I was unable to find the answers on the dialogflow/google terms of use/privacy statement, so I ask here:
Thanks!
Where the API servers are has no bearing on GDPR. What matters are where the users are that it is storing data about; if they may be in the EU, the GDPR applies, i.e. it probably does.
The applicable Dialogflow T&Cs seem to be here. It doesn t appear to list what dialogflow stores or processes specifically, but it says it incorporates Google s general API terms, which in turn link to Google s overall privacy policy, which should tell you what you need.
When dealing with any US-based company (such as Google) that may handle EU personal data, you should check that they are registered with the Privacy Shield scheme, which (not surprisingly) Google is. That should mean you re largely compliant (subject to what data you are collecting and on what grounds), but have a contingency plan for what happens if Privacy Shield collapses, which is entirely possible and fairly likely.
Where the API servers are, make a huge difference.
I think that any Google services transfer personal data outside the EEA (i.e.: the IP address is a personal data). The Privacy Shield is no longer sufficient for GDPR compliance. Therefore, it might be important to consider what happened with Google Analytics recently.
Currently, Google Analytics is not GDPR compliant, and cannot be compliant as long as personal data are not retained in the European Economic Area or other countries whitelisted by European authorities.
As of today, Austria, Denmark, Finland, France, Italy, and Norway Data Protection Authorities have taken a stance against Google Analytics.
You can read more details at the following weblinks:
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