Provision record
DeepL · DeepL Privacy Policy · View original document ↗

International Data Transfers and Standard Contractual Clauses

Medium severity Medium confidence Explicit document language Common · 290 of 352 platforms
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Document Record

What it is

When DeepL sends your data to countries outside the EU that don't have equivalent privacy laws, it uses standard legal contracts (called standard contractual clauses) approved by the EU to provide a baseline level of protection.

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)

Data transfers outside the EEA carry privacy risks if the receiving country has weaker legal protections or government access to data; the adequacy of SCCs as a transfer mechanism has been the subject of significant EU regulatory scrutiny following the Schrems II ruling.

Interpretive note: The policy does not identify specific third countries or subprocessors to which data is transferred, making it difficult for users or organizations to independently assess the adequacy of protections without requesting supplementary documentation.

Recent Activity

This document changed recently

Medium Sep 5, 2026

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.

View change record →

Consumer impact (what this means for users)

EU and EEA users' personal data may be transferred to countries with different privacy standards, protected by standard contractual clauses. In practice, the actual level of protection depends on the specific third country and the subprocessors involved, and users concerned about cross-border transfers may wish to review DeepL's data processing documentation.

How other platforms handle this

Square Medium

to request that your data be transferred to a third party (data portability)

Google Cloud Medium

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.

Roblox Medium

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...

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
If we transfer personal data to countries outside the European Economic Area (EEA) that do not provide an adequate level of data protection, we ensure that appropriate safeguards are in place, such as standard contractual clauses approved by the European Commission.

Excerpt from DeepL's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision engages GDPR Chapter V governing international data transfers.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    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 9, 2026
Last verified
May 9, 2026
Record ID
CA-P-004052
Document ID
CA-D-00448
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
07120b424b50bb749364b07cb13cfa607ebe8a0b00588ea5d3a6f8f1f029b2b0
Analysis generated
May 9, 2026 16:04 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: DeepL
Document: DeepL Privacy Policy
Record ID: CA-P-004052
Captured: 2026-05-09 16:04:20 UTC
SHA-256: 07120b424b50bb74…
URL: https://conductatlas.com/platform/deepl/deepl-privacy-policy/provision/CA-P-004052/international-data-transfers-and-standard-contractual-clauses/
Accessed: Sept. 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does DeepL's International Data Transfers and Standard Contractual Clauses clause do?

Data transfers outside the EEA carry privacy risks if the receiving country has weaker legal protections or government access to data; the adequacy of SCCs as a transfer mechanism has been the subject of significant EU regulatory scrutiny following the Schrems II ruling.

How does this clause affect you?

EU and EEA users' personal data may be transferred to countries with different privacy standards, protected by standard contractual clauses. In practice, the actual level of protection depends on the specific third country and the subprocessors involved, and users concerned about cross-border transfers may wish to review DeepL's data processing documentation.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.

Is ConductAtlas affiliated with DeepL?

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