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EuroCommerce welcomes the opportunity to provide comments on the European Data Protection Board’s (“EDPB“) Guidelines 02/2021 on Virtual Voice Assistants (the “Guidelines”). EuroCommerce appreciates the EDPB’s efforts to provide guidelines for Virtual Voice Assistants (“VVA“) with the aim to guarantee adequate privacy protection for users as the service is available for a vast majority of people when using for example their smartphones. In light of the foregoing, EuroCommerce believes that it is important that such guidelines remain sufficiently open and flexible so that they can take into account the specific characteristics of the different voice service architectures and the rapid technological developments in the VVA sector. In this regard, the legal framework should allow for use of VVA solutions in a way that is not to the detriment of digital innovation as well as European businesses’ competitiveness on the global market.
Below we summarise our key points and proposals and detailed comments which we hope will be helpful when finalising the Guidelines. We would be more than pleased to discuss these issues further with the EDPB should you have any questions regarding our comments.Read more