ElevenLabs collects voice recordings and AI-generated voice models submitted by users and states that this data may be used to train and improve its AI systems, with consent obtained where legally required.
This analysis describes what ElevenLabs's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision directly implicates biometric privacy statutes in multiple U.S. jurisdictions, including Illinois BIPA, which requires opt-in written consent before collecting biometric identifiers, and may engage GDPR Article 9 if voice data is processed to uniquely identify individuals. The scope of consent required, and whether existing consent mechanisms satisfy applicable statutory standards, warrants legal evaluation.
Interpretive note: The adequacy of ElevenLabs' consent mechanism for voice data AI training use under BIPA's written consent requirement and GDPR Article 9's explicit consent standard cannot be determined from policy text alone and requires review of implemented consent flows.
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.
View full change record →Under this clause, voice recordings and voice models submitted to the ElevenLabs platform may be used to train ElevenLabs AI systems. The agreement states that consent will be obtained where required by applicable law, but the specific consent mechanism and its adequacy under biometric privacy statutes may vary by jurisdiction.
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"We collect voice recordings and voice models that you create or upload to our platform. We may use this data to train and improve our AI models and services, subject to your consent where required by applicable law.Excerpt from ElevenLabs's Privacy Policy (Superseded URL)
(1) REGULATORY LANDSCAPE: This provision engages Illinois BIPA (requiring informed written consent before biometric data collection), Texas CUBI, Washington My Health My Data Act, and potentially GDPR Article 9 where voice data is processed to …
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This provision directly implicates biometric privacy statutes in multiple U.S. jurisdictions, including Illinois BIPA, which requires opt-in written consent before collecting biometric identifiers, and may engage GDPR Article 9 if voice data is processed to uniquely identify individuals. The scope of consent required, and whether existing consent mechanisms satisfy applicable statutory standards, warrants legal evaluation.
Under this clause, voice recordings and voice models submitted to the ElevenLabs platform may be used to train ElevenLabs AI systems. The agreement states that consent will be obtained where required by applicable law, but the specific consent mechanism and its adequacy under biometric privacy statutes may vary by jurisdiction.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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