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The answer appears to be yes though involuntarily.



We can see that by ourselves from their transparency report.

https://web.archive.org/web/*/https://protonmail.com/blog/tr...

- 2019/04/20 https://web.archive.org/web/20190420195556/https://protonmai...

- 2019/04/25 https://web.archive.org/web/20190425155330/https://protonmai...

The diff is simple and clear: ...

+In April 2019, at the request of the Swiss judiciary in a case of clear criminal conduct, we enabled IP logging against a specific user account which is engaged in illegal activities which contravene Swiss law. Pursuant to Swiss law, the user in question will also be notified and afforded the opportunity to defend against this in court before the data can be used in criminal proceedings.

Diff from 2019/04/25 to today: ...

-Updated on 13.03.2019 +Updated on 24.04.2019

-ProtonMail is not required to store communications metadata or IP information, as we are exempted from the Swiss Federal Act on the Surveillance of Post and Telecommunications (BÜPF) and its accompanying ordinance. Therefore, ProtonMail can apply a policy of collecting as little user information as possible to protect user privacy. To know exactly what kind of metadata your use of ProtoMail creates, please refer to our Privacy Policy. Upon receiving a judicial order, ProtonMail is obliged to provide any user information readily available that would help identify a user that is subject to a criminal investigation that has been validated by Swiss authorities.

+ProtonMail is not required to store communications metadata or IP information, as we are exempted from the Swiss Federal Act on the Surveillance of Post and Telecommunications (BÜPF) and its accompanying ordinance. Therefore, ProtonMail can apply a policy of collecting as little user information as possible to protect user privacy. To know exactly what kind of metadata your use of ProtoMail creates, please refer to our Privacy Policy. Upon receiving a judicial order, ProtonMail is obliged to provide any user information readily available that would help identify a user that is subject to a criminal investigation that has been validated by Swiss authorities. In addition to the items listed in our privacy policy, in extreme criminal cases, ProtonMail may also be obligated to monitor the IP addresses which are being used to access the ProtonMail accounts which are engaged in criminal activities. Under no circumstances will ProtonMail be able to provide the contents of end-to-end encrypted messages sent on ProtonMail.


In a nutshell: No data retention (yet) but real-time surveillance of metadata.




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