TunnelBear is a global company. Although our physical servers are located in many different countries around the world, TunnelBear does not store Personal Data outside of Canada's physical borders. By using our services, you authorize TunnelBear to use your information according to Canada's laws, regardless of which country you are located in.
As a provider of an online privacy service, we ultimately strive to collect the minimal amount of information required to operate our service. This often means difficult trade-offs between the information we collect and the performance of our service.
As described below, "Personal Data" means any information relating to an identified or identifiable natural person ("Individual") and includes information provided by you while using our Services. If we use or store Personal Data with information that is non-personal, we will consider the combination as Personal Data.
We strive to collect the minimum amount of information required to operate our service.
When you create or update your TunnelBear user account, we collect and store this "Account Data". The Account Data stored is listed below in its entirety:
TunnelBear previously collected your full name as part of the account creation process. Having your full name allowed us to personalize communications and customer support. However, through TunnelBear's regular data privacy discussions, we decided that it was more important to protect privacy than to customize communications. As a result, we have deleted this data and you are now only required to provide your email address when creating a TunnelBear account.
If you pay for our services with a credit card, we do still collect your last name along with your payment information, see 1.4 Personal and Financial Data Collected at Payment for more details.
TunnelBear also collects and stores "Operational Data" required to operate our Services. This is data that we collect and store when you connect to our network. Operational data is listed below in its entirety:
Understanding how much data people are using is a critical metric for TunnelBear. It tells us if people are using TunnelBear, if people have reached their free data limit, if the service is working properly and it also helps us plan for demand on our network. However, choosing a usage metric that respects your privacy is challenging task. We decided that collecting the overall amount of data used by a specific user, for the current month, was the correct balance. We also ensure that no historical record is kept by resetting the total monthly usage value to 0 at the end of each month. We felt that overall usage would respect individual user privacy (i.e. no login timestamps, no logs, etc.) while still providing the most vital data for TunnelBear to efficiently operate our service.
Some data is used to ensure customer satisfaction.
Making a purchase with a credit card on any service will result in Personal Data being exchanged with payment processors. For an anonymous purchase experience, TunnelBear offers payment through Bitcoin. No information is collected or stored from Bitcoin transactions.
TunnelBear processes credit card payment information securely through Stripe and PayPal. Credit card processors may store Personal Data associated with financial transactions outside of Canada's borders.
When you pay with credit card, TunnelBear stores the following information:
TunnelBear does not store, but can securely login and view the following information through our third party payment processors Stripe and PayPal:
TunnelBear never stores your complete credit card number. To keep your payment information secure, we adopt all available security and multi-factor authentication measures available from these providers.
TunnelBear operates exclusively with PCI compliant payment processors. Only our payment processors have the ability to collect, use and access your full credit card information and other financial information. They can use this information solely for the purpose of charging and invoicing you for our (paid) Services.
No one likes credit card fraud. As a service that's serious about online privacy, TunnelBear can attract some dodgy characters that attempt to use stolen credit cards to purchase upgraded TunnelBear accounts. Despite trying a number of commercial solutions, credit card fraud became a significant enough problem that we built our own proprietary machine-learning anti-fraud solution.
To enhance the effectiveness of TunnelBear's anti-fraud tools, we sometimes store your Last Name and the last four numbers of your credit card (and only last 4 numbers) when you upgrade your TunnelBear.
This information is exclusively stored for the purposes of making the use of stolen credit cards to purchase TunnelBear as annoying as possible for thieves.
Some data is used to prevent purchase fraud.
In building our website and apps, we have tried to limit the number of services with access to store cookies in your browser. There are currently three third-party services with this ability. These services store data for as short a time as possible.
TunnelBear explicitly does NOT collect, store or log the following data:
Any Personal Data you provide to TunnelBear will be administered according to the following principles:
Except as described below, TunnelBear will NOT disclose any Personal Data to other commercial parties under any circumstance:
We may send data to third-party service providers who operate services that help us with: customer support; email; hosting, protecting, and securing the TunnelBear infrastructure; DDoS prevention; payment processing; as well as understanding website analytics, account and payment related service usage.
