Google Gemini updated its privacy notice on April 30, 2026 to clarify its Memory feature and expand the scope of personalization practices. The updated language now lists Memory alongside Voice Match as a feature that relies on user consent. Additionally, the terms changed to state that Gemini can personalize experience based on chat history globally, whereas the prior version restricted this to users outside the European Economic Area, Switzerland, and the UK. The removal of a sentence requiring Activity to remain enabled for the Memory feature represents a change to how the personalization mechanism operates.
The updated notice now explicitly identifies Memory as a feature that operates on the basis of user consent, alongside Voice Match. The revised language removes prior geographic restrictions on personalization, meaning Gemini can now reference chat history to generate personalized insights for all users globally, not just those outside the EEA, Switzerland, and the UK. The removal of the statement 'Keep Activity must be on to use this feature' simplifies the operational requirement but does not establish a new obligation. You can learn how to turn the Memory feature on or off through the updated privacy notice.
The updated terms authorize personalization based on chat history for all users globally, whereas the prior policy restricted this to users outside regulated jurisdictions. This represents a material expansion of the scope of data processing and personalization practices. Organizations that based their vendor assessments or compliance strategies on prior geographic limitations should reevaluate their data processing documentation.
→ Review the updated Memory feature controls to understand how to turn Memory on or off in Gemini settings.
→ If you are an EEA, UK, or Swiss user who previously relied on geographic exclusion from personalization, assess whether the expanded global scope affects your privacy preferences.
→ Gemini will use your chat history to personalize your experience globally under the terms of the updated notice.
→ If you do not adjust Memory settings, past conversations will continue to be referenced for personalization according to the updated policy.
ConductAtlas has recorded 3 material changes to this document over 38 days of monitoring (since March 2026). An additional minor or cosmetic changes were excluded.
2 of Google Gemini's significant changes have been classified as negative for consumers.
Removed geographic restriction; now applies globally instead of only outside EEA, Switzerland, and UK.
Explicitly added Memory to list of features requiring user consent alongside Voice Match.
Removed prior language stating Activity must remain on to use Memory feature.
This change record describes what was added, removed, or modified in the document. Analysis reflects what the updated agreement states or permits. It does not constitute a legal determination about enforceability. Applicability may vary by jurisdiction. Methodology
Google can now use your past Gemini conversations to personalize your experience regardless of where you live.
The policy no longer explicitly states that you must keep Activity enabled to use Memory, though controls remain available.
This change broadens the geographic scope of personalization practices from a restricted set of jurisdictions to all users globally. Previously, users in the EEA, Switzerland, and UK were excluded from personalization based on chat history. The updated terms now authorize personalization for all users. The explicit naming of Memory as a consent-based feature aligns with the addition of Memory controls in the privacy disclosure. Organizations that have assessed Google Gemini's privacy practices based on prior geographic restrictions should reevaluate compliance posture under the expanded global scope. The change does not appear to impose new contractual obligations on organizations using Gemini, but those conducting data processing impact assessments or vendor evaluations may need to update their findings.
GDPR, EDPB guidance on consent and automated decision-making, CCPA, UK data protection regime, Swiss FADP
Full compliance analysis
Obligation analysis, escalation trigger, board language, and recommended action.
Watcher: regulatory citations + obligations. Professional: full compliance memo.
ConductAtlas provides verified policy intelligence sourced directly from platform documents. All analysis is intended to support, not replace, legal and compliance review. Record CA-C-001497.
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