Section 9 states that the license does not provide a legal basis for processing personal information contained in the model, and places full compliance responsibility and risk assumption on the licensee as an independent data processor.
This analysis describes what DeepSeek'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 requires each licensee to independently establish a lawful basis for any personal data processing associated with model use or deployment, which may trigger data protection impact assessment obligations and controller-level compliance duties under GDPR, CCPA, and equivalent frameworks.
Under this clause, any organization or individual deploying the model is solely responsible for ensuring their data processing activities comply with applicable law, including identifying a lawful processing basis. The agreement explicitly states that the license itself does not supply that basis.
Cross-platform context
See how other platforms handle Personal Data and IP Compliance Sole Responsibility and similar clauses.
Compare across platforms →"This Model may contain personal information and works with IP rights. You commit to complying with applicable laws and regulations in the handling of personal information and the use of such works. Please note that DeepSeek's license granted to you to use the Model does not imply that you have obtained a legitimate basis for processing the related information or works. As an independent personal information processor and IP rights user, you need to ensure full compliance with relevant legal and regulatory requirements when handling personal information and works with IP rights that may be contained in the Model, and are willing to assume solely any risks and consequences that may arise from that.Excerpt from DeepSeek's Open Source License
(1) REGULATORY LANDSCAPE: This provision directly engages GDPR (lawful basis for processing, controller obligations, and data protection impact assessment requirements), CCPA (consumer data rights and disclosure obligations), and the PRC Personal Information Protection Law.
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This provision requires each licensee to independently establish a lawful basis for any personal data processing associated with model use or deployment, which may trigger data protection impact assessment obligations and controller-level compliance duties under GDPR, CCPA, and equivalent frameworks.
Under this clause, any organization or individual deploying the model is solely responsible for ensuring their data processing activities comply with applicable law, including identifying a lawful processing basis. The agreement explicitly states that the license itself does not supply that basis.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by DeepSeek.