Update ProtonMail Privacy Policy

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ProtonMail/Privacy Policy.md

@@ -1,7 +1,7 @@
 Privacy Policy
 ==============
 
-_Last modified: June 8th, 2021_
+_Last modified: September 6th, 2021_
 
 By using the protonmail.com website and making use of ProtonMail, Proton Drive and Proton Calendar (the "Services"), you understand that your data in relation with your use of our Services is processed according to the following Privacy Policy.  
 The Services are offered by Proton Technologies AG (the "Company" or "We").  
@@ -25,7 +25,7 @@ Such data will only be used to contact you with important notifications about th
 
 In order to maintain the integrity of the Services, we must take measures to avoid creation of accounts by spammers. This is because if spammers use ProtonMail to send messages, ProtonMail’s IP addresses can become blocked by major mail providers such as Gmail, Yahoo, Outlook, etc.
 
-In order to pursue our legitimate interest of preventing the creation of accounts by spam bots or human spammers, we use a variety of human verification methods. Verification may also be requested for some sensitive operations besides account creation in order to protect against brute-force attacks. You may be asked to verify using either hCaptcha (or reCAPTCHA in the event that hCaptcha is unavailable), Email, or SMS. IP addresses, email addresses, and phone numbers provided are saved temporarily in order to send you a verification code and to determine if you are a spammer. If this data is saved permanently, it is always saved as a cryptographic hash, which ensures that the raw values cannot be deciphered by us. [Learn More](https://protonmail.com/support/knowledge-base/human-verification/)
+In order to pursue our legitimate interest of preventing the creation of accounts by spam bots or human spammers, we use a variety of human verification methods. Verification may also be requested for some sensitive operations besides account creation in order to protect against brute-force attacks. You may be asked to verify using either hCaptcha (or reCAPTCHA in the event that hCaptcha is unavailable), Email, or SMS. IP addresses, email addresses, and phone numbers provided are saved temporarily in order to send you a verification code and for anti-spam purposes. The period of temporary data retention is determined by our legitimate interests of protecting the service from spam, and also by any applicable Swiss legal requirements we must comply with. If this data is saved permanently, it is always saved as a cryptographic hash, which ensures that the raw values cannot be deciphered by us. [Learn More](https://protonmail.com/support/knowledge-base/human-verification/)
 
 Data Collection
 ---------------
@@ -47,13 +47,13 @@ In addition to end-to-end encryption, all content is also cryptographically sign
 
 **Communicating with ProtonMail:** Your communications with the Company, such as support requests, bug reports, or feature requests may be saved by our staff. The legal basis for processing is our legitimate interest to troubleshoot more efficiently and improve the quality of the ProtonMail service.
 
-**IP Logging:** By default, we do not keep permanent IP logs in relation with your use of the Services. However, IP logs may be kept temporarily to combat abuse and fraud, and your IP address may be retained permanently if you are engaged in activities that breach our terms and conditions (spamming, DDoS attacks against our infrastructure, brute force attacks, etc). The legal basis of this processing is our legitimate interest to protect our Services against nefarious activities.  
+**IP Logging:** By default, we do not keep permanent IP logs in relation with your use of the Services. However, IP logs may be kept temporarily to combat abuse and fraud, and your IP address may be retained permanently if you are engaged in activities that breach our terms and conditions (spamming, DDoS attacks against our infrastructure, brute force attacks, etc). The legal basis of this processing is our legitimate interest to protect our Services against nefarious activities. If you are breaking Swiss law, ProtonMail can be legally compelled to log your IP address as part of a Swiss criminal investigation. This obligation however does not extend to ProtonVPN ([see VPN privacy policy here](https://protonvpn.com/privacy-policy)). Additional details can be found in our [transparency report](https://protonmail.com/blog/transparency-report).  
 
 Your login IP address is also kept permanently (until you delete it) if you enable authentication logging for your account (by default this is off). The legal basis of this processing is consent, and you are free to opt-in or opt-out at any time in the security panel of your account.
 
 **Payment Information:** We rely on third parties to process credit card, PayPal, and Bitcoin transactions and must therefore share payment information with third parties. Anonymous cash or Bitcoin payments and donations are however accepted. The legal basis of this processing is the necessity to the execution of the contract between you and us.
 
-**Native Applications:** When you use our native applications, we (or the mobile app platform providers) may collect certain information in addition to the information mentioned elsewhere in this Policy. We may use mobile analytics software (such as fabric.io app statistics and crash reporting, Play Store app statistics, App Store app statistics, or self-hosted Sentry crash reporting) to send crash information to our developers so that we can fix bugs rapidly. Some platforms (such as the Google Play Store or the Apple App Store) may also collect aggregate, anonymous statistics like which type of devices and operating systems that are most commonly used (like percentage of Android 6.x vs Android 7.x), the total number of installs, total number of uninstalls, and the total number of active users, and may be governed by the privacy policy and terms and conditions of the Google Play Store or the Apple App Store. None of the software on our apps will ever access or track any location-based information from your device at any time. Any personal data acquired during this process is anonymized.
+**Native Applications:** When you use our native applications, we (or the mobile app platform providers) may collect certain information in addition to the information mentioned elsewhere in this Policy. We may use mobile analytics software (such as fabric.io app statistics and crash reporting, Play Store app statistics, App Store app statistics, or self-hosted Sentry crash reporting) to send crash information to our developers so that we can fix bugs rapidly. Some platforms (such as the Google Play Store or the Apple App Store) may also collect aggregate, anonymous statistics like which type of devices and operating systems that are most commonly used (like percentage of Android 6.x vs Android 7.x), the total number of installs, total number of uninstalls, and the total number of active users, and may be governed by the privacy policy and terms and conditions of the Google Play Store or the Apple App Store. ProtonMail also has access to certain device IDs which are required for sending push notifications to user devices. None of the software on our apps will ever access or track any location-based information from your device at any time. Any personal data acquired during this process is anonymized.
 
 **Import Assistant:** When using Import Assistant to transfer your data, you can choose from multiple options: