Privacy Policy

ARCHIVED 2021-04-24, DATE APPROXIMATE · VERSION 20210424_rev01 · COMPARED WITH 20210223_rev01

Full text changes — 20210223_rev01 to 20210424_rev01

COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED

 - Necessary: These cookies or web storage objects are necessary for our website to work properly, for you to be able to navigate smoothly, and for you to be able to use the most important functions. This includes security features, features that allow easy access, and settings such as the display language of the website and the translation language. We use these cookies or web storage objects on account of our legitimate interest in the presentation of our services and our company as a whole. Processing is based on Art. 6 para. 1 sentence 1 lit. f) GDPR.
 - Performance: In order to continuously improve our website, we collect data for statistical and analytical purposes. We use these cookies or web storage objects to measure, for example, how often users return, and which features they use. In accordance with Art. 6 para 1 sentence 1 lit. a) GDPR, we only use these cookies or web storage objects with your explicit consent.
 - Comfort: We use these cookies or web storage objects to make using our website more comfortable for you. For example, we remember which areas of the website you have already visited and help you to use the website in the best possible way. In accordance with Art. 6 para 1 sentence 1 lit. a) GDPR, we only use these cookies or web storage objects with your explicit consent.
 The following table lists the different types of cookies and web storage objects that may be used on our website. Our cookies or web storage objects are stored in your browser until they are deleted or, if it is a session cookie, until the session has expired. You can withdraw your consent for the use of cookies or web storage objects in the categories "Performance" and "Comfort" in each of these categories directly.
+With the exception of the third-party cookies from our payment service provider Stripe (see explanatory notes, section 10) and the marketing software from HubSpot (see explanatory notes, section 12) the information generated by cookies and web storage objects, relating to the use of this website, is transmitted to our servers within the EU; this is the only place it is stored. This information is not disclosed to third parties.
+With the exception of the third-party cookies from our payment service provider Stripe (see explanatory notes, section 10), the customer support software from Zendesk (see explanatory notes, section 11) and the marketing software from HubSpot (see explanatory notes, section 12) the information generated by cookies and web storage objects, relating to the use of this website, is transmitted to our servers within the EU; this is the only place it is stored. This information is not disclosed to third parties.
+The cookies set with the help of Zendesk are cookies that are technically necessary to ensure the functionality and security of the FAQ-section of our website and to protect the website from bot-controlled attacks. The data processing therefore corresponds to our legitimate interest, Art. 6 para. 1 sentence 1 lit. f) GDPR.
 Overview of the cookies and web storage objects used by DeepL:
 ### Necessary
 | Context | ID | Description | Technology | Expiry | Owner |
 | --- | --- | --- | --- | --- | --- |
 | DeepL Pro-User Login/Session | IDdl\_logoutReason | DescriptionWhen you get logged out accidentally, we will help you with an error message. We use this cookie to deliver this message to you so you can prevent this problem in the future. | TechnologyCookie | ExpirySession | OwnerDeepL |
 | DeepL Pro-User Login/Session | IDep | DescriptionIp-Based Enterprise Account login token. Checked once per session and deleted afterwards. | TechnologyLocal Storage | ExpirySession | OwnerDeepL |
 | DeepL Pro-User Login/Session | IDuser | DescriptionStores the display name of logged-in users to display their name. Deleted if the user logs out. | TechnologyLocal Storage | Expiry7 days | OwnerDeepL |
 | Release process | IDreleaseGroups | DescriptionUsed for gradual, controlled releases to ensure stability, quality and performance of our service and infrastructure. | TechnologyCookie | Expiry1 month | OwnerDeepL |
 | Session ID | IDdapSid | DescriptionSession ID and timestamp. Automatically deleted after 30 minutes of inactivity. | TechnologyCookie | ExpirySession | OwnerDeepL |
 | App Usage Statistics - only for DeepL Apps | IDappUsageStats | DescriptionRemembers when the user last used the app. | TechnologyLocal Storage | ExpiryPersistent Data | OwnerDeepL |
+| Document translation | IDLMT\_doctranslate\_client | DescriptionUsed to bind an ongoing document translation process to a user and protect the document translation feature from excessive use by individual users. This ensures that the service is not impacted for the remaining users. | TechnologyCookie | Expiry1 month | OwnerDeepL |
 ### Performance
 | Context | ID | Description | Technology | Expiry | Owner |
 | --- | --- | --- | --- | --- | --- |
 | User Tracking | IDuid | DescriptionFirst-party user identifier. | TechnologyLocal Storage | Expiry12 months | OwnerDeepL |
 - Diagnostic information in event of errors.
