Privacy Policy

ARCHIVED 2023-03-06, DATE APPROXIMATE · VERSION 20230306_rev01 · COMPARED WITH 20230120_rev01

Full text changes — 20230120_rev01 to 20230306_rev01

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

  | TechnologyCookie | Expiry7 days | OwnerDeepL |
 | Translator | IDrecommendationFlags | Description
 Used to store additional translator settings of the user.
  | TechnologyLocal Storage | Expiry6 month | OwnerDeepL |
+| Checkout Process | IDLMT\_resumeCheckout | Description
+Used to store checkout details of the user to help users resume the checkout process.
+ | TechnologyLocal Storage | ExpiryPersistent Data | OwnerDeepL |
 | Product information | IDapiDocsVisited | Description
 Stores whether API documentation has been visited to help users select the correct package at checkout.
  | TechnologyLocal Storage | ExpiryPersistent Data | OwnerDeepL |
 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/).
 ### 14.5 Hotjar
 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/).
+### 14.6 UserTesting
+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).
 ## 15\. DeepL's Social Media Pages
 DeepL operates several social media profiles (also called "pages") on various social networks e.g., Facebook, Instagram, Twitter, LinkedIn and Xing. There we regularly publish posts about our products, new product features as well as new job offers. If you interact with our pages or contact us via them and are a member of the respective social network, we may receive and process data that identify you. As operator of the pages, we also have the option of viewing anonymous statistics on the interaction of visitors with our pages (insight function). For this purpose, the operators of the social networks record your interactions with our pages using cookies and similar technologies. You can find more information on this kind of data processing by Facebook, Instagram and LinkedIn [here](https://www.facebook.com/legal/terms/information_about_page_insights_data), [here](https://www.facebook.com/help/instagram/788388387972460) and [here](https://www.linkedin.com/help/linkedin/answer/a427660).
 The legal basis for the operation of our social media profiles and the insights function is our legitimate interest within the meaning of Art. 6 para. 1 sentence 1 lit. f) GDPR in using the pages as an information channel for our company. With regard to the insights function, we have a legitimate interest in understanding the visits and interactions with our page in order to be able to respond to them and to further improve our presence. Insofar as your consent given to the social network justifies the data processing within the framework of the respective social platform, processing is carried out on the basis of this consent.
+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.
 Please note that we together with the operator of the respective social network are jointly responsible for the data processing operations triggered when you visit our page. However, the operators of the social networks may also process your data for their own purposes, which are not depicted in this privacy policy. It is also possible that data collected about you will be transferred to third countries, in particular the USA. We have no influence on this data processing and refer to the privacy policies of the respective social networks e.g., for Facebook [here](https://www.facebook.com/policy.php), for Instagram [here](https://www.facebook.com/privacy/policy/), for Twitter [here](https://twitter.com/en/privacy), for LinkedIn [here](https://www.linkedin.com/legal/privacy-policy) and for Xing [here](https://privacy.xing.com/en/privacy-policy).
 In principle, you can assert your rights (see section [19]() below) both against us and against the operator of the respective social platform. However, we would like to point out that despite the joint controllership, you can most effectively assert your rights with the operators of the social networks. If you need help, you can contact us.
 ## 16\. Webinars
 Please note that we may record Zoom webinars and publish them afterwards on our website or social media channels. Participants will not be visible or identifiable in these recordings. As participants can only ask written questions, they will not appear visually in the recording. The answer to the participant's question will be part of the webinar recording. If, contrary to expectations, personal data of the participants is visible during the recording, it will be made unrecognisable before publication. The recording and storage of the webinar is based on Art. 6 para. 1 sentence 1 lit. f) GDPR, as these processing operations are in our legitimate interest to improve the quality of our webinars. When the webinars are published, no further processing of personal data will take place, as we will make them unrecognisable beforehand - if they can be viewed at all.
 ## 17\. Job Applications
 We offer you the opportunity to apply for a position at DeepL via our career page and the integrated career portal, or by email. This digital recruitment process means that in order to complete the application procedure, your application data (usually name, contact information, cover letter, resume, as well as other supporting documents and credentials) is collected and processed electronically. The personal data you provide will be used exclusively for processing your job application. Your data will only be shared with persons involved in the application process. If you submit your documents in German only, even though an English version of the documents was requested in the job advertisement, we reserve the right to translate your documents into English using DeepL's PDF translation feature. In this context, your data may be transferred to the USA (see also section [7.2]() of this privacy policy). The legal basis for the processing of your applicant data is Art. 6 para. 1 sentence 1 lit. b) GDPR in conjunction with Art. 88 para. 1 GDPR in conjunction with § 26 para. 1, 8 sentence 2 BDSG ("Bundesdatenschutzgesetz": German Federal Data Protection Act). If you apply for a freelance job at DeepL, the legal basis for the processing of your applicant data is Art. 6 para. 1 sentence 1 lit. b) GDPR.
+Where necessary, we reserve the right to carry out a pre-check of the data provided by the applicant as part of the application process in relation to the applicant's work permit. The pre-check enables us to find out whether the applicant is eligible to obtain a work visa and at what time such a visa could be provided. 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. We have concluded a data processing agreement with Localyze UG (haftungsbeschränkt) and therefore Localyze may only process the data according to our instructions and not for its own purposes. You can find more information about Localyze's handling of personal data [here](https://www.localyze.com/privacy-policy). The processing of personal data in the context of the pre-check is necessary for the establishment of an employment relationship. Accordingly, we justify the data processing via Art. 6 para. 1 sentence 1 lit. b) GDPR in conjunction with Art. 88 para. 1 GDPR in conjunction with § 26 para. 1, 8 sentence 2 BDSG ("Bundesdatenschutzgesetz": German Federal Data Protection Act).
+If a contract is concluded with you and a work visa is required, Localyze will take over the further coordination of obtaining the work visa. It is possible that Localyze will need to obtain further data from you in addition to the applicant data in order to be able to support you in the visa process (e.g., passport scan; health insurance confirmation). The processing of personal data by Localyze is necessary for the implementation of the employment relationship and is therefore covered by Art. 6 para. 1 sentence 1 lit. b) GDPR in conjunction with Art. 88 para. 1 GDPR in conjunction with § 26 para. 1, 8 sentence 2 BDSG ("Bundesdatenschutzgesetz": German Federal Data Protection Act).
 If, following the recruitment process, an employment contract is concluded, we will store your personal data as part of your personnel file for the purpose of standard organizational and administrative procedures, in compliance with the more extensive legal obligations. In this case, the legal basis for the processing of your data is Art. 6 para. 1 sentence 1 lit. b) GDPR in conjunction with Art. 88 para. 1 GDPR in conjunction with § 26 para. 1 BDSG ("Bundesdatenschutzgesetz": German Federal Data Protection Act). When working on a freelance basis for DeepL, we will store your personal data for the purpose of executing your contract with us. In this case, the legal basis for the processing of your data is Art. 6 paragraph 1 sentence 1 lit. b) GDPR.
 In the event of a rejection on your part or ours, we will retain the data submitted to us for up to a maximum of six months following notification of the rejection. We will subsequently delete the data unless legal regulations require us to store the data for a longer period.
 If you expressly agree to a longer storage period of your data e.g., for your inclusion in our internal applicant pool, the data will be further processed based on your consent in accordance with Art. 6. para. 1 sentence 1 lit. a) GDPR. Your data will then be stored in our pool of applicants for 1000 days. You can withdraw your consent at any time with effect for the future.