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

Pro personal data translation requires DPA

High severity Medium confidence Explicit document language Common · 298 of 352 platforms

Key Facts · in the document’s own words

Must there be a justification under data protection law?
“using DeepL Translator Pro, DeepL API Pro and DeepL Write Pro for the translation or improvement of texts containing personal data of any kind is only permitted if there is a justification for this under data protection law...our Ts&Cs provide for the conclusion of a data processing agreement”
Version CA-V-007227, captured Sept. 30, 2026 · live source ↗
Our reading, not the document’s words
DeepL permits the use of DeepL Translator Pro, DeepL API Pro, and DeepL Write Pro for translating or improving texts containing personal data only if there is a justification under data protection law and a data processing agreement has been concluded.
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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)

Users who process third-party personal data through DeepL Pro services must have both a legal basis under data protection law and a formal data processing agreement, or the use is not permitted.

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Interpretive note: The excerpt uses ellipsis, which may indicate omitted text between the two conditions. It is not entirely clear from the excerpt alone whether the data processing agreement is a separate standalone requirement or part of how data protection law justification is satisfied.

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)

If you use DeepL Pro services to translate or improve texts that contain personal data, you are required to have a legal justification under data protection law and a data processing agreement in place.

How other platforms handle this

Stripe Medium

If we rely on certain legal bases (such as "legal obligation" or "contractual necessity") and you do not provide us with your Personal Data, we may not be able to lawfully provide you services.

DoorDash Medium

By placing an order, you acknowledge and agree that, if the Merchant is responsible for the delivery of an order, the Merchant may use your Personal Information to facilitate the delivery of the order to you...

Grubhub Medium

To the extent that the rules or terms of those promotions concerning the treatment of your personal information conflict with this Privacy Policy, the rules of those promotions will control.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
using DeepL Translator Pro, DeepL API Pro and DeepL Write Pro for the translation or improvement of texts containing personal data of any kind is only permitted if there is a justification for this under data protection law...our Ts&Cs provide for the conclusion of a data processing agreement

Excerpt from DeepL's Privacy Policy

Provision details

Document information
Document
DeepL Privacy Policy
Entity
DeepL
Tracking information
First captured by ConductAtlas
April 29, 2026
Text quoted from version
CA-V-007227, captured Sept. 30, 2026
Record ID
CA-P-042624
Document ID
CA-D-000448
Evidence Provenance
Source URL
Wayback Machine
Archived bytes SHA-256 (version CA-V-007227)
a27015df2fb7402113d9e94e6d8068867ee87f875e77e528422d77257d867db4
Analysis generated
May 20, 2026 18:50 UTC
Methodology
Evidence
✓ Excerpt found verbatim in version CA-V-007227 (checked Oct. 5, 2026)
Citation Record
Entity: DeepL
Document: DeepL Privacy Policy
Record ID: CA-P-042624
Version: CA-V-007227
Captured: 2026-09-30 01:02:01 UTC
SHA-256: a27015df2fb74021…
URL: https://conductatlas.com/platform/deepl/deepl-privacy-policy/provision/CA-P-042624/pro-personal-data-translation-requires-dpa/
Accessed: Oct. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does DeepL's Pro personal data translation requires DPA clause do?

Users who process third-party personal data through DeepL Pro services must have both a legal basis under data protection law and a formal data processing agreement, or the use is not permitted.

How does this clause affect you?

If you use DeepL Pro services to translate or improve texts that contain personal data, you are required to have a legal justification under data protection law and a data processing agreement in place.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 298 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.