NL-incorporated VPN (Surfshark B.V., Amsterdam, KvK 81967985): moved from BVI to NL Oct 2021, merged with Nord Security 2022, RAM-only, Deloitte-audited.
Public DPA: No
Sub-processors: Yes
Open source: No
Netherlands
Sovereignty
A single roll-up of ownership and CLOUD Act exposure.
EU-Sovereign
EU/EEA/Switzerland-owned and -operated, with no identified CLOUD Act exposure.
EU-Based
This listing
EU-operated, with at most minor or transient US exposure.
EU-Hosted
EU hosting available, but a US parent or hyperscaler sub-processor creates material exposure.
US-Linked
Operated by a US-incorporated entity, directly subject to US jurisdiction.
—
Paid
€2.49/mo, annual
CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
None
EU operator, no US parent, no US sub-processors of note.
Minor
This listing
A transient US sub-processor (CDN, maps); data at rest stays in the EU.
Material
US parent, or a core sub-processor is a US-owned hyperscaler.
Direct
The operator itself is US-incorporated.
Italian hacktivist-founded VPN (Perugia, 2010), no-logs, port forwarding, but no longer serves Italian residents (Piracy Shield).
Public DPA: No
Sub-processors: No
Open source: No
Italy
Sovereignty
A single roll-up of ownership and CLOUD Act exposure.
EU-Sovereign
This listing
EU/EEA/Switzerland-owned and -operated, with no identified CLOUD Act exposure.
EU-Based
EU-operated, with at most minor or transient US exposure.
EU-Hosted
EU hosting available, but a US parent or hyperscaler sub-processor creates material exposure.
US-Linked
Operated by a US-incorporated entity, directly subject to US jurisdiction.
—
Paid
€7/mo
CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
None
This listing
EU operator, no US parent, no US sub-processors of note.
Minor
A transient US sub-processor (CDN, maps); data at rest stays in the EU.
Material
US parent, or a core sub-processor is a US-owned hyperscaler.
Direct
The operator itself is US-incorporated.
Swedish founder-owned VPN (Mullvad VPN AB / Amagicom AB, Gothenburg, 2009), anonymous numbered accounts, Cure53-audited, flat €5/month.
Public DPA: No
Sub-processors: Yes
Open source: Yes
Sweden
Sovereignty
A single roll-up of ownership and CLOUD Act exposure.
EU-Sovereign
This listing
EU/EEA/Switzerland-owned and -operated, with no identified CLOUD Act exposure.
EU-Based
EU-operated, with at most minor or transient US exposure.
EU-Hosted
EU hosting available, but a US parent or hyperscaler sub-processor creates material exposure.
US-Linked
Operated by a US-incorporated entity, directly subject to US jurisdiction.
—
Paid
€5/mo
CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
None
This listing
EU operator, no US parent, no US sub-processors of note.
Minor
A transient US sub-processor (CDN, maps); data at rest stays in the EU.
Material
US parent, or a core sub-processor is a US-owned hyperscaler.
Direct
The operator itself is US-incorporated.
Oslo-heritage browser VPN (Opera Norway AS): Deloitte-audited free browser proxy + paid VPN Pro, but ultimately Chinese-controlled via Kunlun Tech (Opera Limited, Cayman/NASDAQ). Listed as a warning.
Public DPA: No
Sub-processors: Yes
Open source: No
Norway
Sovereignty
A single roll-up of ownership and CLOUD Act exposure.
EU-Sovereign
EU/EEA/Switzerland-owned and -operated, with no identified CLOUD Act exposure.
EU-Based
EU-operated, with at most minor or transient US exposure.
EU-Hosted
This listing
EU hosting available, but a US parent or hyperscaler sub-processor creates material exposure.
US-Linked
Operated by a US-incorporated entity, directly subject to US jurisdiction.
—
Freemium
€4/mo
CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
None
EU operator, no US parent, no US sub-processors of note.
Minor
A transient US sub-processor (CDN, maps); data at rest stays in the EU.
Material
This listing
US parent, or a core sub-processor is a US-owned hyperscaler.
Direct
The operator itself is US-incorporated.
