Fireflies.ai GDPR and Data Protection: Visible Bot, Risky Data Transfers

Fireflies.ai GDPR and Data Protection: The Basic Problem

Fireflies.ai is an AI-powered meeting assistant that automatically records, transcribes, and summarizes conversations. It joins meetings as a visible bot — a positive step for transparency under GDPR. However, like many U.S.-based services, Fireflies processes data on servers outside the EU, primarily in the United States. This creates significant challenges for organizations that must comply with European privacy laws.

How Fireflies.ai Works: Visible Bot Is an Advantage

Fireflies connects to meetings through bot integration. The bot appears in the participant list and is usually labeled to indicate its recording or transcription function. This visibility helps alert participants that the meeting is being documented.

The following data may be processed:

• Spoken content (converted to text)
• Speaker identity and timestamps
• Contextual meeting data (e.g. title, date, attendees)
• Additional integrations with calendars, CRM systems, and collaboration tools

While this visibility improves transparency, it does not replace the need for legal consent.

Fireflies.ai GDPR and Data Protection: Visibility isn't Enough

Having a visible bot is helpful, but it’s not a free pass. Under GDPR, users must still fulfill strict transparency and consent requirements:

• Article 5(1)(a): Processing must be lawful, fair, and transparent
• Article 13: Data subjects must be informed
• Article 6: A legal basis (such as consent or legitimate interest) is required

Organizers should inform all participants before or at the start of the meeting and obtain consent — especially during sensitive conversations.

Servers Outside the EU: A Major Concern

Fireflies.ai processes and stores user data primarily in the U.S. While it offers EU data hosting under enterprise plans, these are not standard for all users.

Why this matters:

• The U.S. is not considered a fully safe third country under EU law (per Schrems II)
• U.S. authorities may access data under laws such as the CLOUD Act
• GDPR requires safeguards for international data transfers (e.g., SCCs or DPF membership)

Without contractual protections and strong technical measures, using Fireflies can be risky for EU-based companies.

Fireflies.ai GDPR and Data Protection: Where the Difficulties Lie

Fireflies offers more transparency than many tools thanks to its visible bot. However, GDPR-compliant use still requires:

• Consent from all participants for data processing
• Contractual safeguards such as Standard Contractual Clauses (SCCs)
• Technical and organizational security measures

Smaller companies may find these steps hard to implement in day-to-day operations.

Fireflies.ai GDPR and Data Protection: Theory vs. Practice

In practice, Fireflies is often used without properly informing participants or obtaining valid consent. The visible bot is present, but most users do not explain what is being recorded, how it will be stored, or where the data will go. This creates legal uncertainty, especially when external guests or sensitive topics are involved.

Conclusion: Fireflies.ai Can Be GDPR-Compliant — But Only with Effort

Fireflies offers a good technical foundation with its visible bot and structured features. But reliance on U.S. servers and a lack of default EU hosting pose serious concerns for GDPR compliance.

To minimize risk, users should:

• Provide clear information to all participants
• Obtain explicit consent, particularly for sensitive discussions
• Explore EU hosting options where possible

Alternatively, organizations may opt for tools like Sally, which combine visible bots with exclusive EU-based hosting, offering a more straightforward path to compliance.

Disclaimer: This article is for informational purposes only and does not constitute legal advice.