Privacy Policy

ARCHIVED 2022-12-14, DATE APPROXIMATE · VERSION 20221214_rev01 · COMPARED WITH 20221023_rev01

Full text changes — 20221023_rev01 to 20221214_rev01

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

 ## 1\. Data controller / Contact / Data Protection Officer
 The data controller responsible for data processing pursuant to the GDPR, BDSG, other data protection laws applicable in the member states of the European Union, and other regulations relating to data protection is:
 DeepL SE Maarweg 165 50825 Cologne Germany
+If you have any questions or concerns about privacy, please contact privacy(at)deepl.com. For the conclusion of a data processing agreement pursuant to Art. 28 GDPR (see in detail section 4) and for general questions about our products, please contact sales(at)deepl.com. Further information on the data processing when contacting DeepL can be found in section 11.
+If you have any questions or concerns about privacy, please contact privacy(at)deepl.com. For the conclusion of a data processing agreement pursuant to Art. 28 GDPR (see in detail section 4) and for general questions about our products, please contact sales(at)deepl.com. Further information on the data processing when contacting DeepL can be found in section [12]().
 DeepL's external corporate Data Protection Officer, Dr. Christian Lenz, can be contacted at the following address: dhpg IT-Services GmbH, Bunsenstr. 10a, 51647 Gummersbach, via email to datenschutz(at)dhpg.de, or by telephone on +49 2261 8195 0.
 ## 2\. Scope of Data Protection
 Data protection applies to personal data as defined by the GDPR, i.e. all information relating to an identified or identifiable natural person. An identifiable natural person is deemed to be a natural person who can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier or to one or more specific attributes.
 ## 3\. Texts and Translations - DeepL Translator (free version)
 When using our translation service, please only enter texts that you wish to transfer to our servers. The transmission of these texts is necessary in order for us to provide the translation and offer you our service. We process your texts, the documents you upload and their translations for a limited period of time to train and improve our neural networks and translation algorithms. This also applies to corrections you make to our translation suggestions. The corrections are forwarded to our servers to check them for accuracy and, if necessary, to update the translated text according to your changes. If you use the glossary feature and enter certain pairs of terms there, this data is only stored locally and is not forwarded to our servers. Therefore, you cannot use your glossary entries in another browser or on another device.
+Please note that according to its Terms and Conditions, you may not use DeepL Translator for the translation of texts containing personal data of any kind. The translation of personal data is only possible as part of a DeepL Pro subscription (please see section 4).
+Please note that according to its Terms and Conditions, you may not use DeepL Translator for the translation of texts containing personal data of any kind. The translation of personal data is only possible as part of a DeepL Pro subscription (please see section [5]()).
+## 4\. Texts and Translations - DeepL Pro
+## 4\. DeepL Write Alpha/Beta
+When using our DeepL Pro subscription to translate texts, the texts or documents you submit will not be permanently stored and will only be kept temporarily to the extent necessary for the production and transmission of the translation. After complete performance of the contractually agreed services all submitted texts or documents and their translations will be deleted. When using DeepL Pro, your texts will not be used to improve the quality of our services. For further information on the processing of your data within the DeepL Pro subscription, please refer to section 5 of this privacy policy and our DeepL Pro [Terms and Conditions](https://www.deepl.com/en/pro-license/).
+DeepL Write Alpha/Beta is a function that is currently in the test phase, with which you can improve the language of texts. This test function is not part of our range of services included in a DeepL Pro subscription. For more information on test functions, please see our DeepL Pro [Terms and Conditions](https://www.deepl.com/en/pro-license).
+If you use DeepL Write Alpha/Beta without having a DeepL Pro subscription, please only enter texts that you wish to transfer to our servers. The transmission of these texts is necessary in order for us to improve the language of your texts and offer you our service. We process your texts as well as their improvement for a limited period of time to train and improve our neural networks and algorithms. This also applies to corrections you make to our improvement suggestions. The corrections are forwarded to our servers to check them for accuracy and, if necessary, to update the improved text according to your changes.
+Please note that you may not use DeepL Write Alpha/Beta to improve texts containing personal data of any kind, as also stipulated in the [terms of use](https://www.deepl.com/de/pro-license) of the DeepL Translator.
+If you have a paid DeepL Pro subscription and are logged into your account, the data protection guarantees there also apply to DeepL Write Alpha/Beta. The texts you submit will not be permanently stored and will only be kept temporarily to the extent necessary for the production and transmission of the text improvement. Once the text improvement has been completed, all submitted texts and their improvements will be deleted. When using DeepL Pro, your texts will not be used to improve the quality of our services. For further information on the processing of personal data within the DeepL Pro subscription, please refer to section [5]() and [6]() of this privacy policy and our DeepL Pro [Terms and Conditions](https://www.deepl.com/en/pro-license/).
+## 5\. Texts and Translations - DeepL Pro
+When using our DeepL Pro subscription to translate texts, the texts or documents you submit will not be permanently stored and will only be kept temporarily to the extent necessary for the production and transmission of the translation. After complete performance of the contractually agreed services all submitted texts or documents and their translations will be deleted. When using DeepL Pro, your texts will not be used to improve the quality of our services. For further information on the processing of your data within the DeepL Pro subscription, please refer to section 6 of this privacy policy and our DeepL Pro [Terms and Conditions](https://www.deepl.com/en/pro-license/).
 Please note that using DeepL Pro for the translation of texts containing personal data of any kind is only permitted if there is a justification for this under data protection law. Therefore, our T&C provide for the conclusion of a data processing agreement (see section 8.1.3 of [DeepL Pro Terms and Conditions](https://www.deepl.com/pro-license)). To enter into such an agreement, please contact sales(at)deepl.com.
+## 5\. Creating a DeepL account and Signing up for a DeepL Pro Subscription
+## 6\. Creating a DeepL account and Signing up for a DeepL Pro Subscription
+### 5.1. Creating a DeepL account
+### 6.1. Creating a DeepL account
 You have the option of creating a DeepL account. You can use the DeepL translator via this account within the applicable [DeepL Account Terms and Conditions](https://www.deepl.com/pro-license) (please see also section [3]()). To create the account, the following personal data will be stored:
 - E-mail address
 - Password
 - IP address
 We process the email address and password on the basis of Art. 6 para. 1 sentence 1 lit. b) GDPR in order to perform the contract of use. Your IP address is processed in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR, as it is in our legitimate interests to match your IP address with IP addresses that have misused our service in the past for fraud prevention purposes.
