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.
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.
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.
→ 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.
Expanded from consent-based to multi-basis framework including contract necessity, legitimate interests, legal compliance, and other applicable grounds.
Clarified that requests should be directed to Data Protection Office; named Data Protection Officer for Brazil residents.
Added Eleven Labs Auto India Private Limited and Eleven Labs Technology Middle East Limited as affiliated entities processing personal data.
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
Wording edits to this record that do not change what it claims. Changes to a claim are published as corrections.
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 …
Regulatory exposure, obligation change, escalation trigger, board-ready language, and recommended action for legal and compliance teams.
Unlock the full institutional analysis — InsightConductAtlas 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.
ElevenLabs updated its Terms of Service with several clarifications and additions. The company added language stating that when a Service …
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