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Plain-English summary
Mullvad VPN processes payment information for services, refunds, and accounting, using third-party providers for this purpose (data_use-1). Exercising certain data rights may limit Mullvad's ability to provide support for refunds or lost accounts (data_use-3).
Additionally, in most user requests, Mullvad may not be able to provide data due to their minimal data storage, except for payment data which they cannot give out if it requires disproportionate effort to identify the data subject (data_use-2).
85% confidence
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Risk Flags
Critical issues that need immediate attention or understanding. These are often indicators of potential significant harm or highly one-sided terms.
Not clearly stated: There were no findings that could be confidently categorized as 'risk_flags' based on the provided clauses.
Data Use & Sharing
This section reviews how your data is collected, processed, and shared with others.
medium85% confidence
Payment data processed by third parties
Mullvad processes payment information for specified purposes, and this data is handled by third-party payment service providers.
Why it matters: Your payment information is processed by third-party service providers on behalf of Mullvad for handling payments, refunds, and accounting.
Payment information are processed for the purpose of providing you with the service we offer, to pay out refunds and for accounting purposes. The processing of payment data for the first two purposes are necessary for us to be able to handle the payment (i.e. performance of contract) Payment information processed for accounting purposes are necessary for the compliance of a legal obligation to which we are subject.
Payments, paragraph 1 · Citation strength: strong
low70% confidence
Limited data provided when exercising rights
In most cases, Mullvad will not be able to provide users with data when they exercise their rights, except for payment data, which cannot be provided due to identification requirements.
Why it matters: You may not be able to receive your personal data or a registry extract in most cases, as Mullvad generally does not store data that allows for identification, except for payment data which cannot be given out if identifying the data subject would require disproportionate effort.
However, in most cases we will not be able to provide you with any data since we not store data except payment data which we cannot give out since the purpose of processing the payment data do not require identification of the data subject and would require disproportionate effort for us to further acquire or process additional information to identify the data subject (article 11 in the GDPR).
The rights of individuals, paragraph 2 · Citation strength: strong
low85% confidence
Exercising rights may impact support
Exercising certain rights may limit Mullvad's ability to provide support that requires specific information, such as issuing a refund or finding a lost account.
Why it matters: If you exercise some of your privacy rights, it may affect Mullvad's ability to assist you with support issues like refunds or locating your account.
Please note that exercising some rights may limit our ability to provide support that requires such information, for example issuing a refund or finding a lost account.
The rights of individuals, paragraph 5 · Citation strength: strong
Cancellation & Renewal
This section reviews terms related to canceling your service, refunds, and automatic renewals.
Not clearly stated: There were no findings that could be confidently categorized as 'cancellation_renewal' based on the provided clauses.
Gotchas
Unexpected or less-than-obvious clauses that may be to your detriment. These often include one-sided terms or clauses that limit your rights.
Not clearly stated: There were no findings that could be confidently categorized as 'gotchas' based on the provided clauses.
Protections
These clauses are beneficial to you as the user, enhancing your rights, privacy, or security.
Protection90% confidence
Commitment to anonymity and minimal data retention
Mullvad's policy is to keep users anonymous, never store activity logs or metadata, and maintain minimal data retention.
Why it helps: This commitment indicates a strong focus on user privacy by minimizing the collection and retention of personal data.
Our underlying policy is that we want you to remain anonymous when using our service. It is therefore our policy to never store any activity logs or metadata and to have as minimal data retention as possible.
Mullvad explicitly states that no automated decision making, including profiling, takes place.
Why it helps: This ensures that personal data is not used for automated decisions or profiling, which can be beneficial for privacy and prevent algorithmic bias.
No automated decision making (including profiling) takes place.
Users have the right to file a complaint with the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY).
Why it helps: This provides users with an avenue to escalate privacy concerns to a regulatory body, offering an additional layer of protection and oversight.
You have the right to make a complaint to the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, “IMY”, www.imy.se).
The rights of individuals, paragraph 3 · Citation strength: strong
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