+Please note that the creation of a DeepL account is a prerequisite for signing up for and using a DeepL Pro subscription (see section 5.2), but creating a DeepL account does not oblige you to purchase a paid subscription. Even if you do not sign up for a DeepL Pro subscription after creating the account, the DeepL account remains available and you can use it. You can delete your DeepL account at any time by sending an e-mail with your request to support(at)deepl.com.
+Please note that the creation of a DeepL account is a prerequisite for signing up for and using a DeepL Pro subscription (see section [6.2]()), but creating a DeepL account does not oblige you to purchase a paid subscription. Even if you do not sign up for a DeepL Pro subscription after creating the account, the DeepL account remains available and you can use it. You can delete your DeepL account at any time by sending an e-mail with your request to support(at)deepl.com.
 If your company uses Single Sign-On (SSO) to log in to DeepL, there is no need for a separate registration with DeepL. When you log in via Single Sign-On your company transmits your email address as well as your first and last name directly to us. We also process this data on the basis of Art. 6 para. 1 sentence 1 lit. b) GDPR.
+### 5.2. Signing up for DeepL Pro
+### 6.2. Signing up for DeepL Pro
 If, after creating a DeepL account, you sign up for a DeepL Pro subscription, additionally the following personal data will be collected and processed for the purposes of concluding and fulfilling the contract (Art. 6 para. 1 sentence 1 lit. b) GDPR):
 - First name, surname, and where applicable, company name
 - Address
 - Tax numbers (where applicable)
 - Selected subscription option
 - Possibly other, additional data you provided during the registration process.
+Your payment details will also be processed by us if you initially sign up for a DeepL Pro subscription with a free trial period. Despite the free trial period, the processing of your payment details is already necessary at the time of the formation of the contract within the meaning of Art. 6 para. 1 sentence 1 lit. b) GDPR, as a DeepL Pro subscription is in principle a paid subscription and we only in some cases allow our customers to test our products free of charge for the first 30 days. However, if no cancellation is made within the first 30 days, the subscription will automatically continue to be subject to payment and the method of payment specified by you will be debited at the time stated in the booking process.
+Your payment details will also be processed by us if you initially sign up for a DeepL Pro subscription with a free trial period. Despite the free trial period, the processing of your payment details is already necessary at the time of the formation of the contract within the meaning of Art. 6 para. 1 sentence 1 lit. b) GDPR, as a DeepL Pro subscription is in principle a paid subscription and we only in some cases allow our customers to test our products free of charge for a trial period. However, if no cancellation is made within the aforementioned trial period, the subscription will automatically continue to be subject to payment and the method of payment specified by you will be debited at the time stated in the booking 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 transfer the data to Stripe, Inc., located in the USA. Further information on data protection at Stripe and compliance with the requirements of Art. 44 GDPR can be found [here](https://stripe.com/de/privacy) and [here](https://stripe.com/de/privacy-center/legal). We have concluded a data processing agreement with Stripe, which allows Stripe to process the data solely in accordance with our instructions and not for its own purposes.
+In addition to the aforementioned data, we process further (usage-)data relevant for the provision and billing of our service, such as subscription ID, date and time of the subscription conclusion, billing period, successful payment processing, log-ins, number of translated characters and documents, upgrades and downgrades. The processing and storage of the aforementioned data is necessary for the conclusion of the contract as well as its performance and is therefore justified according to Art. 6 para. 1 sentence 1 lit. b) GDPR. If you yourself are not a party to the contract, but DeepL Pro is provided to you, e.g. by your employer or an organization to which you belong, we justify the processing of the data mentioned in section 5.1 and the aforementioned usage data via Art. 6 para. 1 sentence 1 lit. f) GDPR, as this is necessary for the performance of the business relationship with our customers, i.e. your employer or your organization.
+In addition to the aforementioned data, we process further (usage-)data relevant for the provision and billing of our service, such as subscription ID, date and time of the subscription conclusion, billing period, successful payment processing, log-ins, number of translated characters and documents, upgrades and downgrades. The processing and storage of the aforementioned data is necessary for the conclusion of the contract as well as its performance and is therefore justified according to Art. 6 para. 1 sentence 1 lit. b) GDPR. If you yourself are not a party to the contract, but DeepL Pro is provided to you, e.g. by your employer or an organization to which you belong, we justify the processing of the data mentioned in section 6.1 and the aforementioned usage data via Art. 6 para. 1 sentence 1 lit. f) GDPR, as this is necessary for the performance of the business relationship with our customers, i.e. your employer or your organization.
+We store the data for the duration of the contract term and subsequently, if applicable, for the duration of statutory retention periods, insofar as these prescribe the retention for the respective types of data. We will delete your account if you wish to do so after canceling your subscription. Otherwise, we will maintain your account as DeepL account so that it is available to you in the event of a renewed subscription without you having to register again. This is in your as well as in our legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f) GDPR.
+We store the data for the duration of the contract term and subsequently, if applicable, for the duration of statutory retention periods, insofar as these prescribe the retention for the respective types of data. We will delete your account if you wish to do so after canceling your subscription. Otherwise, we will maintain your account as DeepL account (see section [6.1]()) so that it is available to you in the event of a renewed subscription without you having to register again. This is in your as well as in our legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f) GDPR.
 In your account in the section "usage", you can also view data about your usage behavior e.g., - depending on your subscription - the number of characters translated in the past or the number of documents translated. If you have a consumption-based subscription, such as the DeepL API Pro, you can also view the monthly costs incurred. We justify this data processing via Art. 6 para. 1 sentence 1 lit. f) GDPR, insofar as it is necessary for the performance of the contract, in particular for billing purposes or for managing the number of documents still available for translation. Insofar as the processing goes beyond what is necessary for the performance of the contract, we base the processing on our legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f) GDPR, as we seek to meet our customers' wish to visualize information on usage behavior in a transparent manner. The graphical representation of the development of consumption over the contract period is considered to be also in the interest of our customers.
 If you yourself are not a party to the DeepL Pro subscription, but access to our products is provided to you by your employer or an organization to which you belong, it is possible that we share data about your usage behavior (e.g. last login date) with your employer or organization. Such data transfer only takes place insofar as this corresponds to our legitimate interests as well as the legitimate interests of our customers in receiving information about the use of the subscriptions they have paid for and your interests do not override in the individual case.
