Privacy Policy

ARCHIVED 2024-08-04, DATE APPROXIMATE · VERSION 20240804_rev01 · COMPARED WITH 20240708_rev01

Full text changes — 20240708_rev01 to 20240804_rev01

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

 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, logins, number of translated or improved 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 (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 or improved 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. b) 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.
+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 of the subscription (e.g. number of translated characters and documents, last login date) with your employer or organization on request. Providing this data 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.
 ### 6.3 Processing of the Submitted Texts and Translations / Improvements
 We process the texts you submit to DeepL Pro and their translations or improvements only temporarily, insofar as this is necessary for the creation and transmission of the translation or improvement. The processing is therefore justified by Art. 6 para. 1 sentence 1 lit. b) GDPR. Your texts and the translations or improvements will - within the framework of the contractual agreements and as stated in section [4]() and [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 "saved translations" feature. In this case, texts selected by you, including translations, can be saved on DeepL servers and thus kept accessible at all times. When you use the "saved translations" feature in our apps, your texts and translations are stored locally.
 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.
 - 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 or improvement services. 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 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. 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/).
+## 9\. Cookies and Web Storage on deepl.com and Analysis of User Behavior
+## 9\. Use of Cookies and other Technologies on deepl.com and Analysis of User Behavior
+### 9.1 Use of Cookies and Web Storage on deepl.com
+### 9.1 Use of Cookies, Web Storage and other Technologies 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.
+- Necessary: These cookies or web storage objects are necessary for our website to work properly, to enable smooth navigation and access our most important functions. This includes essential security and accessibility features and preferences such as interface and translator language as well as the handling of the checkout process for DeepL Pro. 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: These cookies or web storage objects measure how our site is used. We use this information to improve our website and services. With these cookies we measure, for example, how often users return and which functions they use. 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.
+- Functional: These cookies or web storage objects enable us to provide you with enhanced functionality and personalization on our website. For example, we can personalize your experience based on which pages you visited. 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.
+- Marketing: These cookies and other technologies are used to deliver advertising more relevant to you and your interests. By selecting this category, you also consent to DeepL sending your data to third parties outside the EU (e.g., Google), including the sharing of hashed email addresses. In accordance with § 25 para. 1 TTDSG and Art. 6 para. 1 sentence 1 lit. a) GDPR, we only use these cookies, web storage objects and other technologies 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.
+The table below lists the different types of technologies 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 the consent you have given for the use of cookies, web storage objects and other technologies in the categories "Performance", "Functional" and "Marketing" or manage your settings at any time. You can do this by deactivating (or activating) the slide button in the top right-hand corner of the respective category in the table below.
+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 [13.1]()) and the marketing software from HubSpot (see explanatory notes, section [14]()) 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.
 ### 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. In case that users visit the website [https://developers.deepl.com](https://developers.deepl.com/) which is hosted by GitBook we use the services of Conva Ventures Inc. ("Conva Ventures" the corporation behind Fathom Analytics) to get basic insights about how our API documentation is being used. For the analysis, no cookie is set, and the analysis will only rely on the IP address and user agent of the user which will be hashed first. These pseudo-anonymized hashes will be anonymized after 24 hours. The data will be processed on servers in the USA. We have concluded a data processing agreement with Conva Ventures and Conva Ventures only processes the data in accordance with our instructions and not for its own purposes. You can find more information about Conva Ventures' handling of personal data [here](https://usefathom.com/blog/anonymization).
 Overview of the cookies and web storage objects used by DeepL:
 | Page views | IDpv | Description
 Stores the page ID of the pages accessed by the user, including a timestamp indicating when this access was last made. Based on this, corresponding information is displayed to the user.
  | TechnologyLocal storage | ExpiryPersistent Data | OwnerDeepL |
+### Comfort
+### Functional
 | Context | ID | Description | Technology | Expiry | Owner |
 | --- | --- | --- | --- | --- | --- |
 | Translator | IDuserRecommendations | Description
 Used to personalise the users experience.
 | Context | ID | Description | Technology | Expiry | Owner |
 | --- | --- | --- | --- | --- | --- |
 | Conversion Tracking | ID | Description
 Records and evaluates conversions from DeepL's LinkedIn advertising campaigns
  | TechnologyTracking Pixel | ExpiryPersistent Data | OwnerLinkedIn |
