DeepL · DeepL Privacy Policy · View original document ↗

Use of Translation Input for AI Model Training (Free Tier)

High severity Unique · 0 of 343 platforms
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Document Record

What it is

If you use the free DeepL translator or app, the text you submit for translation may be used by DeepL to train its AI and may be reviewed by DeepL staff or contractors. This does not apply to paid or API users.

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)

The clause establishes a data usage distinction between service tiers, whereby free tier usage generates training data for model development while paid and API users operate under different data handling terms. This creates operational incentives for service differentiation based on data contribution.

Consumer impact (what this means for users)

Free-tier users' translation inputs, including potentially sensitive personal or professional content, may be accessed by DeepL employees or third parties and incorporated into AI training datasets; the only way to prevent this is to upgrade to a paid plan.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Email privacy@deepl.com to request deletion of your personal data, including any translation inputs DeepL may have retained. Specify your account details and the scope of the deletion request.

How other platforms handle this

Google Gemini Medium

Google uses this data to provide, improve, and develop Google products, services, and machine-learning technologies, including Google's enterprise products.

OpenAI Medium

Only models with a post-mitigation score of "medium" or below can be deployed. Only models with a post-mitigation score of "high" or below can be developed further.

Hulu Medium

engage in any of the foregoing in connection with any use, creation, development, modification, prompting, fine-tuning, training, testing, benchmarking or validation of any artificial intelligence or machine learning tool, model, system, algorithm, product or other technology ("AI Tool").

See all platforms with this clause type →

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▸ View Original Clause Language DOCUMENT RECORD
"
We may use the texts you translate using the free version of our products or the DeepL App to further develop and improve our products and services. We train our AI models on this data. When doing so, we may also have translations reviewed by our employees or carefully selected third parties. This does not apply if you use the DeepL API or a paid subscription plan.

— Excerpt from DeepL's DeepL Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY FRAMEWORK: This provision implicates GDPR Art. 6(1)(f) (legitimate interests as lawful basis), Art. 5(1)(b) (purpose limitation), and Art. 9 if sensitive personal data is inadvertently submitted in translations. The lead supervisory authority is LDI NRW (Germany). UK GDPR equivalent provisions apply to UK users. CCPA §1798.100 and CPRA's expanded rights over sensitive personal information may apply to California residents whose translation inputs contain covered data categories. (2)

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has jurisdiction over unfair or deceptive data practices under FTC Act Section 5, including use of consumer-submitted content for AI training without sufficiently prominent disclosure.
    File a complaint →

Applicable regulations

EU AI Act
European Union
Colorado AI Act
US-CO
GDPR
European Union
Texas AI Act
Texas, USA

Provision details

Document information
Document
DeepL Privacy Policy
Entity
DeepL
Document last updated
May 5, 2026
Tracking information
First tracked
April 30, 2026
Last verified
April 30, 2026
Record ID
CA-P-004050
Document ID
CA-D-00448
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
1d621c54ed3a19fc9ce7b2fc58fa1eb740cb4e4b7669ebdc020370950f152344
Analysis generated
April 30, 2026 05:39 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: DeepL
Document: DeepL Privacy Policy
Record ID: CA-P-004050
Captured: 2026-04-30 05:39:12 UTC
SHA-256: 1d621c54ed3a19fc…
URL: https://conductatlas.com/platform/deepl/deepl-privacy-policy/use-of-translation-input-for-ai-model-training-free-tier/
Accessed: June 17, 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 Use of Translation Input for AI Model Training (Free Tier) clause do?

The clause establishes a data usage distinction between service tiers, whereby free tier usage generates training data for model development while paid and API users operate under different data handling terms. This creates operational incentives for service differentiation based on data contribution.

How does this clause affect you?

Free-tier users' translation inputs, including potentially sensitive personal or professional content, may be accessed by DeepL employees or third parties and incorporated into AI training datasets; the only way to prevent this is to upgrade to a paid plan.

Is ConductAtlas affiliated with DeepL?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by DeepL.