+### 5.3. Processing of the Submitted Texts and Translations
+### 6.3. Processing of the Submitted Texts and Translations
+We process the texts you submit to DeepL Pro and their translations only temporarily, insofar as this is necessary for the creation and transmission of the translation. The processing is therefore justified by Art. 6 para. 1 sentence 1 lit. b) GDPR. Your texts and the translations will - within the framework of the contractual agreements and as stated in section [4]() - not be stored permanently and will be deleted after the performance of the contractually owed service. The only exception is if you use the "save translations" feature in our apps. In this case, texts selected by you, including translations, can be saved locally on the device used and thus kept accessible at all times.
+We process the texts you submit to DeepL Pro and their translations only temporarily, insofar as this is necessary for the creation and transmission of the translation. The processing is therefore justified by Art. 6 para. 1 sentence 1 lit. b) GDPR. Your texts and the translations will - within the framework of the contractual agreements and as stated in section [5]() - not be stored permanently and will be deleted after the performance of the contractually owed service. The only exception is if you use the "save translations" feature in our apps. In this case, texts selected by you, including translations, can be saved locally on the device used and thus kept accessible at all times.
 If you use our glossary feature and store certain term pairs there, this data will be forwarded to our servers and stored for your account. If you want to use the glossary function as part of our service, the data processing that takes place in this context is necessary for the performance of our contract and is therefore also justified by Art. 6 para. 1 sentence 1 lit. b) GDPR.
+## 6\. Translation of documents
+## 7\. Translation of documents
+### 6.1. Translation of .docx and .pptx Documents with DeepL Translator and DeepL Pro
+### 7.1. Translation of .docx and .pptx Documents with DeepL Translator and DeepL Pro
+You can translate documents in .docx and .pptx format both with DeepL Pro as well as with DeepL Translator. When using document translation in DeepL Translator, section [3]() of this privacy policy applies. If you translate documents of the file types mentioned above while you are logged in to your DeepL Pro account, the texts you submit will only be processed temporarily and will be deleted after the completion of the translation process, including the translations themselves (see also section [4]() and [5.3]() of this privacy policy).
+You can translate documents in .docx and .pptx format both with DeepL Pro as well as with DeepL Translator. When using document translation in DeepL Translator, section [3]() of this privacy policy applies. If you translate documents of the file types mentioned above while you are logged in to your DeepL Pro account, the texts you submit will only be processed temporarily and will be deleted after the completion of the translation process, including the translations themselves (see also section [5]() and [6.3]() of this privacy policy).
+### 6.2. Translation of PDF documents with DeepL Translator and DeepL Pro
+### 7.2. Translation of PDF documents with DeepL Translator and DeepL Pro
+DeepL offers the translation of PDF documents for both DeepL Translator and DeepL Pro; in this respect, section 6.1 applies accordingly. Please note the following specifics: The actual translation of your documents will continue to be provided exclusively by DeepL and processed on our infrastructure in the EEA. In order to be able to translate PDF documents, it is necessary for technical reasons to convert the content of the PDF files into formatted text. For this purpose, we use the API of Adobe Systems Software Ireland Limited, 4-6 Riverwalk, City West Business Campus, Dublin 24, Republic of Ireland ("Adobe API"). The PDF documents are sent to the Adobe API, converted there, sent back to DeepL in the required format and translated by DeepL. The infrastructure of Adobe Inc., 345 Park Ave, San Jose, CA 95110, USA, is also used in the conversion process. To make the text translated by DeepL available to you again in PDF format, the Adobe API is used once more (this time in reverse order). Adobe stores the files received on its servers for a maximum period of 24 hours. We have concluded a data processing agreement with Adobe Systems Software Ireland Limited and therefore the transferred data may only be processed according to our instructions. To justify the data transfer to the USA, Adobe Systems Software Ireland Limited and Adobe Inc. have agreed on EU standard contractual clauses, Art. 46 para. 2 lit. c) GDPR. Further information on the handling of personal data at Adobe can be found [here](https://www.adobe.com/privacy/policy-linkfree.html).
+DeepL offers the translation of PDF documents for both DeepL Translator and DeepL Pro; in this respect, section [7.1]() applies accordingly. Please note the following specifics: The actual translation of your documents will continue to be provided exclusively by DeepL and processed on our infrastructure in the EEA. In order to be able to translate PDF documents, it is necessary for technical reasons to convert the content of the PDF files into formatted text. For this purpose, we use the API of Adobe Systems Software Ireland Limited, 4-6 Riverwalk, City West Business Campus, Dublin 24, Republic of Ireland ("Adobe API"). The PDF documents are sent to the Adobe API, converted there, sent back to DeepL in the required format and translated by DeepL. The infrastructure of Adobe Inc., 345 Park Ave, San Jose, CA 95110, USA, is also used in the conversion process. To make the text translated by DeepL available to you again in PDF format, the Adobe API is used once more (this time in reverse order). Adobe stores the files received on its servers for a maximum period of 24 hours. We have concluded a data processing agreement with Adobe Systems Software Ireland Limited and therefore the transferred data may only be processed according to our instructions. To justify the data transfer to the USA, Adobe Systems Software Ireland Limited and Adobe Inc. have agreed on EU standard contractual clauses, Art. 46 para. 2 lit. c) GDPR. Further information on the handling of personal data at Adobe can be found [here](https://www.adobe.com/privacy/policy-linkfree.html).
+If you upload documents containing personal data for PDF translation as a DeepL Pro customer in accordance with section [4]() of this privacy policy, we will process this data in accordance with your express instructions. You give us this instruction by confirming before each translation of a PDF document that you want to translate it using the Adobe API. As a DeepL Pro customer, you have the option of permanently saving the instruction in the translation settings of your account. For team accounts, the translation of PDF documents is only possible after prior authorisation by the team administrator. When using the DeepL API Pro, we cannot ask you for your instruction before each translation of a PDF document for technical reasons. You therefore give us your instruction by allowing the use of this function in your account settings prior to translating PDF documents.
+If you upload documents containing personal data for PDF translation as a DeepL Pro customer in accordance with section [5]() of this privacy policy, we will process this data in accordance with your express instructions. You give us this instruction by confirming before each translation of a PDF document that you want to translate it using the Adobe API. As a DeepL Pro customer, you have the option of permanently saving the instruction in the translation settings of your account. For team accounts, the translation of PDF documents is only possible after prior authorisation by the team administrator. When using the DeepL API Pro, we cannot ask you for your instruction before each translation of a PDF document for technical reasons. You therefore give us your instruction by allowing the use of this function in your account settings prior to translating PDF documents.
