Gemini · Gemini User Agreement

Absence of Substantive Terms in Landing Document

Medium severity
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What it is

This page does not contain the actual legal terms that govern your use of Gemini — it only tells you which separate document to go read, and the content of that document is not reproduced or summarized here.

Consumer impact (what this means for users)

Consumers are effectively one or two clicks away from the terms that govern their crypto trading, data rights, and dispute resolution options — this structural opacity increases the risk that users proceed without informed consent, particularly with respect to mandatory arbitration or class action waiver provisions that may appear in the underlying agreements.

Cross-platform context

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Why it matters (compliance & risk perspective)

Because this landing page contains no substantive legal provisions, users who stop reading here — or who are not prompted to click through — may use Gemini's platform without ever reading the terms that actually bind them, including arbitration clauses or liability waivers.

View original clause language
Your use of the Gemini platform is governed by the user agreement that corresponds to your state of residence: Residents of ID, LA, NY, OH, TX are subject to the terms of the [linked agreement]. Residents of [all other states] are subject to the [linked agreement].

Institutional analysis (Compliance & legal intelligence)

(1) REGULATORY FRAMEWORK: FTC Act Section 5 (15 U.S.C. §45) and the FTC's .com Disclosures guidance (2013) require that material terms be clear and conspicuous — a landing page that withholds all substantive terms and requires click-through may not satisfy this standard. NYDFS regulations require that BitLicense holders present certain disclosures to NY consumers prior to account activation. CFPB supervisory guidance on electronic disclosures (under EFTA and TILA where applicable) also requires accessible and timely presentation of material terms. (2)

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Applicable agencies

  • FTC
    The FTC has authority under Section 5 to enforce clear and conspicuous disclosure requirements for material terms on consumer-facing digital platforms, including cryptocurrency exchanges.
    File a complaint →

Provision details

Document information
Document
Gemini User Agreement
Entity
Gemini
Document last updated
April 29, 2026
Tracking information
First tracked
April 27, 2026
Last verified
April 27, 2026
Record ID
CA-P-003335
Document ID
CA-D-00066
Evidence Provenance
Source URL
Wayback Machine
SHA-256
e8b5bf111a2e5cd34888a16cf24675c30e228f9b1c29c5b20c26cccf5a6125f4
Verified
✓ Snapshot stored   ✓ Change verified
How to Cite
ConductAtlas Policy Archive
Entity: Gemini | Document: Gemini User Agreement | Record: CA-P-003335
Captured: 2026-04-27 11:53:11 UTC | SHA-256: e8b5bf111a2e5cd3…
URL: https://conductatlas.com/platform/gemini/gemini-user-agreement/absence-of-substantive-terms-in-landing-document/
Accessed: May 2, 2026
Classification
Severity
Medium
Categories

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