Gemini retains your personal data for a period of time after your account is closed or your relationship with Gemini ends, as required by law or for legitimate business purposes.
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
Understanding how long your data is retained is important, particularly given the sensitivity of the financial and identity data Gemini collects and the regulatory requirements that mandate retention of financial records.
Interpretive note: The full content of the retention section was not rendered in the provided document, creating significant uncertainty about the specific retention periods and criteria Gemini applies.
Your personal data, including identity documents and transaction records, will be retained by Gemini for a period following account closure, driven primarily by AML, tax, and financial regulatory requirements that require multi-year record retention. You may not be able to fully delete your data even after closing your account.
How other platforms handle this
We retain personal information for as long as necessary to provide our services, comply with legal obligations, resolve disputes, and enforce our agreements. The specific retention periods depend on the type of information and the purposes for which it is processed.
We keep information for as long as we need it to provide our products, comply with legal obligations, or for other legitimate purposes, such as to maintain safety, security, and integrity.
After your account is deleted, we keep data about interactions you've had on our service to prevent abuse, ban evaders and others in an effort to protect and ensure the safety and security of our service and our members.
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"9. Retention— Excerpt from Gemini's Gemini Privacy Policy
(1) REGULATORY LANDSCAPE: Retention obligations for a digital asset exchange are primarily driven by BSA/AML requirements (FinCEN regulations requiring 5-year retention of certain transaction records), IRS reporting obligations, and OFAC compliance documentation. GDPR's data minimization and storage limitation principles require that retention periods be no longer than necessary for the stated purpose, creating a tension with broad financial regulatory retention mandates for EU user data. (2) GOVERNANCE EXPOSURE: Medium. The policy references a retention section but the full retention schedule was not rendered in the provided document. Absent clearly defined retention periods tied to specific data categories and legal bases, there is regulatory exposure particularly for GDPR-governed data. (3) JURISDICTION FLAGS: EU and UK users have the strongest claims to defined retention periods under GDPR's storage limitation principle. California CPRA requires disclosure of retention periods or criteria for determining them. GLBA and BSA mandates will limit the practical ability to delete financial records for all users. (4) CONTRACT AND VENDOR IMPLICATIONS: Vendors receiving personal data from Gemini should have contractually defined retention and deletion obligations that align with Gemini's own retention schedule to avoid downstream retention beyond the permitted period. (5) COMPLIANCE CONSIDERATIONS: Legal teams should confirm that a detailed retention schedule exists internally, is mapped to specific data categories and legal bases, and is reflected in the public-facing privacy policy with sufficient specificity to satisfy CPRA and GDPR disclosure requirements.
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Understanding how long your data is retained is important, particularly given the sensitivity of the financial and identity data Gemini collects and the regulatory requirements that mandate retention of financial records.
Your personal data, including identity documents and transaction records, will be retained by Gemini for a period following account closure, driven primarily by AML, tax, and financial regulatory requirements that require multi-year record retention. You may not be able to fully delete your data even after closing your account.
ConductAtlas has identified this type of provision across 65 platforms. See the full comparison.
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