Gemini claims it is a financial institution under the federal Gramm-Leach-Bliley Act, which it says exempts it from many state privacy laws including parts of the CCPA.
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
This provision establishes the regulatory framework applicable to Gemini's data handling practices. By asserting GLBA status, Gemini indicates its privacy obligations derive from federal banking privacy standards rather than state-level privacy laws, which may impose different notice, consent, or data handling requirements.
Your standard state-level privacy rights — such as the right to opt out of data sale under CCPA — may not apply to Gemini, potentially limiting your control over how your financial and personal data is used.
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"As a financial institution under the Gramm-Leach-Bliley Act ("GLBA"), Gemini's privacy practices are subject to federal law and therefore are exempt from many state privacy laws.Excerpt from Gemini's Privacy Policy
Gemini's assertion of GLBA financial institution status is material for due diligence; it limits CCPA applicability (per the CCPA financial data exemption) and shifts the compliance framework to federal Regulation P requirements.
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This provision establishes the regulatory framework applicable to Gemini's data handling practices. By asserting GLBA status, Gemini indicates its privacy obligations derive from federal banking privacy standards rather than state-level privacy laws, which may impose different notice, consent, or data handling requirements.
Your standard state-level privacy rights — such as the right to opt out of data sale under CCPA — may not apply to Gemini, potentially limiting your control over how your financial and personal data is used.
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