The European Data Protection Board has issued final guidelines on virtual voice assistants.

The guidelines appear to be largely unchanged from the draft issued in February for public consultation.

The main change is noting that even if VVAs are themselves a software service, they always operate through a physical device such as a smart speaker or smart TV. VVAs use electronic communication networks to access these physical devices that constitute “terminal equipment” in the sense of the e-Privacy Directive.

Therefore, the provisions of Art 5(3) of the e-Privacy Directive apply whenever a VVA stores or accesses information in the physical device linked to it.

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