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ElevenLabs states that personal data may be transferred and processed in countries outside the user's country of residence, including countries with different data protection standards.
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
Cross-border data transfers from the EU/EEA to the United States require an approved transfer mechanism under GDPR Chapter V. The policy does not specify in detail which transfer mechanisms are relied upon, which warrants verification by compliance teams evaluating EU data flows.
Interpretive note: The specific transfer mechanisms relied upon by ElevenLabs for EU/EEA and UK data transfers are not explicitly enumerated in the policy text, creating uncertainty about GDPR Chapter V compliance status.
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.
View full change record →This provision establishes that personal data collected from users in any jurisdiction, including the EU/EEA and UK, may be processed in the United States or other countries. The adequacy of transfer safeguards under GDPR depends on the specific mechanisms implemented, which are not fully detailed in the policy text.
How other platforms handle this
to request that your data be transferred to a third party (data portability)
Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.
Further, you may take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data prot...
Monitoring
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"Your personal information may be transferred to and processed in countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country.Excerpt from ElevenLabs's Privacy Policy (Superseded URL)
(1) REGULATORY LANDSCAPE: This provision engages GDPR Chapter V, which restricts transfers of personal data to third countries without adequate protections. The EU-U.S. Data Privacy Framework provides a current adequacy mechanism for U.S. transfers if ElevenLabs is certified; Standard Contractual Clauses provide an alternative. UK GDPR similarly restricts international transfers. EU supervisory authorities enforce Chapter V compliance. (2) GOVERNANCE EXPOSURE: Medium. The absence of explicit enumeration of transfer mechanisms in the policy text creates transparency questions under GDPR Article 13/14 disclosure requirements. Organizations relying on this policy for transfer compliance verification will need to request supplementary documentation from ElevenLabs. (3) JURISDICTION FLAGS: EU/EEA and UK users face the highest exposure from inadequately documented cross-border transfer mechanisms. Switzerland's Federal Act on Data Protection also restricts international transfers. Post-Schrems II, reliance on any transfer mechanism requires a transfer impact assessment for high-risk destination countries. (4) CONTRACT AND VENDOR IMPLICATIONS: Business customers operating in the EU/EEA should request confirmation of the specific transfer mechanisms in place and obtain copies of applicable Standard Contractual Clauses or Data Privacy Framework certification details. Data Processing Agreements should specify the transfer mechanism and associated obligations. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should verify ElevenLabs' EU-U.S. Data Privacy Framework certification status or confirm that Standard Contractual Clauses with required transfer impact assessments are in place. UK adequacy and Swiss data transfer compliance should be separately assessed. Records of processing activities should document the transfer mechanism for each cross-border data flow.
Regulatory citations, enforcement risk, and due diligence action items.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
Cross-border data transfers from the EU/EEA to the United States require an approved transfer mechanism under GDPR Chapter V. The policy does not specify in detail which transfer mechanisms are relied upon, which warrants verification by compliance teams evaluating EU data flows.
This provision establishes that personal data collected from users in any jurisdiction, including the EU/EEA and UK, may be processed in the United States or other countries. The adequacy of transfer safeguards under GDPR depends on the specific mechanisms implemented, which are not fully detailed in the policy text.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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