Is Voiceflow GDPR compliant?

What does Voiceflow do?

A builder for conversational assistants whose runtime is embedded in the page. Because the assistant is generative, it also triggers the Article 50 duty to tell people they are talking to AI.

Does Voiceflow need consent?

Yes. Voiceflow 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 Voiceflow send data outside the EEA?

Yes. Voiceflow 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 Voiceflow?

How do we detect Voiceflow?

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