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Free-Tier Translation Input Used for AI Model Training

High severity High confidence Explicitdocumentlanguage Unique · 0 of 343 platforms
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Document Record

What it is

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

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.

Change history

modified May 22, 2026

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 →

Consumer impact (what this means for users)

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.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Cancel Subscription
    To avoid free-tier training data use, upgrade to a DeepL Pro paid subscription at deepl.com/en/pro, which the policy states excludes translation inputs from training use and deletes them after translation.

How other platforms handle this

Strava Medium

We use information to enhance the quality, reliability, and/or accuracy of our AI Features by creating, developing, training, testing, improving, and maintaining AI and ML models run by Strava or our service providers. We use aggregated, de-identified data for this purpose. We also use personal info...

Ledger Medium

At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.

Garmin Medium

If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...

See all platforms with this clause type →

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▸ View Original Clause Language DOCUMENT RECORD
"
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

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

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.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has jurisdiction over unfair or deceptive data practices affecting US consumers, including disclosures about how consumer-submitted content is used for AI training purposes.
    File a complaint →

Applicable regulations

EU AI Act
European Union
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
DeepL Privacy Policy
Entity
DeepL
Document last updated
May 5, 2026
Tracking information
First tracked
May 20, 2026
Last verified
May 20, 2026
Record ID
CA-P-007201
Document ID
CA-D-00448
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
f487db6bc52a774426e9a5a9985429409c493cc7fa7aa2abe357b0f97b7569b8
Analysis generated
May 20, 2026 18:50 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: DeepL
Document: DeepL Privacy Policy
Record ID: CA-P-007201
Captured: 2026-05-20 18:50:51 UTC
SHA-256: f487db6bc52a7744…
URL: https://conductatlas.com/platform/deepl/deepl-privacy-policy/free-tier-translation-input-used-for-ai-model-training/
Accessed: June 28, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

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Frequently Asked Questions

What does DeepL's Free-Tier Translation Input Used for AI Model Training clause do?

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.

How does this clause affect you?

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.

Is ConductAtlas affiliated with DeepL?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by DeepL.