Best GDPR-compliant AI notetaker for EU companies (2026)
An honest guide for EU companies: what to check, what to ask the vendor, and which tools host where, with every fact sourced and dated.
In this article
No AI notetaker is “GDPR-certified”; no such certificate exists. The best GDPR-compliant AI notetaker for an EU company is one with an Article 28 DPA, defensible data location and transfers, no training on your meetings, and a fit with your consent and works council rules. For EU hosting, Jamie and tl;dv lead; for bot-free team notes, Reline (US-hosted).
We make Reline, so read this as a vendor’s guide. Reline captures audio bot-free on your device, but transcription, AI and storage run in the cloud in the USA under the EU Standard Contractual Clauses. Reline has no EU data residency and no SOC 2. Every competitor fact below comes from that vendor’s own pages, checked on 21 October 2026, and may change.
What does “GDPR-compliant” mean for an AI notetaker?
When your company records a meeting, you are the controller and the notetaker vendor is your processor. A meeting recording is personal data: voices, names, opinions, sometimes special categories such as health. Compliance therefore sits with you, and the vendor’s job is to make it possible. These are the six areas a data protection officer will look at.
1. A DPA under Article 28 GDPR
You need a data processing agreement with every vendor that processes meeting data for you, bot or no bot. Check that it covers the plan you actually buy. Jamie’s pricing page lists DPAs on Enterprise only. Fireflies’ help article describes its processor role for Business and Enterprise. Reline’s DPA at reline.so/dpa is pre-signed and applies to all workspaces. Also read the sub-processor list: it tells you who else touches the data and in which country.
Processing by a processor shall be governed by a contract or other legal act under Union or Member State law, that is binding on the processor with regard to the controller. (Art. 28(3) GDPR)
2. Data location versus data transfers
“Hosted in the EU” and “GDPR-compliant” are different claims. The GDPR does not forbid processing in the USA; it requires a transfer mechanism. The two common ones are the EU-U.S. Data Privacy Framework (an adequacy decision from July 2023 that covers certified US companies) and the Standard Contractual Clauses, usually with a transfer impact assessment. The EU General Court upheld the Data Privacy Framework on 3 September 2025; an appeal is pending at the Court of Justice (case C-703/25 P). Its predecessor, Privacy Shield, was struck down in 2020, which is why many data protection officers prefer EU processing where it exists.
Also separate storage from processing. Per Fireflies’ security FAQ, its Private Storage option keeps content in the EU, but Fireflies still processes it in the United States. tl;dv’s German site says data is hosted and stored in the EU but does not say where AI processing happens. Ask both questions.
3. Retention and deletion
Storage limitation (Art. 5(1)(e) GDPR) means you should keep recordings no longer than needed. Ask how long audio, transcripts and AI outputs live, whether deleting a meeting deletes all of them, and how long backups keep them. Per their own pages, Jamie and Granola do not store meeting audio. Fireflies purges a deleted meeting immediately and deletes account data within 30 days. Reline purges deleted notes from trash after 30 days, with transcript, recording and AI outputs, and keeps backups for up to 30 days.
4. Training AI models on your meetings
There are two questions: does the vendor train its own models on your data, and are its AI providers barred from doing so? Answers differ more than marketing suggests. Otter’s privacy policy says it trains its proprietary AI on de-identified audio recordings and transcriptions. Fathom’s privacy policy says that, depending on your account settings, it may use de-identified meeting data to train its in-house models. Granola’s security page says it trains on anonymised data unless you opt out, with training off by default on Enterprise. Jamie, tl;dv and Fireflies say they do not train on your data. Reline does not train models on your data, and its AI providers are barred from it by their API terms.
5. Participants’ consent and transparency
Everyone in the meeting must know they are being recorded and why (Articles 13 and 14 GDPR), and you need a lawful basis under Article 6. National law adds more: in Germany, Section 201 of the Criminal Code makes recording non-public spoken words without authorisation a criminal offence. In practice, tell everyone in the invite and again at the start, and get consent where the law requires it. A bot-free tool removes the visible bot from the call, not this duty. Reline publishes a notice for meeting participants at reline.so/participants.
