The policy states that personal data is retained for as long as necessary to provide services and meet legal obligations, and that account closure triggers deletion within a reasonable period subject to legal retention requirements.
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 establishes retention duration in general terms without specifying category-by-category retention periods, which may limit users' ability to assess how long specific data types are held. The reference to legal retention requirements means some data may be retained after account closure.
Interpretive note: The policy does not specify retention periods by data category or processing purpose, which limits verification of compliance with GDPR storage limitation requirements without additional documentation.
Establishes a data retention policy with explicit deletion upon account closure, clarifying user data lifecycle and deletion timelines.
View full change record →Under this clause, personal data is retained for the duration of service use and for an unspecified period following account closure, subject to legal obligations that may require continued retention of certain data categories. The policy does not specify retention periods by data type or processing purpose.
How other platforms handle this
We retain personal information for as long as necessary to provide our services, comply with legal obligations, resolve disputes, and enforce our agreements. The specific retention periods depend on the type of information and the purposes for which it is processed.
We keep information for as long as we need it to provide our products, comply with legal obligations, or for other legitimate purposes, such as to maintain safety, security, and integrity.
After your account is deleted, we keep data about interactions you've had on our service to prevent abuse, ban evaders and others in an effort to protect and ensure the safety and security of our service and our members.
Monitoring
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"We retain your personal data for as long as necessary to provide you with our services and to comply with our legal obligations. When you close your account, we will delete your personal data within a reasonable period, subject to any legal retention requirements.— Excerpt from DeepL's DeepL Privacy Policy
1) REGULATORY LANDSCAPE: GDPR Article 5(1)(e) requires that personal data be kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which it is processed (storage limitation principle). The absence of specific retention periods by data category may create compliance tension with GDPR's storage limitation and accountability requirements. UK GDPR imposes parallel obligations. 2) GOVERNANCE EXPOSURE: Medium. The use of 'reasonable period' without defined timeframes may be insufficient to demonstrate compliance with GDPR's storage limitation principle. Data Protection Authorities have indicated that vague retention language may not satisfy accountability requirements under GDPR Article 5(2). 3) JURISDICTION FLAGS: EU/EEA users are subject to GDPR storage limitation requirements. UK users fall under UK GDPR. California users have CCPA deletion rights that may be exercised regardless of DeepL's stated retention schedule. Sector-specific retention obligations (financial records, VAT records) may justify extended retention of transaction data in certain jurisdictions. 4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers with contractual data minimization or retention commitments should confirm that DeepL's retention practices are compatible with those commitments. DPA terms should include specific retention schedules or a commitment to provide them upon request. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should request documentation of DeepL's data retention schedules by data category and processing purpose. Records of processing activities should reflect specific retention periods rather than general language. Organizations using DeepL to process third-party personal data should assess whether their own retention obligations are satisfied by DeepL's practices.
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This provision establishes retention duration in general terms without specifying category-by-category retention periods, which may limit users' ability to assess how long specific data types are held. The reference to legal retention requirements means some data may be retained after account closure.
Under this clause, personal data is retained for the duration of service use and for an unspecified period following account closure, subject to legal obligations that may require continued retention of certain data categories. The policy does not specify retention periods by data type or processing purpose.
ConductAtlas has identified this type of provision across 2 platforms. See the full comparison.
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