DeepL Privacy Policy changes — 20221023_rev01

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For sending the newsletters, we use a service provided by HubSpot, Inc. with headquarters at 25 First Street, 2nd Floor, Cambridge, MA 02141 USA. As part of this, your data may also be transferred to the USA. We have concluded a data processing agreement with HubSpot and therefore HubSpot may only process the data according to our instructions and not for its own purposes. You can find more information on HubSpot's handling of personal data [here](https://legal.hubspot.com/privacy-policy) and [here](https://www.hubspot.com/data-privacy/privacy-shield).

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We also statistically record, among other things via HubSpot, which emails you open and which links you click on in our emails (opening and click rates). This allows us to understand which content is of interest to our users and to optimize the newsletter and our email communication, which corresponds to our legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f) GDPR.

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## 13\. DeepL's Social Media Pages

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DeepL operates several social media profiles (also called "pages") on various social networks e.g., Facebook, Twitter, LinkedIn and Xing. There we regularly publish posts about our products, new product features as well as new job offers. If you interact with our pages or contact us via them and are a member of the respective social network, we may receive and process data that identify you. As operator of the pages, we also have the option of viewing anonymous statistics on the interaction of visitors with our pages (insight function). For this purpose, the operators of the social networks record your interactions with our pages using cookies and similar technologies. You can find more information on this kind of data processing by Facebook and LinkedIn [here](https://www.facebook.com/legal/terms/information_about_page_insights_data) and [here](https://www.linkedin.com/help/linkedin/answer/a427660).

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DeepL operates several social media profiles (also called "pages") on various social networks e.g., Facebook, Instagram, Twitter, LinkedIn and Xing. There we regularly publish posts about our products, new product features as well as new job offers. If you interact with our pages or contact us via them and are a member of the respective social network, we may receive and process data that identify you. As operator of the pages, we also have the option of viewing anonymous statistics on the interaction of visitors with our pages (insight function). For this purpose, the operators of the social networks record your interactions with our pages using cookies and similar technologies. You can find more information on this kind of data processing by Facebook, Instagram and LinkedIn [here](https://www.facebook.com/legal/terms/information_about_page_insights_data), [here](https://www.facebook.com/help/instagram/788388387972460) and [here](https://www.linkedin.com/help/linkedin/answer/a427660).

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The legal basis for the operation of our social media profiles and the insights function is our legitimate interest within the meaning of Art. 6 para. 1 sentence 1 lit. f) GDPR in using the pages as an information channel for our company. With regard to the insights function, we have a legitimate interest in understanding the visits and interactions with our page in order to be able to respond to them and to further improve our presence. Insofar as your consent given to the social network justifies the data processing within the framework of the respective social platform, processing is carried out on the basis of this consent.

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Please note that we together with the operator of the respective social network are jointly responsible for the data processing operations triggered when you visit our page. However, the operators of the social networks may also process your data for their own purposes, which are not depicted in this privacy policy. It is also possible that data collected about you will be transferred to third countries, in particular the USA. We have no influence on this data processing and refer to the privacy policies of the respective social networks e.g., for Facebook [here](https://www.facebook.com/policy.php), for Twitter [here](https://twitter.com/en/privacy), for LinkedIn [here](https://www.linkedin.com/legal/privacy-policy) and for Xing [here](https://privacy.xing.com/en/privacy-policy).

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Please note that we together with the operator of the respective social network are jointly responsible for the data processing operations triggered when you visit our page. However, the operators of the social networks may also process your data for their own purposes, which are not depicted in this privacy policy. It is also possible that data collected about you will be transferred to third countries, in particular the USA. We have no influence on this data processing and refer to the privacy policies of the respective social networks e.g., for Facebook [here](https://www.facebook.com/policy.php), for Instagram [here](https://www.facebook.com/privacy/policy/), for Twitter [here](https://twitter.com/en/privacy), for LinkedIn [here](https://www.linkedin.com/legal/privacy-policy) and for Xing [here](https://privacy.xing.com/en/privacy-policy).

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In principle, you can assert your rights (see section [16]() below) both against us and against the operator of the respective social platform. However, we would like to point out that despite the joint controllership, you can most effectively assert your rights with the operators of the social networks. If you need help, you can contact us.

