This analysis describes what Google 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
The provision establishes that conversation data serves multiple institutional purposes—product improvement, service development, and AI model training—and clarifies that the standard privacy control mechanism (disabling activity logging) does not restrict this particular data usage practice.
The updated notice adds new disclosure sections explaining how data flows when using Gemini Spark (remote browser and computer access), how avatar creation collects and processes information, and clarifies that Google collects information about AI reasoning steps during task execution. The notice also refines language around subscription information to specify 'Google AI plan' rather than just generic 'paid subscription.' These changes do not establish new obligations but rather expand the transparency disclosures provided to users about existing and new features.
View change record →The updated notice now explicitly identifies Memory as a feature that operates on the basis of user consent, alongside Voice Match. The revised language removes prior geographic restrictions on personalization, meaning Gemini can now reference chat history to generate personalized insights for all users globally, not just those outside the EEA, Switzerland, and the UK. The removal of the statement 'Keep Activity must be on to use this feature' simplifies the operational requirement but does not establish a new obligation. You can learn how to turn the Memory feature on or off through the updated privacy notice.
View change record →The updated privacy notice now discloses that Gemini can use data from connected Google apps and imported memory or chats from other AI platforms to personalize your experience and to improve services, including training generative AI models. This data is treated similarly to other Gemini activity. You can manage or delete your imported activity anytime through the Activity controls.
View change record →Users' conversations are processed for AI model improvement and product development regardless of whether Gemini Apps Activity is enabled or disabled. This means the activity control setting does not provide the functional limitation users might expect regarding conversation data use for training purposes.
How other platforms handle this
We may share your personal information with our affiliates, meaning entities that control, are controlled by, or are under common control with Consensys. We also share information with service providers who assist in operating our services, subject to confidentiality obligations.
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
RedCard. We share information with our financial partners to operate the Target RedCard program.
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"Your conversations with Gemini apps and your feedback are used to provide, improve, and develop Google products, services, and machine-learning technologies, including Google's enterprise products. Turning off Gemini Apps Activity doesn't prevent your conversations from being used to improve Google's AI models.— Excerpt from Google Gemini's Gemini Apps Privacy Notice
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The provision establishes that conversation data serves multiple institutional purposes—product improvement, service development, and AI model training—and clarifies that the standard privacy control mechanism (disabling activity logging) does not restrict this particular data usage practice.
Users' conversations are processed for AI model improvement and product development regardless of whether Gemini Apps Activity is enabled or disabled. This means the activity control setting does not provide the functional limitation users might expect regarding conversation data use for training purposes.
ConductAtlas has identified this type of provision across 1 platforms. See the full comparison.
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