Change record
CA-C-004902
DeepL Privacy Policy
Entity
Date detected
September 5, 2026
Effective date
September 5, 2026
Severity
Direction
Positive
Taxonomy
Data collection expansion
Changes
+26 sentences added · −1 sentence removed · 70 sentences modified

Impact Summary

Medium Positive for users
Affected users
All users Premium subscribers Business accounts EU users

DeepL expanded its privacy policy in an update detected on September 5, 2026 to introduce three new account-based storage features: Translation Memories (allowing users to store source-target segment pairs for reuse), Translation Memory Generation (processing uploaded documents to create Translation Memories, then deleting the source documents), and Adaptive Translation (using stored Translation Memories and reference documents to customize translations to user terminology and style). The policy also added a new section on the DeepL Partner Program, restructured sections on call recording and transcription, and refined the description of customization features. These changes establish explicit data handling procedures for account-level storage and processing but specify that content is used only within the user's own account and not for model training or other customer use.

1 obligation expanded

Consumers: The privacy notice now clearly explains how and where three new features store your data, and guarantees your data stays in your account only and is never used to train their translation model or shared with other customers.

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What this means for you

The updated terms establish explicit procedures for three new account-based storage and processing features. Translation Memories allow users to store source and target language segments for reuse; Translation Memory Generation processes uploaded document pairs to generate Translation Memories, then deletes the source documents immediately; and Adaptive Translation uses stored Translation Memories and reference documents to customize translations, with numeric representations (embeddings) calculated and stored in the user's account. The policy states that all content and embeddings are used only within the user's own account, never shared with other customers, and never used to train or improve DeepL's models. The policy specifies GDPR Article 6(1)(b) as the legal basis for processing (contract performance). You can deactivate Adaptive Translation in the relevant Style Profile at any time.

What you can do

Review the updated sections on Translation Memories (8.1), Translation Memory Generation (8.2), and Adaptive Translation (8.3) to understand how your stored content is handled and retained.

If using Adaptive Translation, note that you can deactivate the feature in the relevant Style Profile at any time.

Key Clauses Affected

Translation Memories storage and use

New explicit provision stating user-stored Translation Memories are kept accessible at all times, deleted only when user deletes entries or account, and justified under GDPR Article 6(1)(b) contract performance.

Translation Memory Generation data deletion

New explicit provision stating source and translated documents uploaded for Translation Memory generation are deleted immediately after processing and not otherwise stored or used for model training.

Adaptive Translation embedding storage

New explicit provision stating numeric representations (embeddings) of reference documents are stored in user accounts only, used only within that account, never for other customers, and never for model training.

Full clause-by-clause analysis available with Insight.

This change record describes what was added, removed, or modified in the document. Analysis reflects what the updated agreement states or permits. It does not constitute a legal determination about enforceability. Applicability may vary by jurisdiction. Methodology

Evidence Verification

✓ Verified
Previous Version
861a4ff62c51cea9bf574376217565fdde6462add26677f9dc90824a4e9ecff0
September 3, 2026 00:59 UTC
✓ Verified
Current Version
d360442e772de0c6c96fddc1912a1a034a19b00324ef461465249e0d86b1158a
September 5, 2026 00:55 UTC
✓ Verified
Change Detected
September 5, 2026 00:55 UTC
Analysis Methodology
✓ Verified
Source Document
https://www.deepl.com/en/privacy
Citation Record
Entity: DeepL
Document: DeepL Privacy Policy
Record ID: CA-C-004902
Captured: 2026-09-05 00:55:07 UTC
URL: https://conductatlas.com/change/2026-09-05-deepl-deepl-privacy-policy-4902/
Accessed: Sept. 5, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
For legal and compliance teams

Institutional Analysis

Assessment

DeepL's privacy policy now explicitly documents three account-level data storage and processing features with specific data handling and deletion procedures. The policy states that Translation Memory content, Translation Memory Generation uploads (deleted immediately after processing), …

🔒 Full institutional analysis

Regulatory exposure, obligation change, escalation trigger, board-ready language, and recommended action for legal and compliance teams.

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ConductAtlas provides verified policy intelligence sourced directly from platform documents. All analysis is intended to support, not replace, legal and compliance review. Record CA-C-004902.

Full Changes

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Document Context

Version history → Policy drift analysis → Document page →
Document
DeepL Privacy Policy
Entity
DeepL
Captured
September 5, 2026
Source URL
https://www.deepl.com/en/privacy
Other changes to DeepL Privacy Policy
Previous change Sep 3, 2026
DeepL's privacy policy was updated in an edit detected on September 3, 2026. The change involved removal of a single …
Low Neutral
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