Privacy Policy

July 16, 2018

This Privacy Policy describes how TunnelBear LLC. ("TunnelBear") handles your Personal Data when you use our services ("Services").

By using our Services and/or registering for an account, you are accepting the terms of this Privacy Policy and our Terms of Service, which are integrated here by reference.

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.

If you have any questions or comments about this Privacy Policy, please contact us at: privacy (at) tunnelbear.com

1. Personal Data Collection and Use

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.

We believe in an open dialogue because this Privacy Policy is an evolving document. We welcome your thoughts and feedback on how we're doing.

1.1 What is Personal Data?

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.

1.2 Account User Data

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:

Account Data
What do we use it for?
Email address
Marketing, communications, purchase receipts and occasional product news
Twitter ID (optional)
Completion of our Twitter promotion
Email confirmed
Confirmation that your email address is valid
Paid user
Provide paid users with unlimited data
Paid user expiry date
Provide paid service until this date

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.

1.3 Operational Data

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:

Operational Data
What do we use it for?
OS Version
e.g. iOS 7
User support, troubleshooting and product planning
TunnelBear App Version
e.g. PC version 2.1.1
User support and troubleshooting
Active this month
e.g. 1 or 0
Customer satisfaction, support, network demand planning
Total data used this month
e.g. 22.34 GB
Customer satisfaction, support, network demand planning, granting free user data
Operational events
e.g. Created an account, complete Twitter bonus, made a payment
Troubleshooting account and payment related issues, these events are not related to the time and activity of VPN usage

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.

1.4 Personal and Financial Data Collected at Payment

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.

Credit Card 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:

Payment Data
What do we use it for?
Cardholder last name
e.g. Smith
For use in credit card fraud prevention
Date of card use
e.g. 2014/01/01
For use in credit card fraud prevention
Last four Numbers of Credit Card
e.g. 5555
For use in credit card fraud prevention

TunnelBear does not store, but can securely login and view the following information through our third party payment processors Stripe and PayPal:

Payment Data
What do we use it for?
Card billing address
For use in credit card fraud prevention
Card expiry
For use in credit card fraud prevention
Last four Numbers of Credit Card
For use in credit card fraud prevention

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.

1.5 Cookies and Persistent Trackers

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.

Cookie Details
Why do we store it?
Cookie name: tb_aff
Service: TunnelBear marketing source
Cookie expiry: 30 days
TunnelBear records a bit of information that helps us track how people are finding TunnelBear (e.g. Social media or Google search).
Cookie name: TB_SESSION
Service: TunnelBear website customization
Cookie expiry: 7 days
This cookie stores your account type and is used to customize your TunnelBear.com account.
For example, if you have a paid account, we set your bearType to Grizzly and all of the graphics change to Grizzly Bears. We set a cookie so we don't have to continue checking your account type in the database as you use the website.
Cookie name: tb_user
Service: TunnelBear authentication
Cookie expiry: 30 days
tb_user allows us to understand whether you are a new or returning visitor to our website. By setting this cookie, we're able to customize the content on our own without using any third party tools.
Cookie name: play_session
Service: TunnelBear authentication
Cookie expiry: 7 days
play_session is the authentication token for TunnelBear.com. It allows you to use your account without having to continuously login.
Cookie name: XSRF_token
Service: TunnelBear XSRF protection
Cookie expiry: 1 year
One common attack used against website visitors is a cross-site request forgery attack. TunnelBear uses this cookie to protect you from XSRF attacks.
Cookie name: _ga
Service: Google Analytics – IP anonymization enabled
Cookie expiry: 2 years
To make our website better, we use Google Analytics (GA) to see how many people are visiting it. We have set GA to use the minimum available retention period and not store IP addresses.
Cookie name: _gaid
Service: Google Analytics – IP anonymization enabled
Cookie expiry: 24 hours
To make our website better, we use Google Analytics (GA) to see how many people are visiting it. We have set GA to use the minimum available retention period and not store IP addresses.
Cookie name: _gat
Service: Google Analytics – IP anonymization enabled
Cookie expiry: 1 minute
Google Analytics uses this cookie to limit the number of requests that we can make to their service in a given time period.
Cookie name: _cfuid
Service: DDoS protection - Cloudflare ID
Cookie expiry: 1 year
TunnelBear uses Cloudflare to protect our service from DDoS attacks. Cloudflare uses _cfuid in your browser so that once they have checked to see if you're a bot, they won't have to check again while you use our website.
Cookie name: _stripe_mid
Service: Payment provider - Stripe user
Cookie expiry: 1 year
TunnelBear uses Stripe to process credit card payments on our website. Stripe uses this cookie to help prevent fraud on TunnelBear.com.
Cookie name: _stripe_sid
Service: Payment provider - Stripe session
Cookie expiry: 24 hours
TunnelBear uses Stripe to process credit card payments on our website. Stripe uses this cookie to help prevent fraud on TunnelBear.com.

1.6 Other Data TunnelBear Just does NOT Collect

TunnelBear explicitly does NOT collect, store or log the following data:

  • IP addresses visiting our website
  • IP addresses upon service connection
  • DNS Queries while connected
  • Any information about the applications, services or websites our users use while connected to our Service

No logging!

2. Personal Data

Any Personal Data you provide to TunnelBear will be administered according to the following principles:

2.1 Accountability

Should you have any concerns about how your Personal Data is handled or questions about this Privacy Policy, feel free to contact us at privacy (at) tunnelbear.com

2.2 Disclosure of Personal Data to Third Parties

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.

2.3 Consent and Legitimate Interest

When you sign up for our Service and provide us Personal Data, you allow us to process that information in accordance with this Privacy Policy. We rely on legitimate interest for marketing, research, and fraud prevention. We will obtain your consent where required by law.

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.

2.4 Limiting Collection

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.

2.5 Limiting Use, Disclosure, and Retention

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.

2.6 Accuracy

It is your responsibility to inform TunnelBear of any relevant changes in your Personal Data by updating your account information.

2.7 Safeguards

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.

2.8 Openness and Transparency

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.

2.9 Individual Access

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.

2.10 Individual Access

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.

2.11 Rights of Access, Rectification, Erasure, and Restriction

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 you have any questions about our privacy practices, this Privacy Policy, or how to lodge a complaint with the appropriate authority, please contact TunnelBear by email at privacy (at) tunnelbear.com. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

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
Toll-free: 1-800-282-1376
Phone: (819) 994-5444
TTY: (819) 994-6591
www.priv.gc.ca

2.12 Changes to Our Privacy Policy

We may need to change our Privacy Policy from time-to-time and all updates will be posted online. Your continued use of our Services after the effective date of such changes constitutes your acceptance of such changes. We will post an effective date at the top of the page for your convenience.

We welcome your thoughts and feedback.