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Elevenlabs

Elevenlabs (AI voice platform) exhibits consent bypass (C09). Audio interaction tracking begins before consent flow integration.

5 IOCs4 detections100% pre-consent3 sites
70
Vendor Risk Score

How This Briefing Works

This report opens with key findings, then maps the gaps between what Elevenlabs discloses and what BLACKOUT observed at runtime. From there: what it means for your organization, what to do about it, and the detection data and evidence underneath.

Key Findings

Key Findings

4 detections across 3 sites100% pre-consent activity
CRITICAL

Pre-Consent Activity

Elevenlabs was observed loading and executing before user consent was obtained on 100% of sites where it was detected.

GDPRePrivacy
Disclosure Gaps

Claims vs. Observed Behavior

1 gaps

pending

UNKNOWN
They Claim

“Unknown - requires claims extraction via CDT”

Observed Behavior

Runtime evidence shows C09 pattern

Customer Impact

What This Means For You

Embedded AI services create processor relationship. Text-to-speech input may contain sensitive content. Consent bypass means no lawful basis for processing before user interaction. GDPR Article 28 requires DPA before processing begins.
Recommended Actions

What To Do About It

Role-specific actions based on observed behavior

If You Use Elevenlabs

  • →Confirm consent before Elevenlabs script loads
  • →Review DPA: is user input data used for model training?
  • →Audit what audio interaction data is collected

If You're Evaluating Elevenlabs

  • →Test: does Elevenlabs load before consent banner?
  • →Ask: is voice synthesis input used for AI training?
  • →Verify privacy policy discloses audio data collection

Negotiation Leverage

  • →C09 consent bypass observed. How do you ensure consent before audio tracking?
  • →Is user text-to-speech input used for model training? This requires explicit disclosure.
  • →Embedded AI creates processor relationship. Do you have GDPR Article 28 DPA in place?
Runtime Detections

Runtime Detections

1 BTI-C CODES

BLACKOUT observed this vendor's JavaScript executing in a live browser and classified each hostile behavior using our BTI-C (Behavioral Threat Intelligence — Capability) taxonomy. These are not theoretical risks — each code below was triggered by something we watched this vendor's code actually do.

BTI-C09Consent Bypass

Ignoring CMP signals

IOC Manifest

IOC Manifest

3 INDICATORS

Indicators of compromise across 3 categories. Use for detection rules, CSP policies, or Pi-hole blocklists.

No indicators in this category

Ecosystem

Ecosystem & Supply Chain

AI voice stack. Often embedded in content platforms, e-learning, accessibility features. Audio interaction data may feed model training or usage analytics without clear disclosure.
Evidence

Evidence Artifacts

Artifacts collected during analysis, available with evidence-tier access.

HAR Capture

Complete network capture with all requests and responses

IOC Manifest

5 detection signatures across scripts, domains, cookies, and network endpoints

Vendor Details