+| Conversion Tracking | ID\- | Description
+Records and evaluates conversions from DeepL's Google advertising campaigns.
+ | TechnologyServer-to-server tracking | ExpiryOngoing until consent is revoked | OwnerGoogle |
 ## 10\. Speech-to-text function for web
 For the web version of our DeepL Translator, we also offer a speech-to-text function, where the text to be translated can be dictated yourself. The recorded text is transcribed solely within DeepL's internal infrastructure.
 When using DeepL Pro, the recordings and the transcriptions 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 the recordings, their transcriptions and the translations will be deleted. This does not apply when using the speech-to-text function as part of the free version of DeepL translator or the DeepL account, where the recordings, their transcriptions and the translations are stored and processed for a limited period of time to train and improve our neural networks and translation algorithms (please see also section 3 of this privacy policy). The user will be informed of this before using the speech-to-text function for the first time and asked to give their consent. The consent does not cover the recording of the voices of third parties, which means, you are not permitted to record the voices of third parties. You can withdraw the consent you have given at any time with effect for the future. You do this by deleting the corresponding cookie set by the consent. For further information and explanation of the withdrawal process, please click [here](https://support.deepl.com/hc/articles/10422503124636).
 - 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. You can contact the company through duo(at)stripe.com.
 - Secure the use of website: Our website uses services of Cloudflare, Inc, 101 Townsend St, San Francisco, CA 94107, USA ("Cloudflare"). 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. 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). You can contact the company through privacyquestions(at)cloudflare.com.
 - Support enquires: If you send us a support enquiry, your request. Is 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. You can contact the company through privacy(at)zendesk.com.
 - Manage customer database: We 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. You can contact the company through privacy(at)salesforce.com.
 - Send newsletters and other marketing emails: For sending the newsletters and other marketing emails, 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. You can contact the company through privacy(at)hubspot.com.
 - Conduct the customer satisfaction surveys: 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. You can contact the company through GDPR(at)typeform.com.
+- Conduct surveys: 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. 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. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#4d3d3f243b2c2e3460293e3f0d3c382c21393f242e3e632e2220).
+- Conduct surveys: 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. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#badecad5fad2d5ced0dbc894d9d5d7)
+- Conduct interviews: We use a service provided by UserTesting, Inc. 144 Townsend Street, San Francisco, CA 94107 USA to conduct interviews with you. UserTes ting uses different subcontractors - such as Zoom - 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. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#e090928996818399a09593859294859394898e87ce838f8d).
+- Host Webinars: 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. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#3747455e4156544e774d58585a194244).
+- Job applications: In order to process your application data, it will be forwarded to the service provider Localyze UG (haftungsbeschränkt), Bäckerbreitergang 28, 20355 Hamburg, which carries out the Pre-Check on behalf of DeepL. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#d0b2bfb8bfb5a2b4b5bebdb4b5bca5beb790b4b1a4b1b7a5b1a2b4feb4b5).
+- Job applications: 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. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#89e1ece5e5e6c9fbeceafbfce0fdececa7eae6e4).
+- Job applications: 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. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#1d6f747e765d7e7279786e6e78337e7270)
+- Conduct surveys: 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. 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. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#fd8d8f948b9c9e84d0998e8fbd8c889c91898f949e8ed39e9290).
+- Conduct surveys: 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. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#6b0f1b042b03041f010a1945080406)
+- Conduct interviews: We use a service provided by UserTesting, Inc. 144 Townsend Street, San Francisco, CA 94107 USA to conduct interviews with you. UserTes ting uses different subcontractors - such as Zoom - 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. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#5e2e2c37283f3d271e2b2d3b2c2a3b2d2a373039703d3133).
+- Host Webinars: 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. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#e797958e9186849ea79d88888ac99294).
+- Job applications: In order to process your application data, it will be forwarded to the service provider Localyze UG (haftungsbeschränkt), Bäckerbreitergang 28, 20355 Hamburg, which carries out the Pre-Check on behalf of DeepL. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#f5979a9d9a908791909b98919099809b92b5919481949280948791db9190).
+- Job applications: 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. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#3c54595050537c4e595f4e4955485959125f5351).
+- Job applications: 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. You can contact the company through [\[email protected\]](https://deepl.com/cdn-cgi/l/email-protection#84f6ede7efc4e7ebe0e1f7f7e1aae7ebe9)
 ## 22\. 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 2024