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## 14\. Job Applications

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We offer you the opportunity to apply for a position at DeepL via our career page and the integrated career portal, or by email. This digital recruitment process means that in order to complete the application procedure, your application data (usually name, contact information, cover letter, resume, as well as other supporting documents and credentials) is collected and processed electronically. The personal data you provide will be used exclusively for processing your job application. Your data will only be shared with persons involved in the application process. If you submit your documents in German only, even though an English version of the documents was requested in the job advertisement, we reserve the right to translate your documents into English using DeepL's PDF translation feature. In this context, your data may be transferred to the USA (see also section 6.2 of this privacy policy). The legal basis for the processing of your applicant data is Art. 6 para. 1 sentence 1 lit. b) GDPR in conjunction with Art. 88 para. 1 GDPR in conjunction with § 26 para. 1, 8 sentence 2 BDSG ("Bundesdatenschutzgesetz": German Federal Data Protection Act).

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We offer you the opportunity to apply for a position at DeepL via our career page and the integrated career portal, or by email. This digital recruitment process means that in order to complete the application procedure, your application data (usually name, contact information, cover letter, resume, as well as other supporting documents and credentials) is collected and processed electronically. The personal data you provide will be used exclusively for processing your job application. Your data will only be shared with persons involved in the application process. If you submit your documents in German only, even though an English version of the documents was requested in the job advertisement, we reserve the right to translate your documents into English using DeepL's PDF translation feature. In this context, your data may be transferred to the USA (see also section 6.2 of this privacy policy). The legal basis for the processing of your applicant data is Art. 6 para. 1 sentence 1 lit. b) GDPR in conjunction with Art. 88 para. 1 GDPR in conjunction with § 26 para. 1, 8 sentence 2 BDSG ("Bundesdatenschutzgesetz": German Federal Data Protection Act). If you apply for a freelance job at DeepL, the legal basis for the processing of your applicant data is Art. 6 para. 1 sentence 1 lit. b) GDPR.

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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 this case, the legal basis for the processing of your data is Art. 6 para. 1 sentence 1 lit. b) GDPR in conjunction with Art. 88 para. 1 GDPR in conjunction with § 26 para. 1 BDSG ("Bundesdatenschutzgesetz": German Federal Data Protection Act).

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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 this case, the legal basis for the processing of your data is Art. 6 para. 1 sentence 1 lit. b) GDPR in conjunction with Art. 88 para. 1 GDPR in conjunction with § 26 para. 1 BDSG ("Bundesdatenschutzgesetz": German Federal Data Protection Act). When working on a freelance basis for DeepL, we will store your personal data for the purpose of executing your contract with us. In this case, the legal basis for the processing of your data is Art. 6 paragraph 1 sentence 1 lit. b) GDPR.

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In the event of a rejection on your part or ours, we will retain the data submitted to us for up to a maximum of six months following notification of the rejection. We will subsequently delete the data unless legal regulations require us to store the data for a longer period.

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If you expressly agree to a longer storage period of your data e.g., for your inclusion in our internal applicant pool, the data will be further processed based on your consent in accordance with Art. 6. para. 1 sentence 1 lit. a) GDPR. Your data will then be stored in our pool of applicants for 1000 days. You can withdraw your consent at any time with effect for the future.

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In order to process your application data, it will be forwarded to the service provider Recruitee B.V., Keizersgracht 313, 1016 EE Amsterdam, The Netherlands, which operates the application system. 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. Further information on data protection at Recruitee can be found [here](https://recruitee.com/en/privacy).

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In certain cases, in particular applications for developer positions, the applicant's name and email address may be forwarded to the service provider Codesse Ltd., FF28, Kao Hockham Building, Edingburgh Way, Harlow, Essex, CM20 2NQ, United Kingdom, which provides services regarding the provision and review of coding challenges during an application. We have concluded a data processing agreement with Codesse, which means that Codesse may only process the data in accordance with our instructions and not for its own purposes. Codesse may contact applicants during the application process via email regarding the performance of the coding challenges. Further information on data protection at Codesse can be found [here](https://geektastic.com/legal/privacy-policy.pdf).

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## 15\. Data Security

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Your connections to our website and our apps 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 and/or mobile device 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.

