Proton Mail
A single roll-up of ownership and CLOUD Act exposure.
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EU-Sovereign EU/EEA/Switzerland-owned and -operated, with no identified CLOUD Act exposure.
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EU-Based This listing EU-operated, with at most minor or transient US exposure.
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EU-Hosted EU hosting available, but a US parent or hyperscaler sub-processor creates material exposure.
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US-Linked Operated by a US-incorporated entity, directly subject to US jurisdiction.
Swiss end-to-end encrypted email by Proton AG (Geneva); 100M+ users, Foundation-controlled since June 2024.
Proton Mail is a European service hosted in Switzerland, with at most minor, transient US exposure under the CLOUD Act. It is listed under Private email.
Assessment notes
Proton Mail is operated by Proton AG (Geneva CH), controlled by the non-profit Proton Foundation since June 2024, with end-to-end + zero-access encryption, Swiss jurisdiction (outside EU but under FADP + strong privacy law), own Swiss data centres, ISO 27001, 100M+ users, fully open-source clients, independently audited; Foundation-controlled (non-profit, no VC/PE pressure); the US sub-processors (Zendesk support, Stripe/PayPal/Chargebee billing) are ancillary and never touch the end-to-end-encrypted mailbox data, which sits on Proton's own Swiss data centres, so no US processor holds mailbox data at rest; however, every Proton IP range reaches the internet only through Cloudflare's network (AS13335 as the sole upstream, the pattern of Magic Transit DDoS scrubbing, verified via RIPEstat on 2026-10-03), which carries TLS-encrypted traffic and connection metadata but does not terminate TLS and is not named in Proton's processor lists, so CLOUD Act exposure is recorded as minor (a transient US network layer with no plaintext access and no data at rest), consistent with the rest of the Proton estate.
Findings
- CLOUD Act
- CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
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None EU operator, no US parent, no US sub-processors of note.
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Minor This listing A transient US sub-processor (CDN, maps); data at rest stays in the EU.
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Material US parent, or a core sub-processor is a US-owned hyperscaler.
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Direct The operator itself is US-incorporated.
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- Ownership
- Ownership
Where ultimate control over the operating company sits.
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EU-owned EU-incorporated and EU-controlled; no significant US ownership.
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European This listing Swiss/EEA-owned, with no significant US ownership; treated as European.
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EU HQ, US-funded EU-headquartered but US venture- or PE-controlled.
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EU subsidiary, US parent European operating company owned by a US parent company.
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US-owned The operating company itself is US-headquartered.
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- Sub-processors
- 7 · 4 US
Verified signals
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EU / adequacy hosting: Yes
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EU / adequacy operator: Yes
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No US CLOUD Act exposure: Not assessed
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Card-free payment available: YesAccepts Bitcoin and cash by mail alongside cards.
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End-to-end encryption: Yes
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Public DPA: Yes
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Sub-processors disclosed: Yes
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Open-source clients: No
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Third-party certification: Yes
Jump to
About Proton Mail
Proton Mail is the original product within the Proton AG ecosystem (Geneva, Switzerland) and the flagship of the privacy-first email category: end-to-end + zero-access encryption (Proton itself cannot read user emails or attachments), 100M+ users, 100,000+ organisations. Since June 2024 Proton AG is controlled by the Proton Foundation, a Swiss non-profit, which structurally rules out future VC / PE acquisition pressure. Pricing: Free (1 GB); Mail Plus at €4.99 per month billed monthly, or €3.99 per month billed annually (€47.88 for the year), with 15 GB and a custom domain; Proton Unlimited at €12.99 per month billed monthly, or €9.99 per month billed annually, bundling Mail, Drive, Pass, Calendar, Docs, Sheets and VPN. For the full Proton ecosystem profile see proton-drive and protonvpn. Swiss jurisdiction places ownership_signal: other (Switzerland is non-EU but strong-privacy-law); CLOUD Act exposure is recorded as Minor because all Proton traffic transits Cloudflare's network, which carries TLS-encrypted traffic without terminating it.
Sub-processor map · 7
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Chargebee, Inc. USUnited States
Payment data processing; ancillary
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PayPal group USUnited States
Payment data processing; ancillary
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Stripe, Inc. USUnited States
Payment data processing; ancillary
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Zendesk, Inc. USUnited States
Customer support data processing; ancillary
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Atlassian Pty Ltd non-USAustralia
Customer support data storage; policy lists processing in the EU, US and UK
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ProtonLabs DOOEL Skopje non-USNorth Macedonia
Customer support / direct communications (Proton group entity)
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ProtonLabs Taiwan Co., Ltd non-USTaiwan
Customer support / direct communications (Proton group entity)
| Vendor | Country | Purpose | Owner |
|---|---|---|---|
| Chargebee, Inc. | United States | Payment data processing; ancillary | US |
| PayPal group | United States | Payment data processing; ancillary | US |
| Stripe, Inc. | United States | Payment data processing; ancillary | US |
| Zendesk, Inc. | United States | Customer support data processing; ancillary | US |
| Atlassian Pty Ltd | Australia | Customer support data storage; policy lists processing in the EU, US and UK | non-US |
| ProtonLabs DOOEL Skopje | North Macedonia | Customer support / direct communications (Proton group entity) | non-US |
| ProtonLabs Taiwan Co., Ltd | Taiwan | Customer support / direct communications (Proton group entity) | non-US |
Source: the vendor’s published sub-processor list, read 26 Aug 2026.
Frameworks & certifications
Capability matrix
Table 2Capabilities of Proton Mail
Integration & access
Compliance & governance
Pricing & tiers
Public documents
Alternatives in this category
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Germany · €3/moEU-SovereignCLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
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None This listing EU operator, no US parent, no US sub-processors of note.
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Minor A transient US sub-processor (CDN, maps); data at rest stays in the EU.
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Material US parent, or a core sub-processor is a US-owned hyperscaler.
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Direct The operator itself is US-incorporated.
E2E: Yes Public DPA: No Sub-processors: Yes Open source: No -
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Germany · €1/moEU-SovereignCLOUD 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.
E2E: No Public DPA: Not assessed Sub-processors: Yes Open source: No -
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Germany · €1/moEU-SovereignCLOUD 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.
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Direct The operator itself is US-incorporated.
E2E: No Public DPA: Not assessed Sub-processors: Yes Open source: No -
| Product | Sovereignty | CLOUD Act | Signals | From |
|---|---|---|---|---|
Tuta
Germany
|
EU-Sovereign | CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
|
E2E: Yes
Public DPA: No
Sub-processors: Yes
Open source: No
|
€3/mo |
Mailbox.org
Germany
|
EU-Sovereign | CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
|
E2E: No
Public DPA: Not assessed
Sub-processors: Yes
Open source: No
|
€1/mo |
Posteo
Germany
|
EU-Sovereign | CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
|
E2E: No
Public DPA: Not assessed
Sub-processors: Yes
Open source: No
|
€1/mo |