 You can adjust your instruction at any time in the translation settings in your account. In consequence, we will ask you again for your confirmation before each translation of a PDF document. Further explanations on how to manage your translation settings depending on the DeepL Pro subscription you have chosen can be found [here](https://support.deepl.com/hc/en-us/articles/4408150502802). Free users who want to translate PDF documents with DeepL Translator will also find further information there.
 If you choose not to translate PDF documents, your texts will still be processed exclusively within the European Economic Area.
+### 6.3. Temporary Storage of Metadata when Translating Documents
+### 7.3. Temporary Storage of Metadata when Translating Documents
 Regardless of whether you use our paid or free service when translating documents, particularly the following data is stored for each translation process:
 - Status/progress of the translation process
 - Document file type
 - Number of characters calculated
 - Errors that occurred during the translation process
 This information is processed in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR based on our legitimate interest in improving the functionality of our products, as this makes it easier to identify any sources of error related to the translation process. The data is stored in a database that can only be accessed by selected employees and is automatically deleted after 14 days.
+## 7\. Automatic Collection of Data via Website Access
+## 8\. Automatic Collection of Data via Website Access
 Regardless of whether you use our paid or free service, your device automatically transmits certain data for technical reasons when you access our website [www.deepl.com](https://www.deepl.com/). The following data that you may send us will be stored:
 - Date and time of access
 - Browser type and version
 - Full IP address
 - Diagnostic information in the event of errors
 Processing is carried out in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR based on our legitimate interest in improving the stability and functionality of our website. The data is stored for purely technical reasons. Website access data is used for error analysis, ensuring system security, logging access to DeepL Pro and for improving our translation service. Based on your IP address, we also use geolocation to determine the region from which you are visiting our website. We use this information to check whether we can offer you the DeepL Pro service in your region, which corresponds to our legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f) GDPR. The storage of the full IP address for the users of the DeepL free version for a maximum period of 14 days is also justified by our legitimate interest in achieving the listed purposes, Art. 6 para. 1 sentence 1 lit. f) GDPR. The storage of IP addresses of users of the paid DeepL Pro subscription for the duration of the contract is justified by Art. 6 para. 1 sentence 1 lit. b) GDPR.
+Our website also uses services of Cloudflare, Inc, 101 Townsend St, San Francisco, CA 94107, USA ("Cloudflare"), which operates a so-called Content Delivery Network (CDN). To protect our website, the data transfer between your browser and our servers is routed through Cloudflare's infrastructure in order to analyze whether it is an abusive attack. As part of this analysis, your data is transmitted to Cloudflare in encrypted form, if necessary also to Cloudflare servers in the USA. However, since your translation requests and other customer data are encrypted between your end device and the DeepL servers, Cloudflare does not have any access to this data, but only to meta-data (such as your IP address). Only static resources (such as graphics) are loaded directly from Cloudflare-servers. In addition, Cloudflare determines a so-called botscore immediately before the login to DeepL, which is based on the analysis of the metadata of the client (browser) used. This data is deleted after 30 days. The use of Cloudflare is in our legitimate interest to secure the use of our website and to prevent and defend harmful attacks from outside, Art. 6 para. 1 sentence 1 lit. f) GDPR. We have concluded a data processing agreement with Cloudflare and Cloudflare may therefore only process the data according to our instructions and not for its own purposes. You can find more information about Cloudflare's handling of personal data [here](https://www.cloudflare.com/de-de/privacypolicy/).
+Our website also uses services of Cloudflare, Inc, 101 Townsend St, San Francisco, CA 94107, USA ("Cloudflare"), which operates a so-called Content Delivery Network (CDN). To protect our website, the data transfer between your browser and our servers is routed through Cloudflare's infrastructure in order to analyze whether it is an abusive attack. As part of this analysis, your data is transmitted to Cloudflare in encrypted form, if necessary also to Cloudflare servers in the USA. However, since your translation requests and other customer data are encrypted between your end device and the DeepL servers, Cloudflare does not have any access to this data, but only to meta-data (such as your IP address). Only static resources (such as graphics) are loaded directly from Cloudflare-servers. In addition, Cloudflare determines a so-called bot score immediately before the login to DeepL, which is based on the analysis of the metadata of the client (browser) used. This data is deleted after 30 days. The use of Cloudflare is in our legitimate interest to secure the use of our website and to prevent and defend harmful attacks from outside, Art. 6 para. 1 sentence 1 lit. f) GDPR. We have concluded a data processing agreement with Cloudflare and Cloudflare may therefore only process the data according to our instructions and not for its own purposes. You can find more information about Cloudflare's handling of personal data [here](https://www.cloudflare.com/de-de/privacypolicy/).
+## 8\. Cookies and Web Storage on deepl.com and Analysis of User Behavior
+## 9\. Cookies and Web Storage on deepl.com and Analysis of User Behavior
+### 8.1 Use of Cookies and Web Storage on deepl.com
+### 9.1 Use of Cookies and Web Storage on deepl.com
 If you do not want us to use cookies or web storage objects, you can change your browser settings accordingly. Please note that if you completely disable the use of cookies or web storage objects, the functionality and scope of the website may be impaired.
 We specifically use cookies or web storage objects in the following categories:
 - Necessary: These cookies or web storage objects are necessary to ensure the functioning of our website and the formation as well as the performance of contracts. The cookies serve security purposes, the smooth navigation on our website, the provision of the most important functions of our products, the storage of your settings such as the display language of the website and the selected translation language as well as the handling of the checkout process for DeepL Pro. In addition, statistical data about the use of our website is collected. The collecting of data via the necessary cookies or web storage objects is justified according to § 25 para. 2 no. 2 TTDSG ("Telekommunikation-Telemedien-Datenschutz-Gesetz": German Telecommunications and Telemedia Data Protection Act). The further processing of this data is either necessary in accordance with Art. 6 para. 1 sentence 1 lit. b) GDPR for performing the contract or justified due to our legitimate interest in presenting our products and our company in accordance with 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 and our external service providers use these cookies or web storage objects with your explicit consent in accordance with § 25 para. 1 TTDSG. The further processing of this data is also based on your consent, Art. 6 para. 1 sentence 1 lit. a) GDPR.
 - 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 § 25 para. 1 TTDSG and Art. 6 para. 1 sentence 1 lit. a) GDPR, we only use these cookies or web storage objects and process the data collected from them with your explicit consent.
 The table below lists the different types of cookies and web storage objects that may be used on our website. Cookies or web storage objects are stored until the specified expiration time or until you delete them in your browser 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 in the table below.
