RoPA Pilot

DeepL and GDPR: hosting, non-EU transfer and DPA

DeepL is published by DeepL SE. If your teams use it, it is a processor within the meaning of Article 28 GDPR and it must appear in your record of processing activities.

Vendor (processor)
DeepL SE
Headquarters
European Union
EU hosting
EU by default
Non-EU transfer
No
Transfer mechanism
European Union
Category
AI
Typical personal data
content
Detected domains
deepl.com

Does using DeepL mean a non-EU transfer?

No. DeepL SE keeps the data inside the European Union: no structural transfer to document under Chapter V.

What to write in your Article 30 record

Purpose: AI. Categories of personal data: content. Recipient: DeepL SE. Transfer: European Union. Retention: aligned with the contract or the account lifetime, whichever is shorter.

How RoPA Pilot handles it

RoPA Pilot detects DeepL from the domain name of the tab — never from page content — and pre-fills the record above in one click. The extension flags the record if the transfer mechanism is missing or unverified.

Indicative information from public sources. The transfer mechanism actually applicable to you is the one written in your contract.