| 11 | 11 | - [6.3 Processors involved in the DeepL Pro checkout process]() |
| 12 | 12 | - [6.4 Processing of usage data]() |
| 13 | 13 | - [6.5 Processing of the Submitted Texts and Translations / Improvements]() |
| 14 | 14 | - [7\. Translation of Documents]() |
| 15 | 15 | - [7.1 Translation of Documents with DeepL Translator and DeepL Pro]() |
| 16 | 16 | - [7.2 Temporary Storage of Metadata when Translating Documents]() |
| 17 | | - [8\. Automatic Collection of Data via Website Access]() |
| 18 | | - [9\. Use of Cookies and other Technologies on deepl.com]() |
| 19 | | - [9.1 Use of Cookies, Web Storage and other Technologies on deepl.com]() |
| 17 | - [8.1 Translation Memories]() |
| 18 | - [8.2 Translation Memory Generation]() |
| 19 | - [8.3 Adaptive Translation]() |
| 20 | - [9\. Automatic Collection of Data via Website Access]() |
| 21 | - [10\. Use of Cookies and other Technologies on deepl.com]() |
| 22 | - [10.1 Use of Cookies, Web Storage and other Technologies on deepl.com]() |
| 20 | 23 | - [Necessary]() |
| 21 | 24 | - [Performance]() |
| 22 | 25 | - [Functional]() |
| 23 | 26 | - [Marketing]() |
| 24 | | - [10\. Analysis of User Behaviour]() |
| 25 | | - [11\. DeepL Apps]() |
| 26 | | - [12\. DeepL API Free]() |
| 27 | | - [13\. Connecting with our Customer Team, including via our ChatBot]() |
| 28 | | - [13.1 Recording of dialer and Zoom calls]() |
| 29 | | - [13.2 Sales and Support Requests]() |
| 30 | | - [13.3 Privacy Requests]() |
| 31 | | - [14\. DeepL Newsletter]() |
| 32 | | - [14.1 Product Newsletter]() |
| 33 | | - [14.2 Marketing Newsletter and other marketing communication]() |
| 34 | | - [14.3 Email Service Provider HubSpot]() |
| 35 | | - [15\. User research and surveys]() |
| 36 | | - [15.1 User surveys]() |
| 37 | | - [15.2 Customer Surveys]() |
| 38 | | - [15.3 Typeform]() |
| 39 | | - [15.4 Qualtrics]() |
| 40 | | - [15.5 Hotjar]() |
| 41 | | - [15.6 UserTesting]() |
| 42 | | - [15.7 Ethnio]() |
| 43 | | - [16\. DeepL's Social Media Pages]() |
| 44 | | - [17\. DeepL Bridges (DeepL Community Platform)]() |
| 45 | | - [17.1 Registration]() |
| 46 | | - [17.2 Information published on Platform]() |
| 47 | | - [17.3 Notifications]() |
| 48 | | - [17.4 Content moderation]() |
| 49 | | - [17.5 Cookies]() |
| 50 | | - [17.6 Legal basis]() |
| 51 | | - [17.7 Account Deletion and Data Retention]() |
| 52 | | - [17.8 Bettermode as Processor]() |
| 53 | | - [18\. Webinars]() |
| 54 | | - [19\. Job Applications]() |
| 55 | | - [20\. Data Security]() |
| 56 | | - [20\. Your Rights]() |
| 57 | | - [22\. Special provisions for users from South Korea]() |
| 58 | | - [22.1 Contact and DeepL Chief Privacy Office (CPO)]() |
| 59 | | - [22.2 Additional information for usage of DeepL's free service]() |
| 60 | | - [22.3 Data Deletion and Retention Periods]() |
| 61 | | - [22.4 Data Security and Pseudonymisation]() |
| 62 | | - [22.5 Rights of Data Subject and Legal Representative]() |
| 63 | | - [22.6 Children's Privacy]() |
| 64 | | - [22.7 Overseas Transfer and Delegation of Personal Data Processing]() |
| 65 | | - [23\. Changes to the Privacy Policy]() |
| 27 | - [11\. Analysis of User Behaviour]() |
| 28 | - [12\. DeepL Apps]() |
| 29 | - [13\. DeepL API Free]() |
| 30 | - [14\. Connecting with our Customer Team, including via our ChatBot]() |
| 31 | - [14.1 Recording and Transcription of calls and meetings]() |
| 32 | - [14.2 Sales and Support Requests]() |
| 33 | - [14.3 Privacy Requests]() |
| 34 | - [15\. DeepL Newsletter]() |
| 35 | - [15.1 Product Newsletter]() |
| 36 | - [15.2 Marketing Newsletter and other marketing communication]() |
| 37 | - [15.3 Email Service Provider HubSpot]() |
| 38 | - [16\. User research and surveys]() |
| 39 | - [16.1 User surveys]() |
| 40 | - [16.2 Customer Surveys]() |
| 41 | - [16.3 Typeform]() |
| 42 | - [16.4 Qualtrics]() |
| 43 | - [16.5 Hotjar]() |
| 44 | - [16.6 UserTesting]() |
| 45 | - [16.7 Great Question]() |
| 46 | - [17\. DeepL's Social Media Pages]() |
| 47 | - [18\. DeepL Bridges (DeepL Community Platform)]() |
| 48 | - [18.1 Registration]() |
| 49 | - [18.2 Information published on Platform]() |
| 50 | - [18.3 Notifications]() |
| 51 | - [18.4 Content moderation]() |
| 52 | - [18.5 Cookies]() |
| 53 | - [18.6 Legal basis]() |
| 54 | - [18.7 Account Deletion and Data Retention]() |
| 55 | - [18.8 Bettermode as Processor]() |
| 56 | - [19\. Webinars]() |
| 57 | - [20\. Job Applications]() |
| 58 | - [21\. DeepL Partner Program]() |
| 59 | - [22\. Data Security]() |
| 60 | - [23\. Your Rights]() |
| 61 | - [24\. Special provisions for users from South Korea]() |
| 62 | - [24.1 Contact and DeepL Chief Privacy Office (CPO)]() |
