Your personal data including voice recordings may be transferred to and stored in the US or other countries, which may have weaker privacy protections than your home country.
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
EU/EEA users' data transferred to the US must be protected by an adequate transfer mechanism under GDPR; relying on consent as the basis for international transfers may not fully satisfy GDPR requirements in practice.
Interpretive note: The adequacy of ElevenLabs' international transfer mechanism under GDPR cannot be determined from the policy text alone; DPF certification status and SCC implementation should be independently verified.
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.
View full change record →If you are an EU, UK, or other non-US user, your voice recordings and personal data may be processed in the United States under a legal framework that may differ from your home country's protections.
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Your personal information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.
Your personal information may be transferred to, stored, and processed in the United States or other countries outside of your country of residence, which may have data protection laws that are different from those in your country.
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"If you are located outside of the United States, please be aware that your information may be transferred to, stored, and processed in the United States or other countries where our servers are located. By using our services, you consent to the transfer of your information to these countries, which may have different data protection laws than your country.— Excerpt from ElevenLabs's ElevenLabs Privacy Policy
REGULATORY LANDSCAPE: International data transfers from the EU/EEA to the US are governed by GDPR Chapter V, which requires either an adequacy decision, standard contractual clauses, binding corporate rules, or another approved mechanism. The EU-US Data Privacy Framework (DPF) may provide an adequacy basis if ElevenLabs is certified, but this should be verified. Relying on user consent as the sole basis for international transfers is generally disfavored under GDPR guidance from the European Data Protection Board, as consent must be freely given and the policy's 'by using our services' framing may not satisfy this standard. GOVERNANCE EXPOSURE: Medium to High for EU operations. If ElevenLabs relies on consent embedded in the policy rather than SCCs or DPF certification for EU-to-US transfers, this creates compliance exposure following the Schrems II ruling and subsequent EDPB guidance. UK users are subject to the UK GDPR's equivalent transfer restriction framework. JURISDICTION FLAGS: EU/EEA users have the strongest legal protections and the greatest exposure if transfer mechanisms are inadequate. UK users are subject to the UK's International Data Transfer Agreement framework. Non-EEA countries (Brazil, India, Japan) may have their own transfer restriction requirements that the policy does not address. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers in the EU should request evidence of ElevenLabs' transfer mechanism (SCCs, DPF certification, or binding corporate rules) and include data transfer provisions in their data processing agreements. The policy's reliance on 'by using our services' consent is unlikely to satisfy GDPR controller-to-processor transfer requirements. COMPLIANCE CONSIDERATIONS: Legal teams should verify ElevenLabs' DPF certification status and confirm that SCCs or equivalent mechanisms are in place for EU-to-US data transfers. The policy's consent-based transfer framing should be reviewed by EU counsel for compliance with EDPB guidance on international transfers. A transfer impact assessment may be required for certain categories of data including voice recordings.
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EU/EEA users' data transferred to the US must be protected by an adequate transfer mechanism under GDPR; relying on consent as the basis for international transfers may not fully satisfy GDPR requirements in practice.
If you are an EU, UK, or other non-US user, your voice recordings and personal data may be processed in the United States under a legal framework that may differ from your home country's protections.
ConductAtlas has identified this type of provision across 55 platforms. See the full comparison.
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