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

Sub-Processor and Third-Party Data Sharing

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

What it is

The policy discloses that DeepL shares personal data with third-party service providers including cloud infrastructure, payment processors, customer support vendors, and analytics providers, and states that data processing agreements are in place with these providers.

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 authorizes the transfer of user personal data to multiple categories of third-party processors and asserts that GDPR-compliant data processing agreements govern these transfers. Compliance teams should verify the adequacy of these agreements and the completeness of the sub-processor list, particularly for organizations with strict data residency or sub-processor approval requirements.

Interpretive note: The policy asserts data processing agreements are in place but does not enumerate specific sub-processors within the policy text, making independent verification of scope and adequacy uncertain without requesting the full sub-processor list from DeepL.

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)

Under this clause, personal data including account information, usage data, and payment details may be shared with cloud, analytics, payment, and customer support sub-processors. The agreement states that data processing agreements are in place, but does not enumerate all sub-processors directly within the privacy policy text.

How other platforms handle this

Glassdoor Medium

We will also provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected.

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.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
We use third party service providers to support our services. These include providers of cloud infrastructure, payment processing, customer support, and analytics services. Where these providers process personal data on our behalf, we have entered into data processing agreements with them to ensure that your personal data is protected in accordance with applicable data protection law.

Excerpt from DeepL's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: This provision implicates GDPR Article 28, which requires written data processing agreements with all processors and mandates that processors only act on documented instructions.

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 20, 2026
Last verified
May 20, 2026
Record ID
CA-P-004498
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-004498
Captured: 2026-05-20 18:50:51 UTC
SHA-256: f487db6bc52a7744…
URL: https://conductatlas.com/platform/deepl/deepl-privacy-policy/provision/CA-P-004498/sub-processor-and-third-party-data-sharing/
Accessed: Sept. 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does DeepL's Sub-Processor and Third-Party Data Sharing clause do?

This provision authorizes the transfer of user personal data to multiple categories of third-party processors and asserts that GDPR-compliant data processing agreements govern these transfers. Compliance teams should verify the adequacy of these agreements and the completeness of the sub-processor list, particularly for organizations with strict data residency or sub-processor approval requirements.

How does this clause affect you?

Under this clause, personal data including account information, usage data, and payment details may be shared with cloud, analytics, payment, and customer support sub-processors. The agreement states that data processing agreements are in place, but does not enumerate all sub-processors directly within the privacy policy text.

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.