Provision record
ElevenLabs · ElevenLabs Privacy Policy · View original document ↗

Cross-Border Data Transfer

High severity Medium confidence Explicitdocumentlanguage Common · 290 of 352 platforms
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Document Record

What it is

The policy states that personal data is processed and stored in the United States and may be transferred to other countries, and asserts that users consent to such transfers by using the platform.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision asserts consent-based authorization for cross-border data transfers, including from the EU and UK to the United States; under GDPR, consent alone is generally not a sufficient transfer mechanism and the policy does not specify reliance on Standard Contractual Clauses or other adequacy mechanisms, which may require further evaluation.

Interpretive note: The policy does not specify the transfer mechanism relied upon for EU and UK data flows, and the adequacy of consent as a GDPR Chapter V transfer basis for systematic transfers is a matter of active regulatory interpretation.

Change history

modified May 21, 2026

Changed from conditional warning ('If you are accessing') to affirmative consent mechanism ('you consent to'); elevated severity from medium to high by explicitly stating users accept reduced legal protections.

View full change record →

Consumer impact (what this means for users)

Under this clause, personal data submitted by users in the EU, UK, or other jurisdictions is transferred to and processed in the United States. The agreement asserts user consent as the basis for this transfer, though GDPR compliance for such transfers typically requires additional mechanisms beyond consent obtained through terms acceptance.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    EU or UK users who wish to inquire about the transfer mechanisms applied to their data or to exercise GDPR rights in connection with cross-border transfers should email privacy@elevenlabs.io specifying their jurisdiction and request.

How other platforms handle this

Square Medium

to request that your data be transferred to a third party (data portability)

Google Cloud Medium

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.

Roblox Medium

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...

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▸ View Original Clause Language DOCUMENT RECORD
"
ElevenLabs is based in the United States and the information we collect is governed by U.S. law. By accessing or using our Services or otherwise providing information to us, you consent to the processing, transfer and storage of information in and to the U.S. and other countries, where you may not have the same rights and protections as you do under local law.

Excerpt from ElevenLabs's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1. REGULATORY LANDSCAPE: This provision directly implicates GDPR Chapter V (restrictions on transfers of personal data to third countries), UK GDPR transfer rules, and the EU-U.S. Data Privacy Framework. The assertion of consent as the transfer mechanism engages GDPR Article 49 (derogations for specific situations), which permits consent-based transfers only where the consent is explicit, informed, and given after the data subject is told of possible risks. Enforcement authorities are EU member state data protection authorities and the UK ICO. 2. GOVERNANCE EXPOSURE: High. EU data protection authorities have scrutinized consent-based cross-border transfer justifications and have generally held that Article 49 consent derogations are not appropriate as a primary transfer mechanism for systematic, large-scale transfers. The absence of explicit reference to Standard Contractual Clauses, Binding Corporate Rules, or the EU-U.S. Data Privacy Framework in the policy text creates documented uncertainty about the transfer compliance architecture. 3. JURISDICTION FLAGS: EU and UK users face the greatest exposure from this provision given GDPR and UK GDPR transfer restrictions. Users in countries with analogous data localization or transfer requirements (e.g., Brazil under LGPD, India under DPDPA) may also be affected as those regimes develop. 4. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers in the EU or UK using ElevenLabs as a data processor should confirm whether a GDPR-compliant data processing agreement including appropriate transfer mechanisms (SCCs or DPF certification) has been executed with ElevenLabs. The policy text alone does not document the transfer mechanism in sufficient detail for processor due diligence purposes. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should request documentation from ElevenLabs confirming the transfer mechanism in place for EU and UK data flows, verify whether ElevenLabs is certified under the EU-U.S. Data Privacy Framework, and assess whether the consent language in the policy satisfies GDPR Article 49 requirements for derogation-based transfers if SCCs or DPF are not the primary mechanism.

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Full institutional analysis

Regulatory citations, enforcement risk, and due diligence action items.

Applicable agencies

  • FTC
    The FTC enforces the EU-U.S. Data Privacy Framework and has jurisdiction over misrepresentations regarding cross-border data transfer compliance.
    File a complaint →

Applicable regulations

EU AI Act
European Union
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
EU AI Act - High Risk Provisions
EU
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
ElevenLabs Privacy Policy
Entity
ElevenLabs
Document last updated
May 12, 2026
Tracking information
First tracked
May 21, 2026
Last verified
May 21, 2026
Record ID
CA-P-013072
Document ID
CA-D-00834
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
9275d285aa3d9e34e3fda22987a999e8a89717081c303261ff13981c3172e942
Analysis generated
May 21, 2026 04:41 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: ElevenLabs
Document: ElevenLabs Privacy Policy
Record ID: CA-P-013072
Captured: 2026-05-21 04:41:17 UTC
SHA-256: 9275d285aa3d9e34…
URL: https://conductatlas.com/platform/elevenlabs/elevenlabs-privacy-policy/provision/CA-P-013072/cross-border-data-transfer/
Accessed: July 28, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does ElevenLabs's Cross-Border Data Transfer clause do?

This provision asserts consent-based authorization for cross-border data transfers, including from the EU and UK to the United States; under GDPR, consent alone is generally not a sufficient transfer mechanism and the policy does not specify reliance on Standard Contractual Clauses or other adequacy mechanisms, which may require further evaluation.

How does this clause affect you?

Under this clause, personal data submitted by users in the EU, UK, or other jurisdictions is transferred to and processed in the United States. The agreement asserts user consent as the basis for this transfer, though GDPR compliance for such transfers typically requires additional mechanisms beyond consent obtained through terms acceptance.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.

Is ConductAtlas affiliated with ElevenLabs?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by ElevenLabs.