| 63 | - [24.2 Additional information for usage of DeepL's free service]() |
| 64 | - [24.3 Data Deletion and Retention Periods]() |
| 65 | - [24.4 Data Security and Pseudonymisation]() |
| 66 | - [24.5 Rights of Data Subject and Legal Representative]() |
| 67 | - [24.6 Children's Privacy]() |
| 68 | - [24.7 Overseas Transfer and Delegation of Personal Data Processing]() |
| 69 | - [25\. Changes to the Privacy Policy]() |
| 66 | 70 | |
| 67 | 71 | Protecting your privacy and personal data is very important to us. We therefore only use your personal data within the scope of legal regulations, in particular the General Data Protection Regulation ("GDPR") and the German Federal Data Protection Act ("BDSG"). With this privacy policy, we would like to inform you - regardless of whether you set up a DeepL account, use our DeepL Pro subscriptions, our various apps or visit our website - about the nature, scope and purposes of the collection, use and processing of your personal data by DeepL. |
| 68 | 72 | |
| 69 | 73 | ## 1\. Data controller / Contact / Data Protection Officer |
| 70 | 74 | |
| 71 | 75 | Where we reference DeepL in this privacy notice we refer to the company in the group that acts as controller of, and is responsible for processing your personal data. |
| 72 | 76 | |
| 73 | 77 | The DeepL group is made up of different legal entities, which are: |
| 74 | 78 | |
| 75 | | 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 [5]()) 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 [13](). |
| 79 | 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 [5]()) 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 [14](). |
| 76 | 80 | |
| 77 | 81 | 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. |
| 78 | 82 | |
| 79 | 83 | ## 2\. Scope of Data Protection |
| 80 | 84 | |
| 81 | 85 | 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. |
| 259 | 279 | 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 or improvement services. 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. |
| 260 | 280 | |
| 261 | 281 | If you use our mobile apps, it is also possible to have the entered text and the translation or improvement read aloud or to dictate the text to be translated or improved 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. |
| 262 | 282 | |
| 263 | 283 | 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 or improved, 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. |
| 264 | 284 | |
| 265 | | ## 12\. DeepL API Free |
| 285 | ## 13\. DeepL API Free |
| 266 | 286 | |
| 267 | 287 | 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/en/pro-license) and section [3]() on using the free version of DeepL. |
| 268 | 288 | |
| 269 | 289 | 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. |
| 270 | 290 | |
| 271 | 291 | 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. |
| 272 | 292 | |
| 273 | | ## 13\. Connecting with our Customer Team, including via our ChatBot |
| 293 | ## 14\. Connecting with our Customer Team, including via our ChatBot |
| 274 | 294 | |
| 275 | 295 | You have various possibilities to connect with us, including via contact forms on our website, having calls with our customer team as well as by using our chatbot. You can also contact us directly by email. |
| 276 | 296 | |
| 277 | 297 | We will process your personal data that you provide to us as part of these communications. This may include your name, email address and any other personal data you disclose to us. |
| 278 | 298 | |
| 279 | | ### 13.1 Recording of dialer and Zoom calls |
| 299 | ### 14.1 Recording **and Transcription of calls and meetings** |
| 280 | 300 | |
| 281 | 301 | Our customer team is conducting dialer and Zoom calls with prospects and customers to provide them with general information about DeepL's services and to advise them according to their needs. In order to continue to provide excellent customer service and to continuously improve it, we may record and transcribe the dialer and zoom calls with prospects and customers in certain countries with their consent, using the Salesloft platform provided by Salesloft, Inc., 1180 West Peachtree St NW Suite 2400, Atlanta, GA 30309. We have concluded a data processing agreement with Salesloft and Salesloft is therefore only allowed to process the data according to our instructions and not for its own purposes. |
| 282 | 302 | |
| 283 | | Recordings of the calls, including transcriptions of these, are used for internal training and coaching as well as for documentation purposes. At the beginning of each dialer call, an automated message will inform the called party that the call is being recorded. If you do not wish to participate in a recorded call, you can end the call at any time. For Zoom calls, the Zoom invitation will inform you that the call is being recorded and that you can opt out when you join the call. |