In the event TunnelBear is served with a valid subpoena, warrant or other legal document and applicable law requires TunnelBear to comply, the extent of disclosure is limited to the Personal Data listed within this Privacy Notice.
As noted above, TunnelBear utilizes PCI-compliant third-party payment processors to collect your credit card and other billing information.
If our organization structure changes (e.g., we undergo a restructuring or are acquired), we may need to migrate your Personal Data to a third party related to a business transaction, but, we will ensure that such a third party has entered into an agreement under which the use of your Personal Data is only related to purposes necessary for the transaction.
TunnelBear does NOT store users' originating IP addresses when connected to our service and thus cannot identify users when provided IP addresses of our servers. Additionally, we cannot disclose information about the applications, services, or websites our users consume while connected to our Services; as TunnelBear does NOT store this information.
You have the right to ask us not to contact you. To exercise your choices or ask questions about your Personal Data, please contact us by visiting our privacy center.
We take great care to not collect Personal Data indiscriminately and limit collection to the minimum necessary information required to operate our service. By limiting the collection of data, we help to protect the privacy and security of your Personal Data.
We will not use your Personal Data for any purpose that you have not consented to. TunnelBear will NOT sell or trade Personal Data for commercial purposes.
Only TunnelBear's employees with a business need to know or whose duties require, are granted access to our customers' Personal Data. All such employees will be required as a condition of employment to respect the confidentiality of our customers' Personal Data.
We store your Personal Data only as long as is necessary for the purposes for which it is collected, to provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. We erase or destroy the records containing Personal Data when they are no longer required; this will be done in ways that will ensure your continued privacy.
It is your responsibility to inform TunnelBear of any relevant changes in your Personal Data by updating your account information.
TunnelBear uses exceptionally strong safeguards to protect the privacy of all our records, including your Personal Data. We implement physical, business and technical security measures. These strong safeguards are designed to prevent unauthorized access, disclosure, loss, theft, copying, use or modification to your Personal Data.
So that you can be confident that we are handling your Personal Data appropriately, we take extraordinary measures to document our policies and provide openness and transparency around the data we collect, why we collect it and how we handle it.
If at any time you have a question about our records containing your Personal Data, we will do our best to answer it. You have the right to be told about the kind of Personal Data we maintain and how it is used. Upon request, we will provide you with information regarding the existence, use and disclosure of your Personal Data.
If you are visiting from the European Union, please note that by providing your Personal Data, you consent to any transfer of your Personal Data to Canada and processing of your Personal Data globally in accordance with this Policy.
You have the right to inquire as to whether TunnelBear is Processing Personal Data about you, request access to Personal Data, and ask that we correct, amend or delete your Personal Data where it is inaccurate.
Visit TunnelBear's privacy center to request access to, receive (port), seek rectification, or request erasure of Personal Data held about you by TunnelBear.
To protect your privacy, TunnelBear requires you to login to your account with a username and password before granting you access to or allowing you to make any changes to your Personal Data.
TunnelBear makes good faith efforts to provide you with the ability to delete your Personal Data, however there may be circumstances in which TunnelBear is unable to delete all your Personal Data. For example, we are unable to delete it where we are legally required to keep it, including where we need it to continue to offer you the service or if you are involved in litigation with us, we would be required to retain your personal data, which is limited to the fields we discuss above in 1.2, 1.3 and 1.4.
If TunnelBear determines that your Personal Data cannot be deleted, we will explain why and provide a contact for further inquiries.
If your privacy concerns or complaints are not addressed to your satisfaction by TunnelBear you may contact the Office of the Privacy Commissioner of Canada for further guidance at:
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
Phone: (819) 994-5444
TTY: (819) 994-6591
We welcome your thoughts and feedback.