The agreement states that content submitted by DeepL Pro subscribers is not used to train DeepL's AI models and is processed only to deliver the requested translation or service output.
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 directly addresses AI training data practices for paid subscribers, establishing that submitted content is excluded from model training use. This distinction is operationally significant for organizations submitting confidential, proprietary, or personally identifiable content through the service.
Interpretive note: The exact scope of 'content submitted for translation or other processing' and whether derived metadata, anonymized outputs, or usage analytics fall within the no-training commitment is not fully specified in the provision as extracted; the separate Privacy Policy may contain additional detail.
Broadened scope from 'texts' and 'AI systems' to 'content' and 'AI models' and expanded from 'translation' to 'translation or other processing' to cover expanded service offerings.
View full change record →Under this clause, content submitted through DeepL Pro paid accounts is processed only to deliver the requested service and is not used for AI model training purposes as the agreement states. This provision addresses a key data use concern for organizations handling sensitive or regulated content.
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"DeepL does not use the content you submit for translation or other processing through DeepL Pro to train its AI models. The content you submit is processed solely to provide the requested service.— Excerpt from DeepL's DeepL Terms and Conditions
(1) REGULATORY LANDSCAPE: This provision engages GDPR Article 5 (purpose limitation) and Article 6 (lawful basis for processing) by asserting that content submitted by paid users is processed only for service delivery. For organizations submitting personal data through the translation service, this purpose limitation representation is a material element of the data processing relationship. The EU AI Act's provisions on training data and transparency for AI systems may also be relevant to this disclosure. DeepL's role as a data processor (for personal data in submitted content) or data controller depends on the specific processing context and is addressed in the separate Privacy Policy and Data Processing Agreement referenced in the terms. (2) GOVERNANCE EXPOSURE: Low for standard DeepL Pro use, given the explicit exclusion of Pro content from AI training. However, organizations submitting special category personal data (health, legal, financial information) through the service should verify that the Data Processing Agreement and Privacy Policy adequately address GDPR obligations for that content type. (3) JURISDICTION FLAGS: EU/EEA organizations and those subject to GDPR (including UK GDPR) should ensure a Data Processing Agreement is in place with DeepL as required by GDPR Article 28 for processor relationships. Healthcare or financial services organizations may have additional sector-specific requirements around data processing by third-party AI services. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise procurement and legal teams should confirm that the Data Processing Agreement referenced in the terms is executed and that its provisions are consistent with their own data protection obligations. The no-training-use representation should be evaluated as a contractual commitment and assessed for audit or verification mechanisms. (5) COMPLIANCE CONSIDERATIONS: Organizations should map the categories of personal data submitted through DeepL Pro, confirm these are covered by an executed DPA, and assess whether any special category data processing triggers additional GDPR obligations or requires a Data Protection Impact Assessment.
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This provision directly addresses AI training data practices for paid subscribers, establishing that submitted content is excluded from model training use. This distinction is operationally significant for organizations submitting confidential, proprietary, or personally identifiable content through the service.
Under this clause, content submitted through DeepL Pro paid accounts is processed only to deliver the requested service and is not used for AI model training purposes as the agreement states. This provision addresses a key data use concern for organizations handling sensitive or regulated content.
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