| 303 | We may also create an automated transcript and summary of video and telephone meetings for note-taking purposes, with the consent of the participants, using the Granola service provided by Granola, Inc.- 1151 Walker Rd Ste 417, Dover, DE 19904, United States. We have concluded a data processing agreement with Granola and Granola is therefore only allowed to process the data according to our instructions and not for its own purposes. |
| 284 | 304 | |
| 285 | | All recorded calls, including transcriptions, will be securely stored for a period of two years from the date of the call. After this period, the recordings will be automatically deleted from our systems. You also have the rights mentioned in section 21. |
| 305 | Recordings of the calls and meetings, including transcriptions of these, are used for internal training and coaching as well as for documentation purposes. At the beginning of each call or meeting, a disclaimer will inform the parties that the call is being recorded and/or transcribed. If you do not wish to participate in a recorded or transcribed call, you can end the call or ask the team to switch off the recording or transcription at any time. For Zoom calls, the Zoom invitation will inform you that the call is being recorded and that you can opt out when you join the call. |
| 286 | 306 | |
| 287 | | ### 13.2 Sales and Support Requests |
| 307 | All recorded calls, including transcriptions, will be securely stored for a period of two years from the date of the call. After this period, the recordings will be automatically deleted from our systems. You also have the rights mentioned in section 23. |
| 288 | 308 | |
| 309 | ### 14.2 Sales and Support Requests |
| 310 | |
| 289 | 311 | 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 forms. 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 forms, we use the HubSpot service (see section 14). |
| 290 | 312 | |
| 291 | 313 | 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. |
| 292 | 314 | |
| 293 | 315 | If you contact our support team with questions about your subscription, for example 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 use the ticket system provided by Zendesk Inc. ("Zendesk"), 1019 Market Street, San Francisco, CA 94103, 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 can be found [here](https://www.zendesk.de/company/agreements-and-terms/privacy-notice/). |
| 294 | 316 | |
| 295 | 317 | In addition to contacting our support team, you may also interact with our internal API ChatBot.To provide you with accurate and relevant support, this ChatBot accesses your log-in status, subscription details, and the content of your chat messages. We do this as necessary for our legitimate interests to address your support inquiries, improve the quality of our automated assistance, and (as required) to automatically create a support ticket for a human agent. |
| 296 | 318 | |
| 297 | 319 | 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. |
| 298 | 320 | |
| 299 | 321 | 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. |
| 300 | 322 | |
| 301 | | ### 13.3 Privacy Requests |
| 323 | ### 14.3 Privacy Requests |
| 302 | 324 | |
| 303 | | 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 [13.1](). |
| 325 | 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 14.1. |
| 304 | 326 | |
| 305 | | ## 14\. DeepL Newsletter |
| 327 | ## 15. DeepL Newsletter |
| 306 | 328 | |
| 307 | | ### 14.1 Product Newsletter |
| 329 | ### 15.1 Product Newsletter |
| 308 | 330 | |
| 309 | | If you have signed up for a DeepL account, 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 account, 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 [14.3](). |
| 331 | If you have signed up for a DeepL account, 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 account, 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 [1]()5.3. |
| 310 | 332 | |
| 311 | | ### 14.2 Marketing Newsletter and other marketing communication |
| 333 | ### 15.2 Marketing Newsletter and other marketing communication |
| 312 | 334 | |
| 313 | | If you would like to receive more detailed information about our company, products, services and promotions, you can sign up for our marketing newsletter or you can agree to receiving marketing communication in certain other contexts. We may send you information, within the scope of your consent, about offers, special offers, promotions and marketing campaigns and other news from DeepL from time to time or get in touch with you to discuss specific products and services. 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 emails, for more information please see [14.3](). |
