Gemini transfers personal data internationally, including potentially from the EU or UK to the US or other countries, subject to appropriate safeguards.
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
International data transfers from the EU and UK are subject to GDPR transfer restrictions, and Gemini's compliance with these requirements affects the legal basis for processing EU and UK user data.
Interpretive note: The main policy does not describe the specific transfer mechanisms used for international data transfers; the full content of this section was not rendered in the provided document.
If you are an EU or UK user, your personal data may be transferred to the United States or other countries where data protection standards may differ from those in your jurisdiction. The adequacy of Gemini's transfer mechanisms determines the protections applicable to your data in transit and at rest abroad.
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Your personal information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.
Your personal information may be transferred to, stored, and processed in the United States or other countries outside of your country of residence, which may have data protection laws that are different from those in your country.
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"10. International Transfers— Excerpt from Gemini's Gemini Privacy Policy
(1) REGULATORY LANDSCAPE: International data transfers from the EEA and UK are governed by GDPR Chapter V and UK GDPR respectively. Transfers to the US require either reliance on an adequacy decision (EU-US Data Privacy Framework for qualifying US companies), Standard Contractual Clauses, or Binding Corporate Rules. The policy references a separate EU/UK privacy notice, suggesting transfer mechanisms are addressed there rather than in this document. (2) GOVERNANCE EXPOSURE: Medium. The main policy does not specify the transfer mechanisms used for EEA/UK user data, which creates uncertainty about compliance status. If Gemini relies on the EU-US Data Privacy Framework, its certification status should be verified. If SCCs are used, their implementation and supplementary measures should be current following the Schrems II ruling. (3) JURISDICTION FLAGS: EEA and UK users have the highest exposure given GDPR's strict transfer restrictions. Singapore-based users (the policy references a Singapore locale) may also have data transfer considerations under PDPA. (4) CONTRACT AND VENDOR IMPLICATIONS: All data processing agreements with non-EEA/UK vendors receiving EEA/UK user data should include appropriate transfer mechanisms. Procurement teams should verify transfer compliance for analytics, advertising, and identity verification vendors. (5) COMPLIANCE CONSIDERATIONS: Legal teams should confirm the transfer mechanism(s) in place for EEA/UK user data, verify currency of any SCCs used, and ensure the separate EU/UK privacy notice adequately addresses transfer disclosures required under GDPR Article 13/14.
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International data transfers from the EU and UK are subject to GDPR transfer restrictions, and Gemini's compliance with these requirements affects the legal basis for processing EU and UK user data.
If you are an EU or UK user, your personal data may be transferred to the United States or other countries where data protection standards may differ from those in your jurisdiction. The adequacy of Gemini's transfer mechanisms determines the protections applicable to your data in transit and at rest abroad.
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