Gemini uses cookies and other tracking technologies to collect information about your device and browsing behavior on the platform.
This analysis describes what Gemini's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
Cookies and tracking technologies can collect detailed behavioral data about how you use the platform, which may be shared with advertising and analytics partners.
Interpretive note: The policy references a separate cookies section but the full text of that section was not rendered in the provided document, creating some uncertainty about the specific tracking technologies and opt-out mechanisms described.
Gemini's use of cookies and tracking tools means your browsing patterns, device identifiers, and potentially session data are collected and may be shared with third-party analytics and advertising vendors. The consent management code on the site indicates a differentiated approach for EEA/UK users (opt-in required) versus US users (opt-out model).
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"4. Cookies and other Tracking Technologies— Excerpt from Gemini's Gemini Privacy Policy
(1) REGULATORY LANDSCAPE: Cookie and tracking technology use engages the EU ePrivacy Directive (Cookie Law), GDPR consent requirements for non-essential tracking, CCPA/CPRA's definition of 'sale' and 'sharing' as potentially applicable to cookie-based data flows to advertising networks, and FTC guidance on online tracking. The page source confirms Google Tag Manager is deployed with a consent management configuration that distinguishes EEA/UK (opt-in, stricter) from US (opt-out model). (2) GOVERNANCE EXPOSURE: Medium. The deployment of Google Tag Manager with advertising and analytics tags creates data flows to Google and potentially other third parties. The adequacy of the consent management implementation should be verified against GDPR requirements, particularly the timing of tag firing relative to consent acquisition, which the source code attempts to address by pre-loading consent state before GTM fires. (3) JURISDICTION FLAGS: EEA and UK users require prior informed consent for non-essential cookies under GDPR and the ePrivacy Directive. California CPRA users may have opt-out rights for cookie-based sharing for cross-context behavioral advertising. Illinois, Texas, and Washington cookie practices may engage biometric and sensitive data rules if cookies capture behavioral data combined with biometric identifiers. (4) CONTRACT AND VENDOR IMPLICATIONS: Data processing agreements with cookie-based analytics and advertising vendors should specify data retention limits, prohibited uses, and compliance with applicable regulations. The Google Tag Manager relationship should be reviewed to confirm compliance with Google's data processing terms under GDPR. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should audit the cookie consent management implementation to verify that (a) tags do not fire before consent is granted for EEA/UK users, (b) the consent categories accurately reflect the actual data flows, and (c) opt-out mechanisms for US users are functional and honored by downstream vendors. A cookie audit identifying all active tracking technologies and their purposes would support this review.
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Cookies and tracking technologies can collect detailed behavioral data about how you use the platform, which may be shared with advertising and analytics partners.
Gemini's use of cookies and tracking tools means your browsing patterns, device identifiers, and potentially session data are collected and may be shared with third-party analytics and advertising vendors. The consent management code on the site indicates a differentiated approach for EEA/UK users (opt-in required) versus US users (opt-out model).
ConductAtlas has identified this type of provision across 78 platforms. See the full comparison.
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