| 335 | If you would like to receive more detailed information about our company, products, services and promotions, you can sign up for our marketing newsletter or you can agree to receiving marketing communication in certain other contexts. We may send you information, within the scope of your consent, about offers, special offers, promotions and marketing campaigns and other news from DeepL from time to time or get in touch with you to discuss specific products and services. 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 emails, for more information please see 15.3. |
| 314 | 336 | |
| 315 | 337 | Note to US Individuals: We may also send you marketing communications and newsletters and offers and promotions if you have agreed to send your information to DeepL, such as via Quora. In such a case, we rely on your agreement to send us your information as establishing a relationship with us and your consent to such marketing. You can withdraw your consent at any time with effect for the future by using the unsubscribe link at the end of our emails. |
| 316 | 338 | |
| 317 | | ### 14.3 Email Service Provider HubSpot |
| 339 | ### 15.3 Email Service Provider HubSpot |
| 318 | 340 | |
| 319 | 341 | 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. 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). |
| 320 | 342 | |
| 321 | 343 | 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. |
| 322 | 344 | |
| 323 | | ## 15\. User research and surveys |
| 345 | ## 16\. User research and surveys |
| 324 | 346 | |
| 325 | | ### 15.1 User surveys |
| 347 | ### 16.1 User surveys |
| 326 | 348 | |
| 327 | 349 | 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. |
| 328 | 350 | |
| 329 | 351 | In order for us to properly analyse the survey results, we match your survey results with data on how you interact with and use our services using parameters that are appended to the survey link such as your accountID. 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. We will only do this where you have provided us with your consent to do so, which we will collect when you submit the survey form. You may withdraw your consent for the cookie at any time with effect for the future by sending an email to privacy(at)deepl.com. |
| 330 | 352 | |
| 331 | 353 | Your survey results will be stored and processed collectively by DeepL for up to 5 years. |
| 332 | 354 | |
| 333 | 355 | Please note, that we process data on how you interact with and use our services as necessary for our legitimate interests to understand how our customers use our products. |
| 334 | 356 | |
| 335 | | ### 15.2 Customer Surveys |
| 357 | ### 16.2 Customer Surveys |
| 336 | 358 | |
| 337 | 359 | We want to encourage customers to share their experiences with using our products. DeepL may therefore reach out to you occasionally, via email or other communication channels, to ask about your experience and/or satisfaction with our products. Participation in these surveys is voluntary, and most surveys can be answered anonymously. However, in some instances you may be asked to provide your name and/or email address, either optionally or as a requirement for completing the survey. If you provide us with your email, we may contact you afterwards (e.g., to invite you to participate in research studies or to share your experience in a call with our team). |
| 338 | 360 | |
| 339 | 361 | The 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 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. |
| 340 | 362 | |
| 341 | | ### 15.3 Typeform |
| 363 | ### 16.3 Typeform |
| 342 | 364 | |
| 343 | 365 | 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/). |
| 344 | 366 | |
| 345 | | ### 15.4 Qualtrics |
| 367 | ### 16.4 Qualtrics |
| 346 | 368 | |
| 347 | 369 | 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/). |
| 348 | 370 | |
| 349 | | ### 15.5 Hotjar |
| 371 | ### 16.5 Hotjar |
| 350 | 372 | |
| 351 | 373 | 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/). |
| 352 | 374 | |
| 353 | | ### 15.6 UserTesting |
| 375 | ### 16.6 UserTesting |
| 354 | 376 | |