+With the exception of the third-party cookies from our payment service provider Stripe (see explanatory notes, section [5.2]()), the customer support software from Zendesk (see explanatory notes, section [11.1]()) and the marketing software from HubSpot (see explanatory notes, section [12]()) the information generated by cookies and web storage objects is transmitted to servers within the EU and stored exclusively there. Data is not passed on to third parties.
+With the exception of the third-party cookies from our payment service provider Stripe (see explanatory notes, section [6.2]()), the customer support software from Zendesk (see explanatory notes, section [12.1]()) and the marketing software from HubSpot (see explanatory notes, section [13]()) the information generated by cookies and web storage objects is transmitted to servers within the EU and stored exclusively there. Data is not passed on to third parties.
+### 8.2 Analysis of User Behavior
+### 9.2 Analysis of User Behavior
 In order to better understand how our products are used and to better tailor our products to the needs and desires of our customers, we analyze pseudonymized data about our customers' use of DeepL Pro products. The analysis allows us to understand general usage habits and derive different target and user groups. We can then address the identified user groups in a more specific way and, for example, point them to previously unused or unknown features of our products. In this way, we enable our customers to get to know and use all the features of their DeepL subscription and can thus improve the user experience of the DeepL products. This corresponds to our legitimate interests according to Art. 6 para. 1 p. 1 lit. f) GDPR. The data is processed exclusively on DeepL's servers in the EEA, the data is not transferred to the USA. No transfer of the data to third parties takes place.
 Overview of the cookies and web storage objects used by DeepL:
 ### Necessary
  | TechnologyCookie | Expiry6 months | OwnerDeepL |
 | Translator | IDLMT | Description
 Stores settings made explicitly by the user. E.g. preferred translation language or entries in the glossary.
  | TechnologyLocal Storage | Expiry1 month | OwnerDeepL |
+| Write | IDLMT\_write | Description
+Stores settings made explicitly by the user for the preferred language or language variant, in order to make them available when Write is used again as well as whether the user has already seen the Intro Guide. In addition, the specific use of the alternative pop-up is noted in order to show customers the relevant alternatives in the future. Stores if pop-up announcing DeepL Write was shown.
+ | TechnologyLocal Storage | Expiry30 days | OwnerDeepL |
+| Write | IDLMT\_customization | Description
+Stores if the reference to Write in the header menu was clicked.
+ | TechnologyLocal Storage | Expiry30 days | OwnerDeepL |
+| Write | IDLMT\_preferredLangWeightsWrite | Description
+Stores the weighting of the languages used by the user to allow accurate language identification of the text entered.
+ | TechnologyLocal Storage | Expiry30 days | OwnerDeepL |
 | Translator | IDproductRecommendations | Description
 Used for feature onboarding and discovery on the translator.
  | TechnologyCookie | Expiry7 days | OwnerDeepL |
 | Translator | IDrecommendationFlags | Description
  | TechnologyLocal Storage | ExpirySession | OwnerDeepL |
 | DeepL Pro-User Login/Session | IDuser | Description
 Stores the display name of logged-in users to display their name. Deleted if the user logs out.
  | TechnologyLocal Storage | Expiry7 days | OwnerDeepL |
+| DeepL Pro-User Login/Session | IDrgReload | Description
+Used to login a user. Deleted after the login has been completed.
+ | TechnologyCookie | Expiry10 seconds | OwnerDeepL |
 | Release process | IDreleaseGroups | Description
 Used for gradual, controlled releases to ensure stability, quality and performance of our service and infrastructure.
  | TechnologyCookie | Expiry1 month | OwnerDeepL |
+| Release process | IDdapGid | Description
+Used for controlled rollout of features for logged users.
+ | TechnologyCookie | Expiry1 month | OwnerDeepL |
 | Session ID | IDdapSid | Description
 Session ID and timestamp. Automatically deleted after 30 minutes of inactivity.
  | TechnologyCookie | ExpirySession | OwnerDeepL |
 | App Usage Statistics - only for DeepL Apps | IDappUsageStats | Description
 | Product information | IDapiDocsVisited | Description
 Stores whether API documentation has been visited to help users select the correct package at checkout.
  | TechnologyLocal Storage | ExpiryPersistent Data | OwnerDeepL |
+## 9\. DeepL Apps
+## 10\. DeepL Apps
 In addition to the translation service on our website, we also offer apps for Windows and macOS operating systems ("desktop apps"), as well as apps for iOS and Android ("mobile apps"), through which you can also translate texts.
+You can use the desktop apps in both the free version and the paid DeepL Pro version. The Android app is available in the free version. If you use the free version of DeepL in the apps, Section 3 of this Privacy Policy applies; if you use the paid DeepL Pro version, Sections 4 and 5 apply. As the desktop apps use the same interfaces for creating translations as the web-based service, also sections [6]() and [7]() of this privacy policy apply to the use of these apps.
+You can use the desktop apps in both the free version and the paid DeepL Pro version. The Android app is available in the free version. If you use the free version of DeepL in the apps, Section [3]() of this Privacy Policy applies; if you use the paid DeepL Pro version, Sections [5]() and [6]() apply. As the desktop apps use the same interfaces for creating translations as the web-based service, also sections [7]() and [8]() of this privacy policy apply to the use of these apps.
 When translating texts with our apps, for technical reasons - regardless of whether you use our paid or free service - your device will automatically transmit certain data. The following data which you can transmit to us, is stored:
 - Date and time of access
 - Version of the app
 The processing of this data is based on our legitimate interest in ensuring and improving the stability and functionality of our services, Art. 6 para. 1 sentence 1 lit. f) GDPR. This data is stored solely for technical reasons. Data relating to access is used for error analysis, ensuring system security, logging access to DeepL Pro and to improve our translation service. The full IP address of users using the free version of DeepL is stored for a maximum period of 14 days, which is also justified by our legitimate interest in achieving the listed purposes, Art. 6 para. 1 sentence 1 lit. f) GDPR. The full IP address of DeepL Pro users is stored for the duration of the contract on the basis of Art. 6 para. 1 sentence 1 lit. b) GDPR.
 If you use our mobile apps, it is also possible to have the entered text and the translation read aloud or to dictate the text to be translated yourself. The speech service installed on your device is used for this purpose. Please note that this may result in the transfer of the entered or spoken content to the provider of the speech service used by your device, possibly also to the USA. DeepL has no influence on this processing of your voice and audio data, therefore the privacy policy and terms of use of the speech service used by your device e.g. provided by Apple, Google or Samsung, but also those of other speech services that cannot be listed exhaustively, apply.
