CA-C-002227
ElevenLabs — ElevenLabs Privacy Policy
Entity
Date detected
May 21, 2026
Effective date
May 21, 2026
Severity
Low
Direction
Neutral
Affected users
all users EU users Brazil residents
Taxonomy
Disclosure requirement change
Changes
+2 sentences added · 9 sentences modified
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Event Summary

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.

LOW

Consumer Impact

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.

Governance Analysis

The updated policy clarifies the legal grounds under which ElevenLabs processes personal data, moving beyond consent-based justification to cite contract performance, legal compliance, and legitimate interests. This formalization helps users and regulators understand when and why ElevenLabs may process data without requiring explicit affirmative consent, which is operationally significant under GDPR, CCPA, and LGPD frameworks.

Available Actions

Review the updated policy to understand the legal bases under which ElevenLabs processes your data.

If you wish to exercise your data rights (access, deletion, portability, or objection), submit a request via the online form or email legal@elevenlabs.io using the designated subject line format.

If No Action Is Taken

The updated terms will apply as written; ElevenLabs will process your data under the stated legal bases without requiring consent for all processing activities.

If you do not submit a data rights request, the terms do not obligate ElevenLabs to provide you access to or delete your personal data outside of legal obligations.

Key Clauses Affected

Legal bases for data processing

Policy now cites contract performance, legal compliance, and legitimate interests as bases for processing, replacing reliance on consent as primary justification.

Data Protection Office contact procedures

Formalized contact mechanism through named Data Protection Office at legal@elevenlabs.io and physical mailing address for submitting data rights requests.

Brazil-specific Data Protection Officer

Added designation of Paulo Eduardo Lilia as DPO for Brazilian residents, signaling localized compliance governance.

Full clause-by-clause analysis available with Compliance.
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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
Citation Record
Entity: ElevenLabs
Document: ElevenLabs Privacy Policy
Record ID: CA-C-002227
Captured: 2026-05-21 00:46:02 UTC
URL: https://conductatlas.com/change/2026-05-21-elevenlabs-elevenlabs-privacy-policy-2227/
Accessed: July 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
For legal and compliance teams

Institutional Analysis

Assessment

The policy revision clarifies ElevenLabs' legal bases for data processing and formalizes its data protection governance structure by establishing a named Data Protection Office. The change expands stated legal grounds for processing from consent-based framing to include contract performance, legal compliance, and legitimate interests, which aligns with standard GDPR and CCPA operational practice. The addition of Brazil-specific contact information suggests ElevenLabs operates a Brazil entity and may signal compliance with Brazilian data protection frameworks (LGPD). No immediate compliance action appears required; the changes primarily clarify existing operational and organizational structures.

Regulatory Exposure

GDPR (legal bases under Article 6), CCPA (processing justifications), LGPD (Brazil-specific governance and DPO designation)

Full compliance analysis

Obligation analysis, escalation trigger, board language, and recommended action.

Monitor $19/mo Compliance $249/mo

Monitor: regulatory citations + obligations. Compliance: full compliance memo.

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

Clause-Level Changes

New Provisions Added
GDPR Individual Rights
Low

Splits and clarifies GDPR/regional privacy rights into specific provisions with expanded geographic scope to include Switzerland and the United Kingdom, while reducing severity from medium to low.

Full clause text available with Compliance. See Compliance →
CCPA Rights for California Residents
Medium

Separates CCPA rights into a dedicated provision with more detailed enumeration of California resident rights, including non-discrimination rights not explicitly mentioned in the previous version.

Full clause text available with Compliance. See Compliance →
Provisions Removed
Corporate Transaction Data Transfer
Medium

Removal of explicit M&A and corporate transaction data transfer disclosure reduces transparency about data handling during business restructuring events.

Removed clause text available with Compliance. See Compliance →
User Rights for EU and California Residents
Medium

This combined provision was split into separate GDPR and CCPA provisions in the current version, making the removal of this consolidated provision part of a restructuring rather than a true removal of rights.

Removed clause text available with Compliance. See Compliance →
International Data Transfers
Medium

This provision was renamed and refocused as 'Cross-Border Data Transfers' with materially different language that removes the explicit U.S.-centric framing and weakens consent language.

Removed clause text available with Compliance. See Compliance →
Provisions Modified
Voice Data Collection and AI Model Training
High

Added explicit consent requirement language and simplified the provision to focus on collection and training purposes without specifying particular use cases like text-to-speech or voice cloning.

Before/after clause text available with Compliance. See Compliance →
Data Sharing with Advertising and Analytics Partners
Medium

Removed explicit language about sharing for business partners' own marketing purposes and added specific mention of advertising and analytics partners instead.

Before/after clause text available with Compliance. See Compliance →
Cross-Border Data Transfers
Medium

Removed explicit consent language and made the provision broader by removing specific reference to the United States as the primary destination and removing mention of server location.

Before/after clause text available with Compliance. See Compliance →
Cookies and Tracking Technologies
Medium

Added specific tracking technologies (web beacons, pixel tags), added device information collection, specified uses for analytics and advertising, and removed user control language about browser settings and consent tools; severity increased from low to medium.

Before/after clause text available with Compliance. See Compliance →
Data Retention
Medium

Simplified the retention policy to focus on fulfilling collection purposes and legal/accounting/reporting requirements, removing specific references to providing services, resolving disputes, and enforcing agreements.

Before/after clause text available with Compliance. See Compliance →
Children's Privacy and Age Restriction
Low

Removed reference to parental consent in the condition for deletion and changed 'become aware' to 'learn,' weakening the notification standard.

Before/after clause text available with Compliance. See Compliance →

Cross-platform context

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Full Changes

See the full side-by-side comparison of every sentence added, removed, and modified.

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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
Other changes to ElevenLabs Privacy Policy
Previous change May 19, 2026
ElevenLabs removed two social media platform links from their privacy policy footer on May 19, 2026. The updated policy no …
Low Neutral
Next change May 30, 2026
ElevenLabs modified a single sentence in their privacy policy on May 30, 2026, removing a reference to the EU Digital …
Low Neutral
View full version history →
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