| 355 | 377 | We also use a service provided by UserTesting, Inc. 144 Townsend Street, San Francisco, CA 94107 USA to conduct interviews with you. As a user (Contributor) of UserTesting, you can register for our interviews on UserTesting's platform. We also contact selected customers to make them aware of the interviews and invite them to attend. The interviews are recorded with images and sound and stored by us for two years on the UserTesting platform. We process your data on the basis of your given 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 privacy(at)deepl.com. Please state the exact day and, if possible, the time of the interview. We have concluded a data processing agreement with UserTesting and UserTesting may only process the data according to our instructions and not for its own purposes. UserTesting 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. Further information on the handling of personal data at UserTesting can be found [here](https://www.usertesting.com/privacy-center/gdpr-policy) and [here](https://www.usertesting.com/privacy-center/terms-of-service-contributor). |
| 356 | 378 | |
| 357 | | ### 15.7 Ethnio |
| 379 | ### 16.7 Great Question |
| 358 | 380 | |
| 359 | | We use a service provided by Ethnio Inc, 1909 Roselia Ave, Los Angeles CA 90027, USA, ("Ethnio") to store contact details of participants who signed up to our internal panel for the purpose of inviting them to participate in studies and to incentivize our research studies. Ethnio uses different subcontractors, which are also located in the USA. We have concluded a data processing agreement with Ethnio and Ethnio only processes the data in accordance with our instructions and not for its own purposes. You can find more information about Ethnio's handling of personal data [here](https://ethn.io/gdpr). |
| 381 | We use a service provided by Great Question, Inc., 418 45th Street, Oakland, CA 94609, USA to store contact details of participants who signed up to our internal panel for the purpose of inviting them to participate in studies and to incentivize our research studies. Great Question uses different subcontractors, which are also located in the USA. We have concluded a data processing agreement with Great Question and Great Question only processes the data in accordance with our instructions and not for its own purposes. You can find more information about Great Question's handling of personal data [here](https://greatquestion.co/about/privacy). |
| 360 | 382 | |
| 361 | | ## 16\. DeepL's Social Media Pages |
| 383 | ## 17\. DeepL's Social Media Pages |
| 362 | 384 | |
| 363 | 385 | 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). |
| 364 | 386 | |
| 365 | 387 | 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. |
| 366 | 388 | |
| 367 | 389 | In addition, we use the LinkedIn image pixel to record and evaluate conversions from our LinkedIn advertising campaigns. Conversions mean whether a user is successfully led to our website via our LinkedIn advertising campaign. Furthermore, user interactions - i.e., individual steps taken by the user on our website - are to be recorded and tracked via conversions. The LinkedIn image pixel is embedded on certain pages of our website and provides feedback to LinkedIn if a conversion has taken place. In doing so, LinkedIn processes the user's IP address as well as the presence of a cookie set by LinkedIn, which provides conclusions about the conversion. The processing of your personal data is based on your consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). The consent is given via the cookie settings. You can revoke your consent at any time with effect for the future by revoking the consent for the "Marketing" cookie category or deleting your browser cache. |
| 368 | 390 | |
| 369 | 391 | 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). |
| 370 | 392 | |
| 371 | | In principle, you can assert your rights (see section [21]() 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. |
| 393 | In principle, you can assert your rights (see section 23 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. |
| 372 | 394 | |
| 373 | | ## 17\. DeepL Bridges (DeepL Community Platform) |
| 395 | ## 18\. DeepL Bridges (DeepL Community Platform) |
| 374 | 396 | |
| 375 | | ### 17.1 Registration |
| 397 | ### 18.1 Registration |
| 376 | 398 | |
| 377 | 399 | If you choose to participate in the DeepL online community platform known as "DeepL Bridges" (the "Platform"), you must first have an existing DeepL account. You must use the credentials for your DeepL account to sign in to the Platform. We will use your first name and name as well as the email address used for the respective DeepL account for your Platform account. |
| 378 | 400 | |
| 379 | | ### 17.2 Information published on Platform |
| 401 | ### 18.2 Information published on Platform |
| 380 | 402 | |
| 381 | 403 | On the Platform, we will publish and make available your name (not your email address) together with any optional account or profile information (except for information that you designate as non-public) that you add on the Platform. We will also publish and make available any content you post on the Platform (such as posts, comments, votes). The Platform will not be made public in the early access phase. |
