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
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.
Added 'customer support' as a category of service providers and changed from 'bound by' to 'entered into' language; added reference to 'applicable data protection law' for broader legal compliance.
View full change record →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.
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"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 DeepL Privacy Policy
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. GDPR Article 46 governs transfers to processors outside the EEA and requires appropriate safeguards such as Standard Contractual Clauses. UK GDPR imposes parallel requirements for UK user data. 2) GOVERNANCE EXPOSURE: Medium. The policy asserts that data processing agreements are in place but does not provide a publicly enumerated sub-processor list within the policy text itself. Organizations with contractual obligations to approve sub-processors or restrict data to specific geographies will need to request the full sub-processor list from DeepL directly. 3) JURISDICTION FLAGS: EU/EEA and UK users are subject to the most rigorous sub-processor disclosure requirements under GDPR and UK GDPR respectively. California users may have CCPA rights to know the categories of third parties with whom their data is shared. Cross-border transfers to non-EEA processors (e.g., US-based cloud or analytics vendors) require documented transfer mechanism adequacy. 4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise procurement teams should request DeepL's full sub-processor list and confirm that SCCs or equivalent transfer mechanisms are in place for non-EEA processors. Vendor assessment workflows should include review of DeepL's DPA terms. Organizations with contractual obligations to clients regarding sub-processor approval should assess whether DeepL's DPA terms support those obligations. 5) COMPLIANCE CONSIDERATIONS: Data mapping updates should reflect sub-processor categories disclosed in this policy. DPA review should confirm that processor obligations, audit rights, and breach notification timelines align with the contracting organization's own regulatory obligations. Organizations in regulated industries should assess whether any sub-processors are subject to sector-specific restrictions.
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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.
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.
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