6. Works council, DPIA and the AI Act
In Germany, the works council co-determines technical equipment that is capable of monitoring employees’ behaviour or performance (Section 87(1) no. 6 Works Constitution Act), and a meeting recorder usually qualifies. Other countries, such as Austria and the Netherlands, have comparable co-determination rules. Systematic recording of staff may also call for a data protection impact assessment under Article 35 GDPR. Finally, if a tool infers emotions from employees’ voices, check Article 5(1)(f) of the EU AI Act, which bans emotion recognition in the workplace (with narrow exceptions) since 2 February 2025.
What should EU companies check before signing?
- Get the DPA and confirm it covers your plan, not only Enterprise.
- Read the sub-processor list: who processes the data and in which country.
- Ask where data is stored and where it is processed, and which transfer mechanism applies (Data Privacy Framework, Standard Contractual Clauses).
- Check retention: audio, transcripts, AI outputs, backups, and what happens when you delete a meeting or close the account.
- Check AI training: the vendor’s own models and its AI providers, and whether an opt-out exists.
- Decide whether a bot in the call is acceptable to your clients and candidates.
- Prepare a recording notice for participants and a consent step where the law requires it.
- Involve your data protection officer and works council early; run a DPIA if needed.
Which AI notetakers fit EU companies? Sourced comparison
Facts below come from each vendor’s own pages, checked on 21 October 2026 (homepage, pricing, security page or privacy policy). “Per vendor” is deliberate: we report what the vendor says, not an audit. Where a page was silent, we say so.
| Tool | Bot in the call? | Where data lives (per vendor) | DPA | Trains on your data? |
|---|---|---|---|---|
| Reline | No: microphone and system audio captured locally (macOS, Windows, Linux (beta), browser) | USA (Reline and its sub-processors), EU Standard Contractual Clauses | Pre-signed at reline.so/dpa, all workspaces | No; AI providers barred by their API terms |
| Jamie | No: runs on your device | Storage and processing within the EEA, Switzerland and the UK | Listed on Enterprise only (pricing page) | No, per Jamie |
| tl;dv | Bot, or capture from your device without a bot | Hosted and stored in the EU (German site); AI processing location not stated | Not mentioned on the pricing page; ask tl;dv | No, per tl;dv |
| Fireflies.ai | Bot by default (Fred); bot-free options | USA by default; EU storage via Private Storage (Enterprise), processing still in the USA | Published; processor role described for Business and Enterprise | No, per its security FAQ |
| Otter.ai | Bot by default (OtterPilot); bot-less mode available | AWS in the USA; no EU hosting option found; transfers via Data Privacy Framework and SCCs (privacy policy) | Not stated on the pages we checked | Yes: its own AI on de-identified audio and transcriptions (privacy policy) |
| Granola | No: device audio | US-hosted AWS | Available on request | Anonymised data unless you opt out; off by default on Enterprise |
| Fathom | Bot or bot-free | Hosted in the USA; no EU hosting stated; transfers via Data Privacy Framework and SCCs (privacy policy) | Published at fathom.ai/dpa (privacy policy); signed copy for EU and UK customers on request | Depends on account settings: de-identified data for in-house models, opt-out in settings; third parties barred |
| Tool | Certifications (per vendor) | Price (per vendor, October 2026) |
|---|---|---|
| Reline | None: no SOC 2, no ISO 27001, no HIPAA | Free; Professional $15/user/mo ($12 annual); Enterprise $32 ($26 annual) |
| Jamie | ISO 27001; SOC 2 Type II marked “pending” (pricing page) | Free (10 AI notes/month, 30-min meetings); Pro €39/mo billed annually; Team €33/seat/mo billed annually |
| tl;dv | Says it is SOC 2 compliant (German site) | Free; Pro €18/seat/mo annual (€29 monthly); Business €29 (€39 monthly) |
| Fireflies.ai | SOC 2 Type 2; HIPAA with a BAA (security FAQ) | Free; Pro $10/seat/mo annual ($18 monthly); Business $19 ($29); Enterprise $39 annual |
| Otter.ai | SOC 2 Type 2 (privacy and security page); HIPAA as an Enterprise add-on; SSO and SCIM (pricing page) | Basic free; Pro $16.99/user/mo monthly or $8.33 annual; Business $30 monthly or $19.99 annual |
| Granola | SOC 2 Type II | Basic free; Business $14/user/mo; Enterprise $35/user/mo |
| Fathom | SOC 2 Type II and HIPAA (help center); signed HIPAA BAA listed on the pricing page | Free; Premium $20/mo ($16 annual); Team $19/user ($15 annual, 2-user minimum); Business $34 ($25 annual) |
How to read this: if EU hosting is a hard requirement, start with Jamie (storage and processing in the EEA, Switzerland and the UK, per Jamie) or tl;dv (ask where AI processing happens). If formal certifications decide, Fireflies, Granola, Otter and Fathom state SOC 2 Type 2 and Jamie lists ISO 27001. If training on your meetings is a red line, read the privacy policy, not the homepage: Otter, Fathom and Granola all describe some form of training on de-identified or anonymised data.