| 382 | 404 | |
| 383 | | ### 17.3 Notifications |
| 405 | ### 18.3 Notifications |
| 384 | 406 | |
| 385 | 407 | We will use your email address to send you notifications according to your settings. You can manage your notification settings at any time in your Platform account settings. |
| 386 | 408 | |
| 387 | | ### 17.4 Content moderation |
| 409 | ### 18.4 Content moderation |
| 388 | 410 | |
| 389 | 411 | We moderate content on the Platform and this means we review and process any content flagged to us to the extent required to comply with our legal obligations. Furthermore, we use your content and personal data for the purpose of identifying malicious content. |
| 390 | 412 | |
| 391 | | ### 17.5 Cookies |
| 413 | ### 18.5 Cookies |
| 392 | 414 | |
| 393 | 415 | We are using cookies for your login to our community and to store your preferences. These cookies are strictly necessary to provide you with our service. Any other cookies which are not strictly necessary will only be used if you consent to this. |
| 394 | 416 | |
| 395 | | ### 17.6 Legal basis |
| 417 | ### 18.6 Legal basis |
| 396 | 418 | |
| 397 | 419 | We will process your personal data as necessary to provide you with our community as set out in our terms and conditions for our community (Art. 6 para. 1 sentence 1 lit. b) GDPR) and as required to comply with our legal obligations in connection with the community, such as content moderation (Art. 6 para. 1 sentence 1 lit. c) GDPR). When we are using content for the purpose of spam protection and security measures, we process personal data based on our legitimate interest in ensuring the security of our community (Art. 6 para. 1 sentence 1 lit. f) GDPR). We use cookies based on Section 25 (1) and (2) TDDDG. |
| 398 | 420 | |
| 399 | | ### 17.7 Account Deletion and Data Retention |
| 421 | ### 18.7 Account Deletion and Data Retention |
| 400 | 422 | |
| 401 | 423 | If you would like to delete your Platform account, including the deletion of your content, please reach out to team@deepl-bridges.com. Please also note that the deletion of your Platform account will not impact or delete your separate DeepL account. |
| 402 | 424 | |
| 403 | | ### 17.8 Bettermode as Processor |
| 425 | ### 18.8 Bettermode as Processor |
| 404 | 426 | |
| 405 | 427 | We provide our Platform using Bettermode, a software provided by Bettermode Inc. We have concluded a data processing agreement with Bettermode and Bettermode may only process the data according to our instructions and not for its own purposes. Your data will be stored within the EU. Bettermode, Inc. is located in Canada. Any data transfers will be carried out on the basis of the EU Commission's adequacy decision for Canada. |
| 406 | 428 | |
| 407 | | ## 18\. Webinars |
| 429 | ## 19\. Webinars |
| 408 | 430 | |
| 409 | 431 | 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. |
| 410 | 432 | |
| 411 | 433 | 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/). |
| 412 | 434 | |
| 413 | 435 | 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. |
| 421 | 443 | 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. |
| 422 | 444 | |
| 423 | 445 | Automated decision-making pursuant to Art. 22 GDPR does not take place. |
| 424 | 446 | |
| 425 | 447 | 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. |
| 426 | 448 | |
| 427 | | ## 19\. Job Applications |
| 449 | ## 20. Job Applications |
| 428 | 450 | |
| 429 | 451 | We offer you the opportunity to apply for a position at DeepL via our [career page](https://www.deepl.com/en/careers). Please find further information on how we process candidate personal data in our [privacy notice for candidates](https://www.deepl.com/en/privacy-notice-candidates). |
| 430 | 452 | |
| 431 | | ## 20\. Data Security |
| 453 | ## 21\. DeepL Partner Program |
| 432 | 454 | |
| 433 | | 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. |
| 455 | DeepL uses a [Partner Relationship Management (PRM) platform](http://partners.deepl.com/) to administer its Partner Program, which includes resellers, distributors and other strategic partners. Through this platform we process the business contact details, first name, surname, email address and telephone number of our Partners, of DeepL's existing and prospective end customers, and of DeepL employees involved in partner activities, in each case in their professional capacity. |
| 434 | 456 | |
| 435 | | ## 20\. Your Rights |
