What ElevenLabs means for your app's privacy disclosures

ElevenLabs is a model API. What it involves, whether it needs the tracking prompt, what goes on the App Store labels and the Play Data safety form, and the rejection it is usually behind.

Updated 2026-09-18 · Written from the same rules terms.gg uses to generate documents

What ElevenLabs actually does

Speech synthesis, and voice cloning where you enable it.

What its job necessarily involves

These follow from what the thing is for, so they are true whichever version you installed:

• Text sent for synthesis.
• Voice recordings where cloning is used, which is biometric data in most of the world and changes the legal ground you need.

What to open and check in ElevenLabs

The settings below decide what the honest answer on the forms is, and they are specific to this SDK rather than to its category:

• Whether voice cloning is used, because a voice recording is biometric data in most of the world and needs a different legal ground.
• Whether you hold recorded consent from anyone whose voice you cloned.

ElevenLabs does not need the tracking prompt

Nothing here reads an advertising identifier. So ElevenLabs does not on its own require App Tracking Transparency. That is a statement about this SDK, not about your app: add one ad network or one attribution tool and the prompt applies to everything.

ElevenLabs in Europe: runs on necessity

You cannot deliver the service without it, so ElevenLabs generally rests on the contract with your user rather than on consent. Say plainly in the policy that it is a processor, what it does, and where it runs.

ElevenLabs in California: probably not a sale

ElevenLabs does its job for you rather than for its own commercial purposes, which normally keeps it a service provider rather than a sale. That depends on your contract saying so, and the standard terms usually do.

ElevenLabs on the App Store privacy labels

Apple asks what your app collects, and your app collects whatever its SDKs collect. ElevenLabs is generally declared under App Functionality, alongside whatever the rest of your app does for its own reasons.

ElevenLabs on the Google Play Data safety form

The form asks two things the labels do not: whether data is shared with anyone else, and whether it is encrypted in transit. For this SDK the honest answer is usually collected but not shared, because it processes on your behalf.

Check ElevenLabs's own privacy manifest for ElevenLabs

Since 2024 Apple has required third-party SDKs on its list to ship a signed privacy manifest declaring what they collect and which sensitive APIs they use, and your app's combined manifest is built from them. That file is the authoritative answer for ElevenLabs, it comes from ElevenLabs, and it changes when they ship.

The rejection ElevenLabs is usually behind

Voice cloning was added as a feature and the policy still describes a text app.

What to put in the privacy policy about ElevenLabs

• ElevenLabs named as a processor or a recipient, not hidden behind "our partners".
• What it is for, in a sentence someone would understand without knowing what an SDK is.
• Where it runs, and what makes a transfer outside your region lawful.
• How long the data is kept, which is a question the vendor documents and most policies skip.
• That it processes on your instructions rather than for its own purposes.

Keeping it true after launch

A legal page stops being true the moment the product moves past it, usually by adding a payment provider, an analytics SDK or a sign-in. No store re-checks your pages against your build, so the drift is yours to notice.

• Re-read it whenever you add a dependency that sees user data.
• Re-check what loads on the page after any change: the cookie notice and the policy have to agree.
• Keep the URL stable. Changing where a policy lives breaks every listing that points at it.