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## 16\. Your Rights

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 For sending the newsletters, we use a service provided by HubSpot, Inc. with headquarters at 25 First Street, 2nd Floor, Cambridge, MA 02141 USA. As part of this, your data may also be transferred to the USA. We have concluded a data processing agreement with HubSpot and therefore HubSpot may only process the data according to our instructions and not for its own purposes. You can find more information on HubSpot's handling of personal data [here](https://legal.hubspot.com/privacy-policy) and [here](https://www.hubspot.com/data-privacy/privacy-shield).
 We also statistically record, among other things via HubSpot, which emails you open and which links you click on in our emails (opening and click rates). This allows us to understand which content is of interest to our users and to optimize the newsletter and our email communication, which corresponds to our legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f) GDPR.
 ## 13\. DeepL's Social Media Pages
+DeepL operates several social media profiles (also called "pages") on various social networks e.g., Facebook, Twitter, LinkedIn and Xing. There we regularly publish posts about our products, new product features as well as new job offers. If you interact with our pages or contact us via them and are a member of the respective social network, we may receive and process data that identify you. As operator of the pages, we also have the option of viewing anonymous statistics on the interaction of visitors with our pages (insight function). For this purpose, the operators of the social networks record your interactions with our pages using cookies and similar technologies. You can find more information on this kind of data processing by Facebook and LinkedIn [here](https://www.facebook.com/legal/terms/information_about_page_insights_data) and [here](https://www.linkedin.com/help/linkedin/answer/a427660).
+DeepL operates several social media profiles (also called "pages") on various social networks e.g., Facebook, Instagram, Twitter, LinkedIn and Xing. There we regularly publish posts about our products, new product features as well as new job offers. If you interact with our pages or contact us via them and are a member of the respective social network, we may receive and process data that identify you. As operator of the pages, we also have the option of viewing anonymous statistics on the interaction of visitors with our pages (insight function). For this purpose, the operators of the social networks record your interactions with our pages using cookies and similar technologies. You can find more information on this kind of data processing by Facebook, Instagram and LinkedIn [here](https://www.facebook.com/legal/terms/information_about_page_insights_data), [here](https://www.facebook.com/help/instagram/788388387972460) and [here](https://www.linkedin.com/help/linkedin/answer/a427660).
 The legal basis for the operation of our social media profiles and the insights function is our legitimate interest within the meaning of Art. 6 para. 1 sentence 1 lit. f) GDPR in using the pages as an information channel for our company. With regard to the insights function, we have a legitimate interest in understanding the visits and interactions with our page in order to be able to respond to them and to further improve our presence. Insofar as your consent given to the social network justifies the data processing within the framework of the respective social platform, processing is carried out on the basis of this consent.
+Please note that we together with the operator of the respective social network are jointly responsible for the data processing operations triggered when you visit our page. However, the operators of the social networks may also process your data for their own purposes, which are not depicted in this privacy policy. It is also possible that data collected about you will be transferred to third countries, in particular the USA. We have no influence on this data processing and refer to the privacy policies of the respective social networks e.g., for Facebook [here](https://www.facebook.com/policy.php), for Twitter [here](https://twitter.com/en/privacy), for LinkedIn [here](https://www.linkedin.com/legal/privacy-policy) and for Xing [here](https://privacy.xing.com/en/privacy-policy).
+Please note that we together with the operator of the respective social network are jointly responsible for the data processing operations triggered when you visit our page. However, the operators of the social networks may also process your data for their own purposes, which are not depicted in this privacy policy. It is also possible that data collected about you will be transferred to third countries, in particular the USA. We have no influence on this data processing and refer to the privacy policies of the respective social networks e.g., for Facebook [here](https://www.facebook.com/policy.php), for Instagram [here](https://www.facebook.com/privacy/policy/), for Twitter [here](https://twitter.com/en/privacy), for LinkedIn [here](https://www.linkedin.com/legal/privacy-policy) and for Xing [here](https://privacy.xing.com/en/privacy-policy).
 In principle, you can assert your rights (see section [16]() below) both against us and against the operator of the respective social platform. However, we would like to point out that despite the joint controllership, you can most effectively assert your rights with the operators of the social networks. If you need help, you can contact us.