| 457 | We use this data to manage and register partner deals, coordinate joint sales efforts with Partners to reach end customers, provide Partners with enablement resources and program benefits, and otherwise operate and improve the Partner Program. We process this data on the basis of our legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f) GDPR in efficiently running our partner ecosystem and growing revenue through partner-sourced sales. We do not process any special categories of personal data in connection with this activity. |
| 436 | 458 | |
| 437 | | 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. |
| 459 | The PRM Platform is hosted by Impartner, Inc., 10619 S Jordan Gateway, Suite 200, South Jordan, UT 84095, USA. Impartner may analyse website traffic in this context in order to understand the use of and optimise the portal, and may process information relating to your visit, including your IP address, for this purpose. You can find more information on Impartner's handling of personal data [here](https://impartner.com/privacy-policy/). |
| 438 | 460 | |
| 439 | | - 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. |
| 440 | | - Right to rectification - If any of the data we have stored is incorrect, we would certainly be happy to correct it. |
| 441 | | - Right to erasure - Should you wish your personal data to be deleted, we will comply with your request as far as legally possible. |
| 442 | | - Right to restriction of processing - Should you wish to restrict use, we will comply with your request as far as legally possible. |
| 443 | | - 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. |
| 461 | ## 22\. Data Security |
| 444 | 462 | |
| 445 | | **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.** |
| 446 | | |
| 447 | | UK residents can make a complaint to us via [privacy@deepl.com](mailto:privacy@deepl.com). We will acknowledge your complaint within 30 days and keep you informed throughout. You also have the right to complain to the regulator about the DeepL's processing activities and compliance under applicable data protection legislation. Where you are based in: |
| 448 | | |
| 449 | | - **Germany**, you can contact the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen, at (i) Kavalleriestraße 2 - 4, 40213 Düsseldorf; or (ii) poststelle@ldi.nrw.de; |
| 450 | | - **Other EU member states**, you may contact your local supervisory authority - a full list of supervisory authorities in the EU can be found [here](https://www.edpb.europa.eu/about-edpb/about-edpb/members_en); or |
| 451 | | - **UK**, you can contact the Information Commissioner's Officer ("ICO") and you can make your complaint via the ICO's website [here](https://ico.org.uk/make-a-complaint/). |
| 452 | | |
| 453 | | ## 22\. Special provisions for users from South Korea |
| 454 | | |
| 455 | | ### 22.1 Contact and DeepL Chief Privacy Office (CPO) |
| 456 | | |
| 457 | | If you have any specific questions or concerns about privacy and data protection in South Korea, also with regard to previous versions of this privacy policy, please contact the privacy team of DeepL at privacy(at)deepl.com. |
| 458 | | |
| 459 | | ### 22.2 Additional information for usage of DeepL's free service |
| 460 | | |
| 461 | | In addition to section 3, please note that if you enter personal data when using DeepL Translator / Write in the free version contrary to the terms of use, this data may be checked by a human. |
| 462 | | |
| 463 | | ### 22.3 Data Deletion and Retention Periods |
| 464 | | |
| 465 | | As described above, we will process your data for as long as is necessary for the stated purpose and if applicable, to the extent that you have consented to. Subsequently, we will delete your personal data without undue delay. We will permanently destroy any personal data saved in electronic format in a way that it cannot be restored and recovered. Personal information printed on paper will be destroyed by shredding thereof. |
| 466 | | |
| 467 | | However, as outlined above in section 6.2, DeepL is obliged to retain certain personal data of users as required by applicable laws. Relevant laws under Korean law include, in particular, the Act on the Consumer Protection in Electronic Commerce (Article 6) which provides for the retention of data on contract as well as withdrawals and revocations thereof for 5 years, data on the provision of services for 5 years and data on consumer complaints or consumer disputes for 3 years. The Protection of Communications Secrets Act provides in Article 15-2 to retain records of computer communication or internet log and trace data of access point for 3 months. |
| 468 | | |
| 469 | | ### 22.4 Data Security and Pseudonymisation |
