Gemini Privacy Policy

This document is Gemini's Privacy Policy (dated November 5, 2025), governing the collection, use, and disclosure of personal information by Gemini entities across their digital asset and cryptocurrency exchange platform, with stated legal basis rooted in contractual necessity, regulatory compliance (including GLBA, AML/KYC obligations), and user consent. The policy states that Gemini collects an extensive range of personal data including government-issued identity documents, financial account information, transaction history, biometric data (for identity verification), device identifiers, location data, and behavioral/browsing data, and the terms authorize sharing this information with affiliated entities, service providers, advertising partners, data analytics vendors, financial institution partners, and government or law enforcement agencies upon request. Notably, Gemini asserts GLBA financial institution status to claim exemption from many state privacy laws, which narrows the statutory rights available to US consumers under frameworks such as CCPA; the policy also reserves unilateral right to amend terms at any time at Gemini's sole discretion, a provision that is common in the industry but operationally significant given the breadth of data collected. The policy engages GLBA, CCPA (with carve-outs), GDPR and UK GDPR for EEA and UK users, FinCEN AML/KYC requirements, and COPPA for minors; EU and UK users are directed to a separate privacy notice, and California residents are directed to jurisdiction-specific disclosures, making compliance evaluation jurisdiction-dependent.