Solid from everything I've looked over. Their issue previously was logging IP addresses and complying with legal requests. This changed a bit with Swiss legal victories, and the VPN obviously which can be paid in BTC, so there's nothing to log but the address you used to pay, which they don't have a legal requirement to save, but is obviously permanent given blockchain properties. Rumors of LN integration are floating around, which would be quite powerful with the static route where your @proton.me address is also your Ln address. I wrote about them recently: #228463