The policy states that translation inputs submitted by free-tier users may be used to train and improve DeepL's AI systems, while paid subscribers' inputs are deleted after translation and not used for training.
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 a material operational distinction between free and paid service tiers with respect to how submitted text and document content is processed beyond the immediate translation request. Organizations and individuals transmitting sensitive, confidential, or proprietary content through the free service tier should be aware that the policy authorizes this training use.
Severity increased from medium to high; expanded to explicitly state paid version protections and changed language from 'store' to 'may be used' while adding specific deletion guarantee for paid tiers.
View full change record →Under this provision, translation inputs submitted via the free DeepL service may be retained and processed to improve DeepL's machine learning models. The agreement states that paid DeepL Pro users are not subject to this training use and have their inputs deleted post-translation.
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"If you use the free version of our services, the text and documents you submit for translation may be used by DeepL to improve our translation systems. If you use the paid version of our services (DeepL Pro), the text and documents you submit for translation will not be used to improve our translation systems and will be deleted after the translation is complete.— Excerpt from DeepL's DeepL Privacy Policy
1) REGULATORY LANDSCAPE: This provision implicates GDPR Articles 5, 6, and 13, which require that the legal basis for processing and the purposes of processing be clearly disclosed to data subjects. Where free-tier users inadvertently submit special category data (health, legal, financial), Article 9 GDPR may require explicit consent. The relevant enforcement authority is the German LfDI or BfDI; UK ICO jurisdiction applies for UK users. 2) GOVERNANCE EXPOSURE: High. The policy does not explicitly state the GDPR legal basis (consent, legitimate interest, or contractual necessity) relied upon for using free-tier inputs for training. This ambiguity may create compliance exposure under GDPR transparency and lawfulness requirements, particularly if special category data is incidentally included in submitted content. 3) JURISDICTION FLAGS: EU/EEA users are subject to GDPR requirements for lawful processing disclosure. UK users fall under UK GDPR with similar requirements. California users may have CCPA rights to know and delete personal information used in this context. Organizations subject to legal professional privilege, HIPAA, or financial confidentiality obligations face heightened exposure if sensitive content is submitted via the free tier. 4) CONTRACT AND VENDOR IMPLICATIONS: Procurement teams evaluating DeepL for enterprise use must confirm that the contracted tier is paid or API-level to ensure training-data exclusion applies. B2B contracts should specify the applicable service tier and reference the data handling commitments associated with that tier. Organizations processing client data should assess whether use of the free tier is consistent with their own privacy obligations and client agreements. 5) COMPLIANCE CONSIDERATIONS: Legal and compliance teams should map content sensitivity against service tier usage. Consent mechanism audits may be warranted to determine whether free-tier users are adequately informed of training use at the point of data submission. Data protection impact assessments may be appropriate where bulk or sensitive content is processed via the free tier.
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This provision establishes a material operational distinction between free and paid service tiers with respect to how submitted text and document content is processed beyond the immediate translation request. Organizations and individuals transmitting sensitive, confidential, or proprietary content through the free service tier should be aware that the policy authorizes this training use.
Under this provision, translation inputs submitted via the free DeepL service may be retained and processed to improve DeepL's machine learning models. The agreement states that paid DeepL Pro users are not subject to this training use and have their inputs deleted post-translation.
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