Provision record
Gemini · Gemini Privacy Policy · View original document ↗

GLBA Financial Institution Exemption from State Privacy Laws

High severity Medium confidence Explicit document language Common · 289 of 352 platforms
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Document Record

What it is

Gemini claims that because it is regulated as a financial institution under federal law, it does not have to comply with many state privacy laws that would otherwise give you rights like data deletion or opt-out of data sharing.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This claim directly limits which privacy rights you can exercise as a US consumer, potentially removing protections you might expect under state laws like CCPA.

Interpretive note: The scope of GLBA preemption over specific state privacy laws is not fully settled and varies by state and the nature of the data processing activity involved.

Clause Stability Stable

0
Changes
6
Months Monitored
May 10, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 5149 other provisions on other platforms.

Consumer impact (what this means for users)

If you are a US user, you may not be able to request deletion of your account data or opt out of certain data sharing practices under state privacy laws, because Gemini asserts federal GLBA preemption. The practical scope of this exemption varies by state and is not fully defined in this policy.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Navigate to Section 13 of Gemini's Privacy Policy to identify the state-specific disclosures applicable to your jurisdiction. Follow the linked instructions to submit a privacy rights request if your state provides applicable rights.

How other platforms handle this

Google Cloud Medium

When you use them, we'll validate your request by verifying your identity (for example, by confirming that you're signed in to your Google Account).

Notion Medium

Not be Discriminated Against by us for exercising your privacy rights.

ZipRecruiter Medium

you may also have the right to: (i) opt out of processing of Personal Data for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects...and (iii) appeal any decision by ZipRecruiter...

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
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. For those states with laws that do apply to Gemini's practices, please see our state-focused privacy disclosures about when we may process your personal data and your corresponding rights, in our [jurisdiction-specific disclosures].

Excerpt from Gemini's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision directly implicates the GLBA Privacy Rule (15 U.S.C.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FCRA
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
GLBA
United States Federal
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Gemini Privacy Policy
Entity
Gemini
Document last updated
May 5, 2026
Tracking information
First tracked
May 8, 2026
Last verified
May 10, 2026
Record ID
CA-P-009309
Document ID
CA-D-00067
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
100a5b1c02d6dd78c2be125f4f4d6074785a36e4af75420f7de76e75657b03e7
Analysis generated
May 8, 2026 05:01 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Gemini
Document: Gemini Privacy Policy
Record ID: CA-P-009309
Captured: 2026-05-08 05:01:43 UTC
SHA-256: 100a5b1c02d6dd78…
URL: https://conductatlas.com/platform/gemini/gemini-privacy-policy/provision/CA-P-009309/glba-financial-institution-exemption-from-state-privacy-laws/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Gemini's GLBA Financial Institution Exemption from State Privacy Laws clause do?

This claim directly limits which privacy rights you can exercise as a US consumer, potentially removing protections you might expect under state laws like CCPA.

How does this clause affect you?

If you are a US user, you may not be able to request deletion of your account data or opt out of certain data sharing practices under state privacy laws, because Gemini asserts federal GLBA preemption. The practical scope of this exemption varies by state and is not fully defined in this policy.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 289 platforms. See the full comparison.

Is ConductAtlas affiliated with Gemini?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Gemini.