 The processing of this data is based on our legitimate interest in improving the stability and functionality of our website, Art. 6 para. 1 sentence 1 lit. f) GDPR. This data is stored solely for technical reasons and is not linked to a specific person. Data relating to access is used for error analysis, ensuring system security, logging access to paid services (e.g. DeepL Pro), and to improve our translation service. Due to a legitimate interest in achieving the listed purposes, the full IP address will be stored for a short period of time, not exceeding 14 days.
 Your texts will be sent to DeepL for translation. This, however, only takes place when you explicitly request a translation in the App. This data is processed for the purpose of fulfilling the contract pursuant to Art. 6 para. 1 sentence 1 lit. b) GDPR.
+## 9\. Registering with DeepL
+## 9\. DeepL Free API
+In addition to the paid DeepL Pro API, we also offer a limited free version of our API (DeepL Free API). For further information, please see our [DeepL Pro Terms and Conditions](https://deepl.com/pro-license/) and section 3 (see above) on using the free version of DeepL.
+In order to use the DeepL Free API, it is necessary to register with DeepL and create an account. For this purpose, your data will be processed in accordance with section 10, i.e., your e-mail address, the password you chose, and your IP address will be stored.
+If you book the Free API option during the checkout process, further data, as specified in section 10, will be collected. Although no costs are incurred when using the DeepL Free API - subject to a (possible) upgrade - your payment data is collected in order to prevent improper use of the Free API. Solely for this purpose, payment information is also passed on, in accordance with section 10., to the payment service provider we have commissioned, Stripe Payments Europe Ltd.
+We process the data mentioned in sections 10. as part of the initiation or fulfillment of the free-of-charge usage contract concluded between you and us on the basis of Art. 6 para. 1 sentence 1 lit. b) GDPR. If no order is placed following registration, we will store your data for one month and then delete it.
+## 10\. Registering with DeepL
 You have the possibility to register with DeepL. In order to ensure that you can log in, the following personal data will be stored:
 - E-mail address
 - Password
 - IP address
 - Payment details
 We process this data in order to initiate or fulfil a contract pursuant to Art. 6 para. 1 sentence 1 lit. b) GDPR.
 If, following registration, no order is placed, we will store your data for one month, following which it will be deleted. If an order is placed, we will store the data for the duration of the contract period and subsequently, if necessary, for the duration of any statutory retention periods.
+## 10\. Processing of Payments for DeepL Pro Subscriptions
+## 11\. Processing of Payments for DeepL Pro Subscriptions
 When signing up for a DeepL Pro subscription, the following personal information is stored and processed for the purposes of billing and contract fulfilment:
 - E-mail address
 - First name, surname, and company name
 - Address
 - Additional information you may provide during the registration process
 In order to process payments, we forward the necessary payment data to our authorized payment service provider: Stripe Payments Europe Ltd, Block 4, Harcourt Centre, Harcourt Road, Dublin 2, Ireland. Where necessary, Stripe will also transfer the data to Stripe, Inc. in the USA. Further information on Stripe's data protection and compliance with the requirements of Art. 44 GDPR (particularly after the EU-US Privacy Shield has been declared invalid) can be found [here](https://stripe.com/de/privacy). We have concluded a data processing agreement with Stripe, which allows Stripe to only process the data in accordance with our instructions and not for its own purposes.
