Change record
CA-X-002227
ElevenLabs Privacy Policy
Entity
Date detected
May 21, 2026
Effective date
May 20, 2026
Severity
Low
Direction
Neutral
Taxonomy
Disclosure requirement change
Changes
+2 sentences added · 9 sentences modified

Impact Summary

Low Neutral for users
Affected users
All users EU users UK users Brazil residents

ElevenLabs updated its Privacy Policy to expand its corporate structure, revise legal bases for data processing, and clarify contact procedures for data subject rights requests. The policy now lists additional affiliated entities (Eleven Labs Auto India Private Limited and Eleven Labs Technology Middle East Limited), shifts from consent-based processing to contract necessity and legitimate interests as primary legal bases, and designates a Data Protection Office for rights requests. The practical effect is that data processing may now proceed under multiple legal grounds beyond user consent, and data subjects in Brazil have a named Data Protection Officer.

1 obligation expanded

Data controllers using ElevenLabs: ElevenLabs may now process your data under multiple legal grounds, not just your consent, which may require you to review your own privacy notices to customers if you rely on ElevenLabs for data processing.

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What this means for you

The updated policy expands the legal bases under which ElevenLabs may process personal data. Previously, the policy emphasized consent as the primary basis; the revised language now states that processing may rely on contract necessity, legitimate interests (including fraud prevention and security), compliance with legal obligations, or other applicable legal grounds depending on circumstances and applicable law. This means data processing may proceed without explicit user consent in certain contexts where the company asserts a contractual or legitimate interest basis. The policy also clarifies that data subject rights requests should be directed to a Data Protection Office, with a named officer for Brazil residents.

What you can do

→ Review the updated legal bases for processing to understand when ElevenLabs may process your data without explicit consent.

→ If you wish to exercise data subject rights (access, deletion, portability), use the online form or email legal@elevenlabs.io with your request and location.

Key Clauses Affected

Legal bases for processing

Expanded from consent-based to multi-basis framework including contract necessity, legitimate interests, legal compliance, and other applicable grounds.

Data subject rights contact

Clarified that requests should be directed to Data Protection Office; named Data Protection Officer for Brazil residents.

Corporate entity list

Added Eleven Labs Auto India Private Limited and Eleven Labs Technology Middle East Limited as affiliated entities processing personal data.

Full clause-by-clause analysis available with Insight.
ⓘ

This change record describes what was added, removed, or modified in the document. Analysis reflects what the updated agreement states or permits. It does not constitute a legal determination about enforceability. Applicability may vary by jurisdiction. Methodology

Evidence Verification

✓ Verified
Previous Version
23ba6fbe35d3b0be9a23780309c3cb2b879f8ae3595b30a5ff07051f3eb5526e
May 19, 2026 16:06 UTC
✓ Verified
Current Version
8565223bcd6694ee5874e81e75eb125c6e51d7f4e88d3f06091629118a7474ea
May 21, 2026 00:46 UTC
✓ Verified
Change Detected
May 21, 2026 00:46 UTC
✓
Analysis Methodology
✓ Verified
Source Document
https://elevenlabs.io/privacy-policy
Record history

Wording edits to this record that do not change what it claims. Changes to a claim are published as corrections.

2026-10-11 · Feed summary edited · summary regenerated by summarize_events
Previous text
Clarified data processing legal bases and formalized Data Protection Officer contacts in privacy policy.
2026-10-11 · Impact summary edited · summary regenerated by summarize_events
Previous text
The updated policy clarifies that ElevenLabs may process your personal data based on multiple legal grounds: contract performance, legal compliance, legitimate interests, and other applicable legal bases, rather than relying primarily on your consent. The policy also reorganizes contact procedures for exercising data rights, designating a formal Data Protection Office accessible by email at legal@elevenlabs.io and by mail at the stated address. For Brazilian residents, the policy names Paulo Eduardo Lilia as the designated Data Protection Officer. You can exercise data rights using the online form or by emailing the Data Protection Office with your request in the subject line.
2026-10-11 · Summary edited · summary regenerated by summarize_events
Previous text
ElevenLabs updated its privacy policy on May 21, 2026, making several modifications to how it describes legal bases for data processing and contact procedures for exercising data rights. The policy now references multiple legal bases for processing (contract performance, legal compliance, legitimate interests) instead of relying primarily on consent, and reorganized contact instructions to designate a Data Protection Office with specific email and mailing address. The policy also added Brazil-specific contact information naming Paulo Eduardo Lilia as the Data Protection Officer for Brazilian residents. These changes clarify ElevenLabs' organizational structure, formalize data protection contacts, and broaden the stated legal justifications for data processing.
2026-10-07 · Change line edited · change line rewritten to the 2026-10-07 template: no detection date, no sentence counts
Previous text
ElevenLabs updated their ElevenLabs Privacy Policy (Superseded URL) on May 21, 2026. Change detected: 2 sentence(s) added, 9 sentence(s) modified. Document contained 281 sentences after update.
Citation Record
Entity: ElevenLabs
Document: ElevenLabs Privacy Policy
Record ID: CA-X-002227
Version: CA-V-002830
Captured: 2026-05-21 00:46:02 UTC
URL: https://conductatlas.com/change/2026-05-21-elevenlabs-elevenlabs-privacy-policy-2227/
Accessed: Oct. 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
For legal and compliance teams

Institutional Analysis

Assessment

ElevenLabs revised its legal bases for data processing from consent-focused language to a multi-basis framework that includes contract necessity, legitimate interests, and compliance with legal obligations. The change reflects standard GDPR Article 6 legal basis …

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Regulatory exposure, obligation change, escalation trigger, board-ready language, and recommended action for legal and compliance teams.

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ConductAtlas provides verified policy intelligence sourced directly from platform documents. All analysis is intended to support, not replace, legal and compliance review. Record CA-X-002227.

Full Changes

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Document Context

Version history → Policy drift analysis → Document page →
Document
ElevenLabs Privacy Policy
Entity
ElevenLabs
Captured
May 21, 2026
Source URL
https://elevenlabs.io/privacy-policy
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