 No cookies are used in our mobile apps. However, a unique user ID (no cross-device ID) is used, which allows us to track, for example, the source and target language settings, how many characters are translated, whether the copy button is used, and if so, how it is used. The processing of this data is based on our legitimate interest (Art. 6 para. 1 sentence 1 lit. f) GDPR) to better understand the needs of our users and to be able to adapt the app according to customer requirements.
+## 10\. DeepL API Free
+## 11\. DeepL API Free
 In addition to the paid DeepL API Pro plan, we also offer a limited free version of our API (DeepL API Free). For further information, please see our [DeepL Pro Terms and Conditions](https://www.deepl.com/pro-license) and section [3]() on using the free version of DeepL.
+In order to use DeepL API Free, it is necessary to create a DeepL account (please see section [5.1]()). If you select the API Free option during the checkout process, further data, as specified in section [5.2](), will be collected. Although no costs are incurred when using DeepL API Free - subject to a (possible) upgrade - your payment data is collected in order to prevent improper use of API Free. Solely for this purpose, payment information is also passed on, in accordance with section [5.2](), to the payment service provider we have commissioned, Stripe Payments Europe Ltd.
+In order to use DeepL API Free, it is necessary to create a DeepL account (please see section [6.1]()). If you select the API Free option during the checkout process, further data, as specified in section [6.2](), will be collected. Although no costs are incurred when using DeepL API Free - subject to a (possible) upgrade - your payment data is collected in order to prevent improper use of API Free. Solely for this purpose, payment information is also passed on, in accordance with section [6.3](), to the payment service provider we have commissioned, Stripe Payments Europe Ltd.
 We process your data in order to perform the free-of-charge usage contract concluded between you and us on the basis of Art. 6 para. 1 sentence 1 lit. b) GDPR and on the basis of our legitimate interest in preventing misuse of the API Free, Art. 6 para. 1 sentence lit. f) GDPR.
+## 11\. Contacting our Sales or Support Team
+## 12\. Contacting our Sales or Support Team
 You have the possibility to contact us via various contact forms on our website. You can also contact us directly by email.
+### 11.1. Sales and Support Requests
+### 12.1. Sales and Support Requests
+If you would like to send us a sales enquiry in order to receive further information about our products and subscription plans or to start contract negotiations, you are welcome to use our sales contact form. In addition to your email address, you are required to provide your name and telephone number; all other information is optional. For the provision of our contact form, we use the HubSpot service (see section 12), where your request is pre-filtered and then forwarded to the ticket system of the provider Zendesk Inc. ("Zendesk"), 1019 Market Street, San Francisco, CA 94103, USA. We use Zendesk to process your enquiry and your further communication with us, we also use the service to manage our customer database. This may also involve the transfer of your contract 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. Further information on the handling of personal data at Zendesk and on compliance with the requirements of Art. 44 GDPR can be found [here](https://www.zendesk.de/company/privacy-and-data-protection/) and [here](https://www.zendesk.com/blog/update-privacy-shield-invalidation-european-court-justice/). We also use the Customer Relationship Management System (CRM) of Salesforce.com Germany GmbH, Erika-Mann-Str. 31, 80636 München, Deutschland ("Salesforce CRM") to manage our customer database, which includes our existing and potential customers, and to organize sales and communication processes. Furthermore, Salesforce CRM enables us to analyse our customer-related processes. We have concluded a data processing agreement with Salesforce and Salesforce is therefore only allowed to process the data according to our instructions and not for its own purposes. The customer data is stored on servers in the EU.
+If you would like to send us a sales enquiry in order to receive further information about our products and subscription plans or to start contract negotiations, you are welcome to use our sales contact form. In addition to your email address, you are required to provide your name and telephone number; all other information is optional. For the provision of our contact form, we use the HubSpot service (see section [13]()), where your request is pre-filtered and then forwarded to the ticket system of the provider Zendesk Inc. ("Zendesk"), 1019 Market Street, San Francisco, CA 94103, USA. We use Zendesk to process your enquiry and your further communication with us, we also use the service to manage our customer database. This may also involve the transfer of your contract 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. Further information on the handling of personal data at Zendesk and on compliance with the requirements of Art. 44 GDPR can be found [here](https://www.zendesk.de/company/privacy-and-data-protection/) and [here](https://www.zendesk.com/blog/update-privacy-shield-invalidation-european-court-justice/). We also use the Customer Relationship Management System (CRM) of Salesforce.com Germany GmbH, Erika-Mann-Str. 31, 80636 München, Deutschland ("Salesforce CRM") to manage our customer database, which includes our existing and potential customers, and to organize sales and communication processes. Furthermore, Salesforce CRM enables us to analyse our customer-related processes. We have concluded a data processing agreement with Salesforce and Salesforce is therefore only allowed to process the data according to our instructions and not for its own purposes. The customer data is stored on servers in the EU.
 If you contact our support team with questions about your contract and its implementation via our contact form, it is necessary to provide a valid email address so that we know who the inquiry comes from and can respond to it. We also use the aforementioned ticket system Zendesk to respond to your enquiry.
 For both support and sales enquiries including any subsequent correspondence , Art. 6 para. 1 sentence 1 lit. b) GDPR serves as the legal basis for the processing of your personal data, as the processing is necessary for the initiation of the contract or the conclusion and performance of our contract. Art. 6 para. 1 sentence 1 lit. b) 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 where this is required. The processing of your personal data as part of our customer database and the analyses of our customer-related processes is based on Art. 6 para. 1 sentence 1 lit. f) GDPR, as this is in our legitimate interest.
 If you have contacted our Support team via the contact form, it is possible that we will subsequently inquire by email 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.
+### 11.2. Privacy Requests
+### 12.2. Privacy Requests
+You also have the option of contacting privacy(at)deepl.com with questions or concerns about data protection at DeepL. We process your data in accordance with Art. 6 para. 1 sentence 1 lit. a) GDPR on the basis of your voluntarily given consent. We also use the Zendesk ticket system to respond to privacy enquiries, so please also note the above explanations in this regard under section [11.1]().
+You also have the option of contacting privacy(at)deepl.com with questions or concerns about data protection at DeepL. We process your data in accordance with Art. 6 para. 1 sentence 1 lit. a) GDPR on the basis of your voluntarily given consent. We also use the Zendesk ticket system to respond to privacy enquiries, so please also note the above explanations in this regard under section [12.1]().
