AI servicesDeepL and the GDPR: agreement, role and data location.
DeepL is a ai services tool. Most customers use it as a processor, it explains how to get its data processing agreement, and the data location depends on your account. Below: what to check and how to declare it.
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In short
- Category
- AI services
- Usual role
- Usually a processor
- Data location
- Set per account or project
- Agreement
- Obtained through the vendor
What does DeepL do with personal data?
Support business activities or client services using the provider’s API or services. That is how Privacyboard describes a typical use of DeepL, as a starting point you can edit.
The data usually involved: prompts, uploaded content, outputs and any personal data included in API requests.
Is DeepL a processor or a controller?
Most customers use DeepL as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for ai services tools and it is what Privacyboard suggests.
As a processor, it needs a written agreement with you under Article 28, and you should know which subprocessors it uses. Confirm the role against your own agreement, because the way you use a tool can change it.
Where does DeepL store personal data?
DeepL does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable.
How to find yours: Check your account settings, the address you log in to, or the provider’s data processing terms. Support can tell you if you cannot find it.
Even when the main location is in the EU, ask whether subprocessors or support access involve a transfer outside the EEA, and record it if so.
Which legal basis usually applies to DeepL?
The legal basis for DeepL depends on what goes through it. The legal basis depends on what you send to the provider and why. Use the basis of the activity the AI supports in your register.
This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Does DeepL have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
DeepL does not publish the full text of its data processing agreement on a public page. The reference page explains how a customer gets or signs it, usually from inside the account. Article 28 of the GDPR still requires a written contract, so get it and keep a copy.
What we noted when we opened the page: DeepL Pro Terms and Conditions with DeepL SE (Cologne); section 8.1.5 says the DPA is downloadable from the DeepL Trust Centre and forms part of the agreement. Says DeepL decides the processing location; privacy policy says documents are processed in the EEA.
A page that exists does not mean you are covered. Whether the agreement applies to you depends on your plan and on what you accepted, so record the decision yourself in your vendor list.
Open the DeepL reference pageHow to declare DeepL
- 1
In your privacy policy
Name DeepL as a recipient, say what it is used for (support business activities or client services using the provider’s API or services) and mention any transfer outside the EEA. Articles 13 and 14 ask you to tell people who receives their data.
- 2
In your vendor list
Add DeepL with its purpose, the data involved, its role, its region and a link to the agreement. Privacyboard prefills all of this, you confirm or correct it.
- 3
In your processing register
Link DeepL to the activities that use it, so each record shows its recipients. Article 30 asks the register to list the categories of recipients.
What to check before relying on DeepL
- Decide what personal data may be sent in prompts, and block the rest.
- Check whether inputs are retained or used for training under your plan.
- Record the provider and the purpose in your privacy policy.
- Check for automated decisions about people, which carry extra duties under Article 22.
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Questions, answered.
Is DeepL GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how DeepL is configured and used, on the agreement you have with it and on your own practices. What can be checked is documented here: it explains how to get a data processing agreement, the usual role and the data location. Read the agreement itself before relying on it.
Does DeepL have a DPA?
DeepL does not publish the full text of its data processing agreement on a public page. The reference page explains how a customer gets or signs it, usually from inside the account. Article 28 of the GDPR still requires a written contract, so get it and keep a copy. The reference page is https://www.deepl.com/en/pro-license.
Is DeepL a data processor?
Usually, yes. Most customers use DeepL as a processor that acts on their instructions. Check your own agreement and how you use the tool, because the role can differ.
Which legal basis applies when I use DeepL?
The legal basis for DeepL depends on what goes through it. The legal basis depends on what you send to the provider and why. Use the basis of the activity the AI supports in your register. This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Where does DeepL store data?
DeepL does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable. How to find yours: Check your account settings, the address you log in to, or the provider’s data processing terms. Support can tell you if you cannot find it.
Do I need to mention DeepL in my privacy policy?
Yes, if DeepL handles personal data for you. The GDPR asks you to tell people who receives their data (Articles 13 and 14). Name the vendor or its category, say what it is used for and mention any transfer outside the EEA.
How do I add DeepL to my vendor list?
In Privacyboard, pick DeepL from the catalog. The purpose, the data, the suggested role and a link to its agreement are prefilled, and you confirm each one. Creating a workspace is free.
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Privacyboard is not affiliated with DeepL. Names and logos belong to their owners and are used only to identify the tool. This page summarises public documents as checked on 1 November 2026; it is guidance, not legal advice, and it does not certify any vendor.