Where does Reline fit, honestly?
Reline captures your microphone and system audio locally on your computer, so no participant joins the call and no join notice appears. Live transcription in 60+ languages, AI summaries and storage then run in our cloud in the USA. You keep the full transcript and the recording, with a play button on every transcript line, in a notepad your team edits together. Notes are private by default, with five permission levels per note and folder, and the interface is available in English, German, French, Spanish, Japanese, Portuguese and Arabic.
The trade-off is plain: Reline offers no EU data residency and no SOC 2. It fits when the bot in the call is your main problem and your data protection officer accepts US processing under the Standard Contractual Clauses in a DPA that covers every plan. If not, pick one of the EU-hosted tools above.
Replacing Fireflies specifically? Our Fireflies alternative guide goes through the switch step by step. For a German-language round-up of every tool on the data-protection axis, see our GDPR check of AI meeting assistants.
Common questions
- Is any AI notetaker GDPR-certified?
- No. There is no official “GDPR certificate” for software, so a “GDPR-certified” label is marketing. What exists are DPAs, transfer mechanisms, security certifications such as SOC 2 or ISO 27001, and your own documentation. Compliance depends on how you deploy the tool. Not legal advice.
- Can an EU company use a US-hosted AI notetaker under the GDPR?
- Usually yes, if a valid transfer mechanism applies: the EU-U.S. Data Privacy Framework for certified companies, or the Standard Contractual Clauses with a transfer impact assessment. The Framework was upheld by the EU General Court in September 2025, but an appeal is pending, so many DPOs prefer EU processing where it is available. Not legal advice.
- Which AI notetakers keep data in the EU?
- Per their own pages as of 21 October 2026: Jamie keeps storage and processing within the EEA, Switzerland and the UK, and tl;dv says data is hosted and stored in the EU. Fireflies offers EU storage via Private Storage on Enterprise, but processes in the USA. Reline, Granola, Otter and Fathom do not offer EU hosting.
- Do I need consent to record a meeting with an AI notetaker in the EU?
- You need a lawful basis and must inform everyone recorded; several national laws, such as Section 201 of the German Criminal Code, also require authorisation to record spoken words. In practice, announce the recording and get consent. Bot-free capture removes the visible bot, not that duty. Not legal advice.
- Does the works council have to approve an AI notetaker?
- In Germany, often yes: under Section 87(1) no. 6 Works Constitution Act, the works council co-determines tools capable of monitoring behaviour or performance, which usually covers meeting recorders. Austria and the Netherlands have comparable rules. Settle it before rollout. Not legal advice.
- Where does Reline store meeting data?
- In the USA. Reline captures audio locally on your device; transcription, AI summaries and storage run in the cloud with Reline and its sub-processors in the USA, covered by the EU Standard Contractual Clauses in the DPA at reline.so/dpa. Reline does not train models on your data and offers no EU data residency.
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