Phrase Language Intelligence Platform and the GDPR: AI training, data location and DPA

Trains on your data, with no documented way to stop it.

Yes for some models: Phrase may train its own non-text AI models (e.g. MT engine selection, quality scoring) on customer content, no opt-out stated. Text-generating models are trained only with your prior approval.

Vendor's wording: “The Phrase Group may use the Customer Content to train ML Models which are not designed to deliver an output to a customer in the form of a sequence of words or phrases.”

Source: phrase.comTerms of Service, 3.4.1 and 3.4.2 (ML Models used in the Phrase Solutions)Checked on 19 October 2026

DPA on request.

Yes: the Data Processing Addendum is Annex 1 of the Terms of Service and applies automatically; no separate signing described.

Vendor's wording: “Data Processing Addendum means the data processing addendum contained in Annex 1 to these Terms of Service.”

Source: phrase.comTerms of Service, Section 1 DefinitionsChecked on 19 October 2026

Published.

Yes: https://phrase.com/subprocessor-overview/ lists 15 sub-processors. AI/model providers: Microsoft, Google Ireland, OpenAI Ireland, Anthropic Ireland, Eleven Labs, Palabra.AI; machine translation: Rozetta, Tencent Cloud Europe, Unbabel.

Vendor's wording: “Get a detailed overview of all sub-processors for all Phrase Solutions.”

Source: phrase.comSub-ProcessorsChecked on 19 October 2026

EU or Swiss vendor.

Not applicable (EU-based vendor, Phrase a.s., Prague, Czech Republic)

Vendor's wording: “Phrase means Phrase a.s. (formerly Memsource a.s.), a joint stock company incorporated under the laws of the Czech Republic”

Source: phrase.comTerms of Service, Section 1 DefinitionsChecked on 19 October 2026

After the terms end: 30 days to export, deletion starts then and finishes within 60 days of termination. Personal data stays up to 60 days after you delete it in the product.

Vendor's wording: “Phrase will retain the Customer Content for thirty (30) days following termination or expiration of the Terms of Service”

Source: phrase.comTerms of Service Annex 1 (DPA), 10.1 and 3.3Checked on 19 October 2026

ISO 27001 certified; SOC 2 Type I (Type II expected in 2026). 1 full certification plus 1 attestation.

Vendor's wording: “Phrase is SOC 2 Type I certified, with Type II certification expected in 2026.”

Source: phrase.comCertificationsChecked on 19 October 2026