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The policy states that voice recordings submitted by users may be processed to train and improve ElevenLabs' AI models, subject to user account settings and applicable consent mechanisms.
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 use of user-submitted voice audio for AI model training, which creates obligations under GDPR lawful basis requirements and may trigger biometric consent statutes in Illinois, Texas, and Washington if voice recordings are characterized as biometric identifiers under those frameworks.
Interpretive note: The policy's reference to 'applicable consent choices' does not specify whether consent is obtained through opt-in or opt-out mechanisms, and the characterization of voice recordings as biometric data under state law depends on jurisdiction-specific definitions and enforcement posture.
Language simplified and narrowed to focus on submitted recordings only; added explicit reference to 'account settings and applicable consent choices' providing user control over AI training use.
View full change record →Under this clause, voice audio submitted to the ElevenLabs platform may be retained and used to train AI models. The agreement indicates that account settings may allow users to adjust these preferences, and applicable consent requirements apply depending on jurisdiction.
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"We collect voice recordings and audio inputs you provide when using our Services. We may use voice data, including recordings you submit, to develop, train, and improve our AI models and voice synthesis technologies, subject to your account settings and applicable consent choices.Excerpt from ElevenLabs's Privacy Policy
1. REGULATORY LANDSCAPE: This provision implicates GDPR (lawful basis for processing, and potentially Article 9 if voice data qualifies as biometric data), CCPA/CPRA (disclosure of training data uses and right to opt out of certain data uses), and state biometric privacy statutes including BIPA (Illinois), CUBI (Texas), and the Washington My Health MY Data Act if voice data is treated as biometric. Enforcement authorities include EU/UK data protection authorities, the California Privacy Protection Agency, and Illinois state courts under BIPA's private right of action. The assertion that voice data may be used for AI training may face constraint under GDPR if the lawful basis relied upon is legitimate interest rather than explicit consent for biometric processing. 2. GOVERNANCE EXPOSURE: High. The use of voice recordings for AI training is an area of active regulatory attention. BIPA carries a private right of action with statutory damages of $1,000 to $5,000 per violation, and several courts have addressed whether AI voice processing falls within its scope. GDPR enforcement actions concerning AI training data have been initiated in multiple EU jurisdictions. The combination of voice data collection and AI training use creates layered exposure across multiple regulatory regimes. 3. JURISDICTION FLAGS: Illinois presents the highest exposure given BIPA's private right of action and broad definition of biometric identifiers that may encompass voice prints. Texas and Washington have analogous statutes with attorney general enforcement. EU and UK users are protected by GDPR and UK GDPR requirements that may require explicit consent for biometric data processing. California's CPRA imposes additional sensitive personal information handling requirements that may apply to voice data. 4. CONTRACT AND VENDOR IMPLICATIONS: Enterprise or API customers integrating ElevenLabs into their own products should evaluate whether downstream collection of end-user voice data through ElevenLabs APIs triggers their own biometric consent obligations. Data processing agreements with ElevenLabs should specify the scope of AI training uses and whether customer-submitted voice data is excluded from model training by contract. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should audit the consent architecture governing AI training uses of voice data, confirm that account-level opt-out mechanisms are operationally implemented and documented, assess whether a biometric data retention and destruction schedule is required under applicable state law, and evaluate whether the policy's disclosure of AI training uses satisfies CCPA data use disclosure requirements at the point of collection.
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This provision authorizes the use of user-submitted voice audio for AI model training, which creates obligations under GDPR lawful basis requirements and may trigger biometric consent statutes in Illinois, Texas, and Washington if voice recordings are characterized as biometric identifiers under those frameworks.
Under this clause, voice audio submitted to the ElevenLabs platform may be retained and used to train AI models. The agreement indicates that account settings may allow users to adjust these preferences, and applicable consent requirements apply depending on jurisdiction.
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