+## 12\. DeepL Newsletter and Customer Satisfaction Surveys
+## 13\. DeepL Newsletter
+### 12.1. Product Emails
+### 13.1. Product Emails
+If you have signed up for DeepL Pro or DeepL API Free, we will occasionally send you emails with news on our products, such as the launch of new languages and new features as well as on related products and services. This will also include information and tips on how to get the most out of DeepL Pro. We are entitled to use the email address you provided when signing up for a DeepL Pro/DeepL Free API subscription in this way under the legal conditions of § 7 para. 3 of the German Act against Unfair Competition (UWG). Given our existing contractual relationship, it is also in our legitimate interest to inform you as set out above (Art. 6 para. 1 sentence 1 lit. f) GDPR). If you do not wish to receive such emails from us, you can object to the use of your email address for this purpose at any time by sending an email to support(at)deepl.com. Of course, each of our emails contain an unsubscribe link at the end. For sending the newsletter, we use a service provided by HubSpot, Inc. ("HubSpot"), for more information see [12.4]().
+If you have signed up for DeepL Pro or DeepL API Free, we will occasionally send you emails with news on our products, such as the launch of new languages and new features as well as on related products and services. This will also include information and tips on how to get the most out of DeepL Pro. We are entitled to use the email address you provided when signing up for a DeepL Pro/DeepL Free API subscription in this way under the legal conditions of § 7 para. 3 of the German Act against Unfair Competition (UWG). Given our existing contractual relationship, it is also in our legitimate interest to inform you as set out above (Art. 6 para. 1 sentence 1 lit. f) GDPR). If you do not wish to receive such emails from us, you can object to the use of your email address for this purpose at any time by sending an email to support(at)deepl.com. Of course, each of our emails contain an unsubscribe link at the end. For sending the newsletter, we use a service provided by HubSpot, Inc. ("HubSpot"), for more information see [13.3]().
+### 12.2. Marketing Emails
+### 13.2. Marketing Emails
+If you like to receive more detailed information about our company, products, services and promotions, you can sign up for our marketing newsletter. We may send you information about special offers, promotions and marketing campaigns and other news from DeepL from time to time. The processing of your data is based on your consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). You can withdraw your consent at any time with effect for the future by sending an email to support(at)deepl.com. Of course, our emails each contain an unsubscribe link at the end. We also use the HubSpot service to send the marketing newsletter, for more information please see [12.4]().
+If you like to receive more detailed information about our company, products, services and promotions, you can sign up for our marketing newsletter. We may send you information about special offers, promotions and marketing campaigns and other news from DeepL from time to time. The processing of your data is based on your consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). You can withdraw your consent at any time with effect for the future by sending an email to support(at)deepl.com. Of course, our emails each contain an unsubscribe link at the end. We also use the HubSpot service to send the marketing newsletter, for more information please see [13.3]().
+### 12.3. Customer Satisfaction Surveys
+### 13.3. Email Service Provider HubSpot
+From time to time, DeepL sends out customer satisfaction surveys via email to inquire about your satisfaction with our products. Participation in the surveys is voluntary and they can generally be answered anonymously, but you also have the option to voluntarily provide your name and/or email address. If you do so, we may contact you afterwards and ask if you would be willing to share your experience with us in a personal conversation.
+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.
+## 14\. User research and surveys
+### 14.1 User surveys
+Users are given the opportunity to participate in surveys via the web and app interface of our services. Participation in the surveys is voluntary and can be achieved, for example, via a pop-up found on the interface. The user may be redirected to a third party website (e.g. Qualtrics) to complete the survey.In order for us to properly analyse the survey results, we match your survey results with your product interaction that we collect when you use our DeepL products. This helps us to get better insights on how our users respond to our services, which help us to improve our DeepL product offering and services based on the collected survey information. Your personal data will not be collected or processed throughout the entire process. We won't ask you to enter any personal data when taking part in the survey. Furthermore, to collect your product interaction data we don't collect or process your IP-address. In order to obtain this data from you, we will assign you a user ID upon confirmation that you wish to participate in the survey. This user ID - in the form of a cookie - does not give away any personal data about the person behind the interaction data and is therefore anonymised.
+Your survey results and product interaction data (if any) will be stored and processed collectively by DeepL for up to 2 years.
+If personal data is nevertheless collected or processed in the aforementioned process - which we do not plan or assume from our side - we justify this via Art. 6 (1) sentence 1 lit. f) DSGVO, as this represents the least intrusion into the rights of the user in contrast to an opt-in and corresponds to the principle of data minimisation. You may withdraw your consent for the cookie at any time with effect for the future by deleting your browser cache.
+### 14.2. Customer Surveys
+From time to time, DeepL sends out customer surveys via email to inquire about your experience and/or satisfaction with our products. Participation in the surveys is voluntary and they can generally be answered anonymously, but you also have the option to voluntarily provide your name and/or email address. If you do so, we may contact you afterwards and ask if you would be willing to share your experience with us in a personal conversation.
 This processing of your data corresponds to our legitimate interests according to Art. 6 para. 1 sentence 1 lit. f) GDPR to improve our products and to further develop them according to our customer's wishes. If you voluntarily provide your name and/or email address in the survey, we justify the processing of your data via your consent pursuant to Art. 6 para. 1 sentence 1 lit. a) GDPR. You can revoke this consent at any time with effect for the future.
+#### 12.3.1 Typeform
+### 14.3 Typeform
 To conduct the customer satisfaction surveys, we use a service of Typeform SL, Carrer Bac de Roda, 163, local, 08018 Barcelona, Spain ("Typeform"), on whose platform the surveys are stored. Typeform uses different subcontractors, which are also partly located in third countries outside the EU. Therefore, in certain cases, there may be a transfer of your data to the USA. We have concluded a data processing agreement with Typeform and Typeform only processes the data in accordance with our instructions and not for its own purposes. You can find more information about Typeform's handling of personal data [here](https://admin.typeform.com/to/dwk6gt/).
+#### 12.3.2 Hotjar
+### 14.4 Qualtrics
+Furthermore, we use a survey tool of Hotjar Ltd., Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian's STJ 3141, Malta ("Hotjar"), on whose platform the surveys are stored. Hotjar uses different subcontractors, which are also partly located in third countries outside the EU.Therefore, in certain cases, there may be a transfer of your data to the USA. We have concluded a data processing agreement with Hotjar and Hotjar only processes the data in accordance with our instructions and not for its own purposes. You can find more information about Hotjar's handling of personal data [here](https://www.hotjar.com/legal/policies/privacy/).