 ## 14\. Job Applications
+We offer you the opportunity to apply for a position at DeepL via our career page and the integrated career portal, or by email. This digital recruitment process means that in order to complete the application procedure, your application data (usually name, contact information, cover letter, resume, as well as other supporting documents and credentials) is collected and processed electronically. The personal data you provide will be used exclusively for processing your job application. Your data will only be shared with persons involved in the application process. If you submit your documents in German only, even though an English version of the documents was requested in the job advertisement, we reserve the right to translate your documents into English using DeepL's PDF translation feature. In this context, your data may be transferred to the USA (see also section 6.2 of this privacy policy). The legal basis for the processing of your applicant data is Art. 6 para. 1 sentence 1 lit. b) GDPR in conjunction with Art. 88 para. 1 GDPR in conjunction with § 26 para. 1, 8 sentence 2 BDSG ("Bundesdatenschutzgesetz": German Federal Data Protection Act).
+We offer you the opportunity to apply for a position at DeepL via our career page and the integrated career portal, or by email. This digital recruitment process means that in order to complete the application procedure, your application data (usually name, contact information, cover letter, resume, as well as other supporting documents and credentials) is collected and processed electronically. The personal data you provide will be used exclusively for processing your job application. Your data will only be shared with persons involved in the application process. If you submit your documents in German only, even though an English version of the documents was requested in the job advertisement, we reserve the right to translate your documents into English using DeepL's PDF translation feature. In this context, your data may be transferred to the USA (see also section 6.2 of this privacy policy). The legal basis for the processing of your applicant data is Art. 6 para. 1 sentence 1 lit. b) GDPR in conjunction with Art. 88 para. 1 GDPR in conjunction with § 26 para. 1, 8 sentence 2 BDSG ("Bundesdatenschutzgesetz": German Federal Data Protection Act). If you apply for a freelance job at DeepL, the legal basis for the processing of your applicant data is Art. 6 para. 1 sentence 1 lit. b) GDPR.
+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 this case, the legal basis for the processing of your data is Art. 6 para. 1 sentence 1 lit. b) GDPR in conjunction with Art. 88 para. 1 GDPR in conjunction with § 26 para. 1 BDSG ("Bundesdatenschutzgesetz": German Federal Data Protection Act).
+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 this case, the legal basis for the processing of your data is Art. 6 para. 1 sentence 1 lit. b) GDPR in conjunction with Art. 88 para. 1 GDPR in conjunction with § 26 para. 1 BDSG ("Bundesdatenschutzgesetz": German Federal Data Protection Act). When working on a freelance basis for DeepL, we will store your personal data for the purpose of executing your contract with us. In this case, the legal basis for the processing of your data is Art. 6 paragraph 1 sentence 1 lit. b) GDPR.
 In the event of a rejection on your part or ours, we will retain the data submitted to us for up to a maximum of six months following notification of the rejection. We will subsequently delete the data unless legal regulations require us to store the data for a longer period.
 If you expressly agree to a longer storage period of your data e.g., for your inclusion in our internal applicant pool, the data will be further processed based on your consent in accordance with Art. 6. para. 1 sentence 1 lit. a) GDPR. Your data will then be stored in our pool of applicants for 1000 days. You can withdraw your consent at any time with effect for the future.
 In order to process your application data, it will be forwarded to the service provider Recruitee B.V., Keizersgracht 313, 1016 EE Amsterdam, The Netherlands, which operates the application system. 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. Further information on data protection at Recruitee can be found [here](https://recruitee.com/en/privacy).
+In certain cases, in particular applications for developer positions, the applicant's name and email address may be forwarded to the service provider Codesse Ltd., FF28, Kao Hockham Building, Edingburgh Way, Harlow, Essex, CM20 2NQ, United Kingdom, which provides services regarding the provision and review of coding challenges during an application. We have concluded a data processing agreement with Codesse, which means that Codesse may only process the data in accordance with our instructions and not for its own purposes. Codesse may contact applicants during the application process via email regarding the performance of the coding challenges. Further information on data protection at Codesse can be found [here](https://geektastic.com/legal/privacy-policy.pdf).
 ## 15\. Data Security
 Your connections to our website and our apps 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 and/or mobile device 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.
 ## 16\. Your Rights
 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, email: [poststelle(at)ldi.nrw.de](mailto:poststelle@ldi.nrw.de).
 ## 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://www.deepl.com/privacy).
+Last update: July 2022
+Last update: October 2022

Privacy Policy

Full text changes — 20220803_rev01 to 20221023_rev01