Finnish publicly listed VPN (F-Secure Corporation, Helsinki; Nasdaq Helsinki: FSECURE), formerly FREEDOME VPN, ISO 27001-certified company-wide but with no independently audited no-logs claim.
Public DPA: No
Sub-processors: Yes
Open source: No
Finland
Sovereignty
A single roll-up of ownership and CLOUD Act exposure.
EU-Sovereign
EU/EEA/Switzerland-owned and -operated, with no identified CLOUD Act exposure.
EU-Based
This listing
EU-operated, with at most minor or transient US exposure.
EU-Hosted
EU hosting available, but a US parent or hyperscaler sub-processor creates material exposure.
US-Linked
Operated by a US-incorporated entity, directly subject to US jurisdiction.
ISO/IEC 27001
Paid
€4/mo, annual
CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
None
EU operator, no US parent, no US sub-processors of note.
Minor
This listing
A transient US sub-processor (CDN, maps); data at rest stays in the EU.
Material
US parent, or a core sub-processor is a US-owned hyperscaler.
Direct
The operator itself is US-incorporated.
Gibraltar-incorporated VPN (IVPN Limited / ex-Privatus, founded 2009), Cure53-audited no-logs, open-source apps, independent ownership.
Public DPA: No
Sub-processors: Yes
Open source: Yes
Gibraltar
Sovereignty
A single roll-up of ownership and CLOUD Act exposure.
EU-Sovereign
EU/EEA/Switzerland-owned and -operated, with no identified CLOUD Act exposure.
EU-Based
This listing
EU-operated, with at most minor or transient US exposure.
EU-Hosted
EU hosting available, but a US parent or hyperscaler sub-processor creates material exposure.
US-Linked
Operated by a US-incorporated entity, directly subject to US jurisdiction.
—
Paid
€6/mo
CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
None
This listing
EU operator, no US parent, no US sub-processors of note.
Minor
A transient US sub-processor (CDN, maps); data at rest stays in the EU.
Material
US parent, or a core sub-processor is a US-owned hyperscaler.
Direct
The operator itself is US-incorporated.
CERN-founded Swiss VPN (Proton AG, Geneva), owned by non-profit Proton Foundation; 15,000+ servers, audited no-logs, open-source apps, free tier.
Public DPA: Yes
Sub-processors: Yes
Open source: Yes
Geneva · CH
Switzerland
Sovereignty
A single roll-up of ownership and CLOUD Act exposure.
EU-Sovereign
EU/EEA/Switzerland-owned and -operated, with no identified CLOUD Act exposure.
EU-Based
This listing
EU-operated, with at most minor or transient US exposure.
EU-Hosted
EU hosting available, but a US parent or hyperscaler sub-processor creates material exposure.
US-Linked
Operated by a US-incorporated entity, directly subject to US jurisdiction.
—
Freemium
€5/mo
CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
None
EU operator, no US parent, no US sub-processors of note.
Minor
This listing
A transient US sub-processor (CDN, maps); data at rest stays in the EU.
Material
US parent, or a core sub-processor is a US-owned hyperscaler.
Direct
The operator itself is US-incorporated.
Stockholm-operated VPN, US-owned since the 2023 Pango acquisition (operating entity OVPN Inc.); fully owns its hardware, diskless RAM-only, court-proven no-logs, legal-fees insurance.
Public DPA: No
Sub-processors: Yes
Open source: No
United States
Sovereignty
A single roll-up of ownership and CLOUD Act exposure.
EU-Sovereign
EU/EEA/Switzerland-owned and -operated, with no identified CLOUD Act exposure.
EU-Based
EU-operated, with at most minor or transient US exposure.
EU-Hosted
This listing
EU hosting available, but a US parent or hyperscaler sub-processor creates material exposure.
US-Linked
Operated by a US-incorporated entity, directly subject to US jurisdiction.
—
Paid
€4.22/mo, annual
CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
None
EU operator, no US parent, no US sub-processors of note.
Minor
A transient US sub-processor (CDN, maps); data at rest stays in the EU.
Material
This listing
US parent, or a core sub-processor is a US-owned hyperscaler.
Direct
The operator itself is US-incorporated.