+For the surveys we use a service of Qualtrics Ireland Limited, Costello House, 1 Clarendon Row, Dublin 2, DO2 TA43, Ireland ("Qualtrics"), on whose platform the surveys are stored. Access to the surveys is placed on the website by DeepL so that each user can freely decide whether to participate in the survey. Qualtrics uses different subcontractors, which are also partly located in third countries outside the EU. Therefore, in certain cases, there may be a transfer of your data to the USA. We have concluded a data processing agreement with Qualtrics and therefore Qualtrics may only process the data according to our instructions and not for its own purposes. Further information on the handling of personal data at Qualtrics can be found [here](https://www.qualtrics.com/privacy-statement/) and [here](https://www.qualtrics.com/support/survey-platform/getting-started/data-protection-privacy/).
+### 12.4. Email Service Provider HubSpot
+### 14.5 Hotjar
+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).
+Furthermore, we use a survey tool of Hotjar Ltd., Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian's STJ 3141, Malta ("Hotjar"), on whose platform the surveys are stored. Hotjar uses different subcontractors, which are also partly located in third countries outside the EU.Therefore, in certain cases, there may be a transfer of your data to the USA. We have concluded a data processing agreement with Hotjar and Hotjar only processes the data in accordance with our instructions and not for its own purposes. You can find more information about Hotjar's handling of personal data [here](https://www.hotjar.com/legal/policies/privacy/).
+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.
+## 15\. DeepL's Social Media Pages
+## 13\. DeepL's Social Media Pages
 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 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.
+In principle, you can assert your rights (see section [19]() 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
+## 16\. Webinars
+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.
+We offer webinars for our users and existing or prospective customers. The webinars are interactive events on the products we offer, conducted by our staff. External speakers may also be invited to the webinars. We point this out accordingly before registration.
+We use a service provided by Zoom Video Communications, Inc. ("Zoom"), 55 Almaden Blvd. Suite 600, San Jose, CA 95113, USA, on whose platform the webinars are held. Registration for our webinars takes place via a corresponding landing page of Zoom. We have concluded a data processing agreement with Zoom and Zoom may only process personal data according to our instructions and not for its own purposes. We would like to point out that if you access Zoom's website, Zoom is responsible for the personal data processed through your use of the website. If you have entered into a contractual relationship with Zoom, we have no influence on the personal data collected and processed in this context as part of our webinars. Further information on the handling of personal data at Zoom - in particular also in relation to webinars - can be found [here](https://explore.zoom.us/en/privacy/).
+In the event of registration for a webinar on a landing page provided by Zoom, we collect and process all personal data that you provide when registering for one of our webinars (first and last name, email address, company (optional), position (optional)). We process your data to fulfil the free participation contract concluded between you and us on the basis of Art. 6 para. 1 sentence 1 lit. b) GDPR. We store your data on this basis for the duration of the existence of our contractual relationship, i.e. until the conclusion of the webinar, and subsequently for the duration of the statutory retention periods where this is required. If you have a DeepL account and it is possible for us to assign the webinar registration to this account, the processing of your personal data in the context of our customer database and the analyses of our customer-related processes until the end of the webinar is based on Art. 6 para. 1 sentence 1 lit. f) GDPR, as this is in our legitimate interest to record the demand for webinars and in this context to improve the services for our customers. After completion of the webinar, we note in our customer database under your account that you participated in the webinar. The name and e-mail address given during registration will not be noted and - if they do not match the details in the DeepL account created - will be deleted by us after the webinar has ended. Should personal data be processed at all in this note in the customer database beyond the webinar, we base this on Art. 6 para. 1 sentence 1 lit. f) GDPR, as this is in our legitimate interest to specifically identify whether customers understand our products in order to provide them with support more quickly in individual cases, or in order to provide certain customers with extended webinars and training.
+When participating in a webinar and using Zoom, the following additional personal data is processed:
+- User information (This is data associated with the Zoom account and its authentication, e.g. first name, last name, display name, email address, password (unless Single Sign On (SSO) is used), profile picture, Zoom unique user ID);
+- Communication data (This is data that you independently enter, upload or share as part of the webinar and associated Zoom usage);
+- Meeting metadata and telemetry data (This technical data is, among other things, data relating to the use of the service, including when and how sessions were conducted (IP address, event logs, session information, etc.), as well as device and hardware information that Zoom needs to access in order for features such as camera, microphone, etc. to be operational in the context of participation).
+Please note that it is also possible to participate in the webinar without having a Zoom account. In this case, the collection and processing of data is limited to the minimum necessary to be able to maintain the service for you. We have chosen settings so that the collection and processing of the communication content generally takes place on servers in the European Union. As Zoom is based in the USA, we cannot exclude the possibility that data processing (in particular meeting metadata) may also take place in the USA when using the service. A collection and processing of your data through the use of Zoom takes place on the basis of Art. 6 para. 1 sentence 1 lit. b) GDPR (participation contract). We store the data collected and processed by Zoom on our behalf for the duration of the Zoom webinar and subsequently for the duration of the statutory retention periods, if this is required. We have no influence on the duration of the data processed by Zoom under its own responsibility. Please contact Zoom directly for information in this regard.
+Automated decision-making pursuant to Art. 22 GDPR does not take place.
+Please note that we may record Zoom webinars and publish them afterwards on our website or social media channels. Participants will not be visible or identifiable in these recordings. As participants can only ask written questions, they will not appear visually in the recording. The answer to the participant's question will be part of the webinar recording. If, contrary to expectations, personal data of the participants is visible during the recording, it will be made unrecognisable before publication. The recording and storage of the webinar is based on Art. 6 para. 1 sentence 1 lit. f) GDPR, as these processing operations are in our legitimate interest to improve the quality of our webinars. When the webinars are published, no further processing of personal data will take place, as we will make them unrecognisable beforehand - if they can be viewed at all.
+## 17\. 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 [7.2]() 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). 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).
+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, Edinburgh 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
+## 18\. 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
+## 19\. 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 withdraw your consent - Should you wish to revoke any previously granted consent, we will comply with your request. Revocation does not affect the permissibility of the processing of your data up to now.
 **In addition, you can object to the further processing of your data if we process your data based on our legitimate interest (Art. 6 para. 1 sentence 1 lit. f), Art. 21 GDPR). If we process your data for the purpose of direct advertising, you have a general right to object. If we do not process your data for advertising purposes, the objection must be based on your particular 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, email: [poststelle(at)ldi.nrw.de](mailto:poststelle@ldi.nrw.de).
+## 17\. Changes to the Privacy Policy
+## 20\. 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: October 2022
+Last update: December 2022