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

Pro personal data translation requires DPA

Medium confidence Common · 290 of 343 platforms
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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)

Generated by a model from the captured document; not read by a person

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 16, 2026

The updated policy discloses how DeepL Voice processes audio data during real-time translation. Audio, transcripts, and translations are deleted after use unless your organization sets a retention period (ranging from 20 seconds to 30 days). The policy also discloses that DeepL processes voice characteristics for speaker matching (up to 30 seconds per session) and may process tone and speaking style if voice matching is enabled. For languages without DeepL's own voice model, the policy now discloses that ElevenLabs processes backup voice data on DeepL's instructions. You can update voice matching settings at any time, and guests can opt out of voice matching or switch to pre-set voices on a per-meeting basis.

View change record →

Consumer impact (what this means for users)

Generated by a model from the captured document; not read by a person

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

Kling AI

You may be required to provide certain categories of Data to us under the following circumstances: (i) as required under any applicable laws or regulations; (ii) as required under any contract entered into between us...

OpenAI

These Terms contain the entire agreement between you and OpenAI regarding the Services and, other than any Service-specific terms, supersedes any prior or contemporaneous agreements between you and OpenAI.

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 in version CA-V-007227, captured Sept. 30, 2026 (checked Oct. 5, 2026)
Not the current version. The document's current version is CA-V-007475, captured Oct. 10, 2026; this clause has not been re-checked against it.
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. 23, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Categories

Other risks in this policy

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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 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.