The policy states that personal data may be transferred outside the EEA to third-party service providers, and asserts that appropriate safeguards such as Standard Contractual Clauses are used to govern these transfers.
This analysis describes what DeepL's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision discloses that EEA user data may be routed to non-EEA processors, with Standard Contractual Clauses cited as the primary safeguard mechanism. Organizations subject to strict data residency requirements or sector-specific cross-border transfer restrictions should evaluate whether this transfer framework satisfies their obligations.
Interpretive note: The policy does not enumerate specific recipient countries or processors involved in cross-border transfers, making it difficult to assess the adequacy of safeguards for specific transfer routes without additional documentation from DeepL.
Reframed to focus on service providers based outside EEA rather than conditional transfers, broadening the scope of disclosed data transfers.
View full change record →Under this clause, personal data of EU/EEA users may be transferred to processors outside the EEA. The policy asserts that Standard Contractual Clauses or equivalent mechanisms are in place to protect such data, though the specific recipient countries and processors involved in cross-border transfers are not enumerated in the policy text.
How other platforms handle this
to request that your data be transferred to a third party (data portability)
Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.
Further, you may take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data prot...
"Some of our service providers are based outside the European Economic Area (EEA). Where we transfer personal data outside the EEA, we ensure that appropriate safeguards are in place, for example by using standard contractual clauses approved by the European Commission.Excerpt from DeepL's Privacy Policy
1) REGULATORY LANDSCAPE: This provision implicates GDPR Chapter V (Articles 44-49), which governs international data transfers and requires that transfers to third countries be subject to an adequacy decision or appropriate safeguards such as Standard …
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This provision discloses that EEA user data may be routed to non-EEA processors, with Standard Contractual Clauses cited as the primary safeguard mechanism. Organizations subject to strict data residency requirements or sector-specific cross-border transfer restrictions should evaluate whether this transfer framework satisfies their obligations.
Under this clause, personal data of EU/EEA users may be transferred to processors outside the EEA. The policy asserts that Standard Contractual Clauses or equivalent mechanisms are in place to protect such data, though the specific recipient countries and processors involved in cross-border transfers are not enumerated in the policy text.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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