 We process this data for the purpose of contract fulfilment pursuant to Art. 6 para. 1 sentence 1 lit. b) GDPR. The data will be stored for the duration of the contract period and subsequently, if necessary, for the duration of any statutory retention periods.
+## 11\. Contact with our Sales or Support Team
+## 12\. Contact with our Sales or Support Team
 We offer you the possibility to contact our sales or support team via a form provided on the website or by e-mail. A valid e-mail address and your name are required so that we know who the enquiry comes from and can respond to it. Your telephone number and the company name can be provided voluntarily.
+If your enquiry is aimed at the conclusion of a contract, Art. 6 para. 1 sentence 1 lit. b) DSGVO serves as the legal basis. In this case we will store your data for the duration of the statutory retention periods. If you contact us for other purposes, the data will be processed in accordance with Art. 6 para. 1 sentence 1 lit. a) DSGVO on the basis of your voluntarily given consent. We store the data for the duration of the statutory retention periods.
+We offer you the possibility to contact our Sales or Support team via a form provided on the website or by e-mail. A valid e-mail address and your name are required so that we know who the enquiry comes from and can respond to it. Your telephone number and the company name can be provided voluntarily.
+If you have contacted our support team via the contact form, it is possible that we will subsequently inquire by e-mail about your satisfaction with our customer service. In this case, we process your data on the basis of our legitimate interests in accordance with Art. 6 para. 1 sentence 1 lit. f) DSGVO in order to determine the satisfaction of our customers and to continuously improve our service.
+If your request is related to the conclusion of a contract with us or concerns questions about the implementation of your contract (in particular, Support requests), Art. 6 para. 1 sentence 1 lit. b) GDPR serves as the legal basis for the processing of your personal data, including any subsequent correspondence. Art. 6 para. 1 sentence 1 GDPR also provides justification for the processing of personal data that may be contained in documents sent to our Support team. We will store your data for the duration of our business relationship and subsequently for the duration of the legal retention periods. If you have contacted our Support team via the contact form, it is possible that we will subsequently inquire by e-mail about your satisfaction with our customer service. In this case, we will process your data on the basis of our legitimate interests in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR in order to determine customer satisfaction and to continuously improve our service.
+We use the ticket system of the provider Zendesk Inc. for the processing of your enquiries and the satisfaction survey. ("Zendesk"), 1019 Market Street, San Francisco, CA 94103, USA. This may also involve the transfer of your data to the USA. We have entered into an agreement with Zendesk for the processing of orders and Zendesk may therefore only process the data in accordance with our instructions and not for its own purposes. For further information on how Zendesk handles personal data and how Zendesk complies with the requirements of Art. 44 of the Data Protection Act (especially after the EU-U.S. Privacy Shield has been removed), please click [here](https://www.zendesk.com/company/customers-partners/privacy-policy/).
+We use the ticket system of the provider Zendesk Inc. for the processing of your enquiries and the satisfaction survey. ("Zendesk"), 1019 Market Street, San Francisco, CA 94103, USA. This may also involve the transfer of your data to the USA. We have entered into a data processing agreement with Zendesk and Zendesk may therefore only process the data in accordance with our instructions and not for its own purposes. For further information on how Zendesk handles personal data and how Zendesk complies with the requirements of Art. 44 GDPR (particularly after the EU-U.S. Privacy Shield has been declared invalid), please click [here](https://www.zendesk.com/company/privacy-and-data-protection/) and [here](https://www.zendesk.com/blog/update-privacy-shield-invalidation-european-court-justice/).
+## 12\. E-mail Marketing
+## 13\. E-mail Marketing
 We process your data, provided that you have given your consent to do so, in accordance with Art. 6 para. 1 sentence 1 lit. a) GDPR. We have concluded a data processing agreement with HubSpot and therefore HubSpot may only process the data under our instructions and not for its own purposes. For more information on how personal data is handled at HubSpot and how HubSpot complies with the requirements of Art. 44 GDPR (particularly after the EU-US Privacy Shield has been declared invalid), please click [here](https://legal.hubspot.com/product-privacy-policy).
