to our terms and conditions.

1. Legal framework

The Services are operated by Proton AG (the “Company”, “We”), domiciled at Route de la Galaise 32, 1228 Plan-les-Ouates, Geneva, Switzerland. It is therefore governed by the laws and regulations of Switzerland. Additional information about the legal framework can be found in our transparency report.

We are also GDPR compliant. The designated representative of the Company in the European Union (notably for the purpose of art. 27 GDPR) is Proton Europe sàrl, rue de Grünewald 94, L-1912 Luxembourg.

2. Data Proton collects from you, and how we use it

Our overriding policy is to collect as little user information (personal data included) as possible to ensure a private user experience when using the Services. We do not have the technical means to access the content of your encrypted emails, files, and calendar events.

Data collection is limited to the following:

2.1 Visiting proton.me website: We employ a local installation of self-developed analytics tools. Analytics are anonymized whenever possible and stored locally (and not on the cloud). IP addresses are not retained and stored for such analytics.

2.2 Account creation and Account Activity: Data processing activities related to Account creation and Account activity may vary between our Services. They are detailed in the product-specific privacy policies listed in preamble:

2.3 Communicating with Proton: Your communications with us, such as support requests, bug reports, or feature requests may be saved by our staff. The legal basis for processing is our legitimate interest to troubleshoot more efficiently and improve the quality of our Services.

2.4 Payment information: We rely on third parties to process credit card, PayPal, and Bitcoin transactions and must therefore share payment information with them. Anonymous cash or Bitcoin payments and donations are accepted. The legal basis of this processing is the necessity to the execution of the contract to provide the Services.

2.5 Native applications: When you use our native applications, we (or the mobile app platform providers) may collect certain information. We may use mobile analytics software (e.g. fabric.io(new window) 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 in order to rapidly fix bugs. Some platforms, such as Google’s Play Store or Apple’s App Store may also collect aggregate, anonymous statistics, which may be governed by their respective privacy policies and terms and conditions. Such statistics can include most commonly used devices and operating systems, total number of installs and uninstalls, and the total number of active users.

Our applications do not access or track any location-based information from your device.

2.6 Blog: We have a public blog on our website. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your personal information appears on our blog and you want it removed, contact us here.

2.7 Social Media: We are active on Facebook, Instagram, Linkedin, Twitter, Reddit, and Mastodon. Any information, communication, or material you submit to us via social media platforms is done at your own risk without any guarantee of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.

3. Network traffic that may go through third-parties

Proton's alternative routing technology allows Proton Services to bypass many censorship blocks, but in doing so your network traffic may go through third-party networks, which we do not control. This could enable a third party to record your IP address or see that you are using Proton apps (the same information that your internet service provider is able to see). These third parties cannot see your actual data, which remain encrypted. By default, alternative routing is not used for Proton apps unless they detect that censorship measures are active on your network. Alternative routing can also be disabled in the settings panel of our mobile and desktop applications. However, doing so may cause you to be unable to access your Account from a network that is censoring Proton. Learn more

4. Data subprocessors

To provide the Services, we rely on different data subprocessors, which process different categories of data. Processors never store data outside of the scope of their specific purpose. Notably, they do not store data in relation with the general day-to-day use of your Account and Services, which is exclusively processed by the Company. Subprocessors are as follow:

4.1 Proton Group subprocessors

ProtonLabs DOOEL Skopje

Purpose: Process data in relation with customer support requests, or other direct communications with the company (section 2.4)
Data processing location: Macedonia

ProtonLabs Taiwan Co., Ltd

Purpose: Process data in relation with customer support requests, or other direct communications with the company (section 2.4)
Data processing location: Taiwan (R.O.C)

4.2 Third-party subprocessors

Zendesk, Inc.

Purpose: Provide services in relation with the processing of customer support data (section 2.4)
Data processing location: United States

Stripe, Inc.

Purpose: Provide services in relation with the processing of payment data (section 2.6)
Data processing location: United States

PayPal group

Purpose: Provide services in relation with the processing of payment data (section 2.6)
Data processing location: United States, Singapore

5. Data disclosure

We will only disclose the limited user data we possess if we are legally obligated to do so by a binding request coming from the competent Swiss authorities. We may comply with electronically delivered notices only when they are delivered in full compliance with the requirements of Swiss law. Proton’s general policy is to challenge requests whenever possible and where there are doubts as to the validity of the request or if there is a public interest in doing so. In such situations, we will not comply with the request until all legal or other remedies have been exhausted. Under Swiss law, subjects of judicial procedures have to be notified of such procedures, although such notification has to come from the authorities and not from the Company. Under no circumstances can Proton decrypt encrypted message content and disclose decrypted copies. Aggregate statistics about data requests from the competent Swiss authorities can be found in our transparency report.

6. Your privacy rights at Proton

Through your Account interface, you can directly access, edit, delete, or export personal data processed by the Company in your use of the Services.

If your Account has been suspended for a breach of our terms and conditions, and you would like to exercise the rights related to your personal data, you can make a request to our support team.

In case of violation of your rights, you have the right to lodge a complaint to the competent supervisory authority.

7. Modifications to Privacy Policy

Within the limits of applicable law, the Company reserves the right to review and change this Privacy Policy at any time. As long as you are using the Services, you are responsible for regularly reviewing this Privacy Policy. Continued use of the Services after such changes are performed shall constitute your consent to it.