| 470 | | |
| 471 | | In addition to the measures set out in section 20 of this privacy policy, under the Korean Personal Information Protection Act we take various technical, administrative and physical measures to ensure data security and the security of personal data. For example, we manage access rights to our systems that contain personal data as well as pseudonymized data in a traceable manner; we take various measures to prevent unauthorised access to personal and pseudonymized data, including maintaining a VPN network; we regularly train our employees in the handling of personal data, including pseudonymized data and data security. We regularly evaluate our data processing procedures and modify them as necessary. In addition, we work with strict physical access controls to e.g. our IT infrastructure and data storage systems as well as to documents that contain personal data. |
| 472 | | |
| 473 | | As outlined above in section 9.2, we analyze pseudonymized data about our customers' use of DeepL Pro products to understand general usage habits and derive different target and user groups. Pseudonymized data is used only until the purpose of data analysis is fulfilled and is destroyed thereafter. |
| 474 | | |
| 475 | | ### 22.5 Rights of Data Subject and Legal Representative |
| 476 | | |
| 477 | | As outlined above in section 20, you have the right to exercise your rights as a data subject by contacting us at privacy(at)deepl.com. DeepL Pro-customers can also reach out to support(at)deepl.com for assistance. |
| 478 | | |
| 479 | | You may exercise your rights through a legal representative or an authorized agent. In such cases, the legal representative or agent must present a signed power of attorney in writing to act on your behalf. |
| 480 | | |
| 481 | | ### 22.6 Children's Privacy |
| 482 | | |
| 483 | | Our service is not intended for children under the age of 14, and DeepL does not knowingly collect personal data from children under the age of 14. If you have any reason to believe that a child under the age of 14 has provided personal data to DeepL through the service, please contact us at privacy(at)deepl.com. We will investigate any such notification and if appropriate, delete the personal data from our systems. |
| 484 | | |
| 485 | | ### 22.7 Overseas Transfer and Delegation of Personal Data Processing |
| 486 | | |
| 487 | | We may transfer personal data to the overseas delegatees listed below in order to provide services and enhance customer convenience. In order to deliver our services, we may store your personal data on DeepL servers located within the EEA and transfer it to the delegatees located abroad. The overseas transfer is conducted through telecommunication network from time to time as needed. The transferred data will be retained and used in accordance with our privacy policy's retention periods. This overseas transfer is essential for the provision of our services. Therefore, if you refuse the overseas transfer, it may restrict your access to our services. |
| 488 | | |
| 489 | | - 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. |
| 490 | | - 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. |
| 491 | | - 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. |
| 492 | | - 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. |
| 493 | | - 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. |
| 494 | | - 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. |
| 495 | | - 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 [privacy-dsr@qualtrics.com](mailto:privacy-dsr@qualtrics.com). |
| 496 | | - 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 [dpo@hotjar.com](mailto:dpo@hotjar.com) |
| 497 | | - Conduct interviews: We use a service provided by UserTesting, Inc. 144 Townsend Street, San Francisco, CA 94107 USA to conduct interviews with you. UserTesting 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 [privacy@usertesting.com](mailto:privacy@usertesting.com). |
| 498 | | - 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 [privacy@zoom.us](mailto:privacy@zoom.us). |
| 499 | | - 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 [bohoerdenmdelung@dataguard.de](mailto:bohoerdenmdelung@dataguard.de). |
| 500 | | - 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 [hello@recruitee.com](mailto:hello@recruitee.com). |
| 501 | | - 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 [rick@codesse.com](mailto:rick@codesse.com) |
| 502 | | |
| 503 | | ## 23\. Changes to the Privacy Policy |
| 504 | | |
| 505 | | 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/en/privacy). |
| 463 | 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. |