 Under the legal requirements of section 7 para. 3 UWG (German Act against Unfair Competition), we are authorized to use the e-mail address you provided when signing up for a DeepL Pro subscription for direct advertising for our own similar goods or services. In such cases, we process your data on the basis of our legitimate interests in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR.
 If you do not wish us to send you such recommendations by e-mail, you can object to the use of your address for this purpose at any time, without incurring any costs other than the transmission costs specified in the basic tariffs. A message in text form is sufficient for this purpose. Each e-mail will of course always contain an unsubscribe link.
+## 13\. Job Applications
+## 14\. Job Applications
 We offer you the opportunity to apply for a position at DeepL via our career page, the integrated career portal, or by e-mail. This digital recruitment process means that in order complete the application procedure, your application data is collected and processed electronically. The personal data you provide will be used exclusively for processing your job application. Your personal data will only be passed on or otherwise transferred to persons involved in the recruitment process.
 If, following the recruitment process, an employment contract is concluded, we will store your personal data as part of your personnel file for the purpose of standard organizational and administrative procedures, in compliance with the more extensive legal obligations.
 In the event that we reject an application, we will automatically delete the data transmitted to us six months after notification of rejection. The data will not be deleted, however, if legal regulations require that the data is stored for a longer period.
 Your applicant data is processed in accordance with Art. 88 para. 1 GDPR in conjunction with section https://legal.hubspot.com/product-privacy-policy 26 para. 1, 8 p. 2 BDSG.
 If you expressly agree to a longer storage of your data, e.g. for your inclusion in our internal applicant pool, the data will be further processed based on your consent. The legal basis in this case is Art. 6 para. 1 p. 1 lit a) GDPR. You can, of course, let us know that you would like to revoke your consent at any time, with effect for the future.
 In order to process the applicant and application data, your data will be forwarded to the service provider Recruitee B.V., Keizersgracht 313, 1016 EE Amsterdam, The Netherlands, which operates the application system. Further information on data protection at Recruitee can be found [here](https://recruitee.com/en/privacy). We have concluded a data processing agreement with Recruitee, which means that Recruitee may only process the data in accordance with our instructions and not for its own purposes.
+## 14\. Data Security
+## 15\. Data Security
 Your connections to our website are protected with encryption techniques in line with the current state of the art. The level of protection also depends on which encryption your Internet browser supports. You can tell whether an individual page of our website is transmitted in encrypted form by looking at the closed key or lock symbol in the status bar of your browser. We also use suitable technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.
+## 15\. Your Rights
+## 16\. Your Rights
 The following rights are granted by European Union directives and regulations. If you wish to exercise any of the rights listed below, please contact us at the above address.
 - Right to confirmation and right of access - We will gladly confirm whether we are processing any of your personal data, which data we are processing, and for what purpose we are processing it.
 - Right to rectification - If any of the data we have stored is incorrect, we would certainly be happy to correct it.
 - Right to erasure - Should you wish your personal data to be deleted, we will comply with your request as far as legally possible. If data must be stored for legal reasons, it will be blocked. The data is then no longer available for further use.
 - Right to object - If your personal data is being processed on the basis of legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f) GDPR, you have the right to object to the processing of your personal data if there are reasons for doing so arising from your particular situation or if the objection is directed against direct marketing, pursuant to Art. 21 GDPR. If the latter is the case, you have the general right to object, which we will implement without any further specification of a specific situation.
 You also have the right to lodge a complaint regarding the processing of your personal data with a supervisory authority, such as the data protection supervisory authority responsible for us:
 Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen, Kavalleriestraße 2 - 4, 40213 Düsseldorf, E-Mail: poststelle@ldi.nrw.de.
+## 16\. Changes to the privacy policy
+## 17\. Changes to the privacy policy
 We reserve the right to amend this privacy policy. The current version of the privacy policy can be accessed at any time on our [website](https://deepl.com/privacy.html).
+Last update: February 2021
+Last update: April 2021