Is Google Dialogflow GDPR compliant?

What does Google Dialogflow do?

Google's conversational platform, often embedded through its df-messenger element. It carries Google's transfer question along with the AI disclosure duty of any assistant that talks to people.

Does Google Dialogflow need consent?

Yes. Google Dialogflow is Chat, which is never strictly necessary for a website to function. Under ePrivacy Article 5(3), and its national transpositions, storing or reading anything on the device for that purpose requires consent first, and that consent has to be as easy to refuse as it is to give.

ePrivacy Art. 5(3) · TDDDG § 25 (DE) · TKG 2021 § 165(3) (AT) · GDPR Art. 6(1)(a)

Does Google Dialogflow send data outside the EEA?

Yes. Google Dialogflow processes data outside the European Economic Area, so you need a transfer mechanism under Chapter V and you have to say so in your privacy policy. In practice this means standard contractual clauses, or a provider certified under the EU-US Data Privacy Framework.

GDPR Art. 44 · GDPR Art. 46

What can I use instead of Google Dialogflow?

How do we detect Google Dialogflow?

We load your page in a real browser as a first-time visitor who clicks nothing, then look at what it contacted. Google Dialogflow is recognised by requests to dialogflow.com and dialogflow.cloud.google.com, and we report whether it merely loaded or actually sent data, and whether it set a cookie before any choice was made.