Google Gemini updated its privacy notice on May 19, 2026 to add new disclosure sections, clarify how data collection works with new features like Gemini Spark and Avatars, and refine language around data use and retention. The notice now explicitly describes how the platform collects information about AI reasoning steps, distinguishes between different Connected Apps scenarios, and adds a section on avatar creation data. The operational difference is that users now have more detailed disclosure of what data types are collected and how specific features process information.
The updated notice adds new disclosure sections explaining how data flows when using Gemini Spark (remote browser and computer access), how avatar creation collects and processes information, and clarifies that Google collects information about AI reasoning steps during task execution. The notice also refines language around subscription information to specify 'Google AI plan' rather than just generic 'paid subscription.' These changes do not establish new obligations but rather expand the transparency disclosures provided to users about existing and new features.
The updated notice expands transparency around two new Gemini capabilities (Spark with remote access and Avatars) and clarifies that data collection includes information about AI reasoning and task execution steps. This allows users to understand what data flows occur when using these features, though it does not establish new user controls or opt-out mechanisms for the disclosed practices.
ConductAtlas has recorded 4 material changes to this document over 58 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.
New section explicitly describes data collection when using remote browser and remote computer access features.
New section discloses what data is collected when users create avatars in Gemini Apps.
Updated language clarifies that Google collects information about AI model thinking steps and task execution processes.
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
This update primarily represents enhanced privacy notice transparency rather than new operational obligations. Google has added disclosures for two new Gemini features (Spark with remote access capabilities and Avatars) and clarified the scope of data collection related to AI reasoning. Organizations using Gemini in their infrastructure should review whether these new feature disclosures affect their own privacy notices or data processing agreements, particularly if they reference Gemini's practices or offer Gemini to users. No new contractual obligations appear to be imposed on third parties, but DPAs may benefit from review if they contain feature-specific carve-outs or limitations.
GDPR (Article 13/14 transparency requirements), CCPA (California Consumer Privacy Act disclosure requirements), EU AI Act (transparency regarding AI systems and their outputs). The enhanced disclosures about AI reasoning steps and remote access features may engage regulatory transparency requirements in multiple jurisdictions.
Full compliance analysis
Obligation analysis, escalation trigger, board language, and recommended action.
Monitor: regulatory citations + obligations. Compliance: 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-002221.
See the full side-by-side comparison of every sentence added, removed, and modified.
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