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
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.
This standalone provision was removed and merged into the revised 'Cross-Border Data Transfers' provision with substantively different framing.
View full change record →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.
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Your personal information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.
Your personal information may be transferred to, stored, and processed in the United States or other countries outside of your country of residence, which may have data protection laws that are different from those in your country.
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"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 DeepL Privacy Policy
(1) REGULATORY LANDSCAPE: This provision engages GDPR Chapter V governing international data transfers. Post-Schrems II (CJEU Case C-311/18), SCCs remain a valid transfer mechanism but require a Transfer Impact Assessment (TIA) to verify that the destination country's laws do not undermine the SCCs' protections. The European Data Protection Board has issued guidance on TIA requirements. The relevant enforcement authority is the lead supervisory authority for DeepL (German LfDI or BfDI) and national authorities of affected data subjects. (2) GOVERNANCE EXPOSURE: Medium. The policy's reference to SCCs is a standard disclosure, but organizations using DeepL as a processor must ensure their DPA reflects current SCC templates (post-June 2021 European Commission update) and that DeepL has conducted or provided TIAs for relevant transfer destinations. Failure to document adequate transfer mechanisms creates GDPR Chapter V compliance exposure. (3) JURISDICTION FLAGS: EU/EEA users and organizations subject to GDPR face the highest exposure. UK organizations must comply with UK GDPR's separate international transfer framework (International Data Transfer Agreements). Swiss users may also be subject to the revised Swiss Federal Act on Data Protection. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers should request documentation of DeepL's subprocessor list and the specific transfer mechanisms in place for each subprocessor. DPAs should identify which third countries data may be transferred to and confirm that updated SCC modules are in place. Customers should request TIA documentation where transfers involve countries without EU adequacy decisions. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should include DeepL in their records of processing activities and document the transfer mechanism. Where DeepL uses US-based subprocessors, organizations should assess whether the EU-US Data Privacy Framework adequacy decision applies and whether DeepL or its subprocessors are certified participants.
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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.
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.
ConductAtlas has identified this type of provision across 4 platforms. See the full comparison.
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