Google updated the Gemini Apps Privacy Notice on March 21, 2026, replacing generic references to 'personalization based on past Gemini chats' with the branded feature name 'Memory.' The document date was updated from March 10 to March 20, 2026. This is a terminology clarification with no substantive change to data processing practices or user rights. No immediate compliance action is required, but organizations with AI-tool usage policies referencing Gemini's personalization settings should note the new feature name for documentation consistency.

This change is primarily a terminology update and does not materially alter data processing activities. However, the following frameworks remain relevant to the underlying Memory/personalization feature: (1) GDPR Art. 13(2)(b) — purposes of processing and legal basis must reflect the named feature 'Memory'; Art. 5(1)(a) transparency principle requires that feature naming in privacy notices be clear and consistent with the actual product. (2) GDPR Art. 22 — if Memory involves automated decision-making or profiling, naming it explicitly as a feature could trigger additional transparency or opt-out obligations. (3) Cal. Civ. Code §1798.100 (CCPA/CPRA) — California consumers' right to know about personal information use for profiling applies; the renaming to 'Memory' should be consistently reflected across all consumer-facing disclosures. (4) UK GDPR Art. 13 — same transparency requirements apply for UK users. (5) EU AI Act (Regulation 2024/1689) — if Memory constitutes a component of a general-purpose AI system, transparency obligations under Art. 13 and 52 may apply to how the feature is described. No enforcement actions or supervisory opinions are directly triggered by this terminology change alone.

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