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The policy states that personal data including user information may be transferred to a third-party acquirer in connection with a merger, acquisition, asset sale, or similar corporate transaction.
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 authorizes the transfer of all collected personal data, including voice recordings and account information, to successor entities in corporate transactions without requiring separate user consent at the time of transfer, subject to applicable law.
Expanded scope to include 'financing due diligence, reorganization, bankruptcy, receivership' and 'transition of service to another provider'; added qualifier 'as permitted by law and/or contract'.
View full change record →Under this clause, personal data collected by ElevenLabs including voice recordings, account identifiers, and payment information may be transferred to an acquiring or successor entity as part of a corporate transaction. Applicable law in certain jurisdictions may impose notice or consent requirements on such transfers.
How other platforms handle this
If we're involved in a reorganization, merger, acquisition, sale of some or all of our assets or other business transaction, depending on the circumstances, we may disclose any of the information described in Section 2 above...
Whenever we transfer personal data internationally, we use tools and transfer agreements to: make sure the data transfer complies with applicable law; and help to give your data the same level of protection as it has in the EU...
disclosure is required by a third-party to complete a transaction initiated by the user
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"If ElevenLabs is involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.Excerpt from ElevenLabs's Privacy Policy
1. REGULATORY LANDSCAPE: This provision implicates GDPR (transfers in corporate transactions may require a new lawful basis assessment and updated privacy notices to data subjects), CCPA/CPRA (acquirers must honor existing privacy rights and disclosures or provide new notice and opt-out opportunities), and FTC guidelines on data transfers in acquisitions. Enforcement authorities include EU/UK data protection authorities and the California Privacy Protection Agency. 2. GOVERNANCE EXPOSURE: Medium. Business transfer clauses are standard in commercial privacy policies, but the breadth of data transferred, including potentially biometric-adjacent voice recordings, may create heightened scrutiny under state biometric statutes that require separate consent for transfer of biometric data. BIPA explicitly requires written consent for the disclosure or dissemination of biometric identifiers. 3. JURISDICTION FLAGS: Illinois BIPA may require written consent prior to disclosure or transfer of biometric data, including in acquisition contexts. GDPR requires that data subjects be informed of a change in data controller and may require a new lawful basis in some transfer scenarios. California CPRA requires acquirers to honor existing CCPA rights. 4. CONTRACT AND VENDOR IMPLICATIONS: In M&A due diligence involving ElevenLabs or any platform with analogous provisions, acquiring parties should assess whether biometric or sensitive data consent obligations transfer with the acquired data assets, and whether the acquirer's own privacy framework is compatible with the uses disclosed in ElevenLabs' policy. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should ensure that business transfer protocols include data protection impact assessments for transfers involving biometric or sensitive data categories, and that data subject notification procedures are documented for use in acquisition scenarios.
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This provision authorizes the transfer of all collected personal data, including voice recordings and account information, to successor entities in corporate transactions without requiring separate user consent at the time of transfer, subject to applicable law.
Under this clause, personal data collected by ElevenLabs including voice recordings, account identifiers, and payment information may be transferred to an acquiring or successor entity as part of a corporate transaction. Applicable law in certain jurisdictions may impose notice or consent requirements on such transfers.
ConductAtlas has identified this type of provision across 288 platforms. See the full comparison.
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