Google Gemini · Gemini Apps Privacy Notice · View original document ↗

AI Model Training Use of Conversations

Medium severity High confidence Explicitdocumentlanguage Unique · 0 of 343 platforms
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Recent governance activity Google Gemini recorded 2 documented changes in the last 30 days.
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Document Record

What it is

Google uses your Gemini conversations and feedback to train and improve its AI products. The notice advises you not to share confidential or sensitive information for this reason.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

The terms authorize Google to use conversation content for AI model training and product improvement, which means information submitted in conversations may inform future AI outputs and training datasets. The policy's advisory against submitting confidential information confirms the operational scope of this use.

Recent Activity

This document changed recently

Medium May 21, 2026

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 →
Medium Apr 30, 2026

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 →
Medium Mar 27, 2026

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 →

Clause Stability Stable

0
Changes
3
Months Monitored
Apr 28, 2026
First Seen
May 20, 2026
Last Seen
This clause type exists across 3350 other provisions on other platforms.

Consumer impact (what this means for users)

Content you submit in Gemini conversations may be used to train Google's AI systems, meaning personal details, questions, and context shared with the assistant may contribute to AI model development. The notice explicitly advises against submitting confidential or sensitive information.

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
    Delete your Gemini Apps Activity at myactivity.google.com to remove stored conversations from Google's systems. Turning off Gemini Apps Activity in your Google Account settings will prevent future conversations from being used to improve Google products.

How other platforms handle this

Strava Medium

We use information to enhance the quality, reliability, and/or accuracy of our AI Features by creating, developing, training, testing, improving, and maintaining AI and ML models run by Strava or our service providers. We use aggregated, de-identified data for this purpose. We also use personal info...

Ledger Medium

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.

Garmin Medium

If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...

See all platforms with this clause type →

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▸ View Original Clause Language DOCUMENT RECORD
"
Your conversations and any related feedback you provide help us improve Google products and services, including Gemini apps. Please don't submit confidential information or information you wouldn't want reviewed or used for these purposes.

— Excerpt from Google Gemini's Gemini Apps Privacy Notice

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: AI training use of personal data implicates GDPR Article 6 (lawful basis), Article 5(1)(b) (purpose compatibility), and may engage the EU AI Act's requirements for general-purpose AI model training, including copyright and data sourcing obligations. The Irish Data Protection Commission and EU AI Office are relevant authorities. For California users, CPRA provisions regarding use of sensitive personal information for secondary purposes may apply. GOVERNANCE EXPOSURE: High. Using user-submitted personal data for AI model training constitutes secondary processing that may require a separate lawful basis under GDPR, and the compatibility of this secondary purpose with the original service provision purpose requires documented assessment. Organizations allowing employee use of Gemini should consider whether employee conversation data being used for AI training creates employment law or data protection obligations. JURISDICTION FLAGS: EU/EEA users have the strongest legal basis to challenge secondary AI training use of their personal data. Illinois BIPA may be relevant if biometric-adjacent data is incidentally processed. California CPRA provides opt-out rights for certain secondary uses of sensitive personal information. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers should verify whether Google's business agreements exclude conversation data from AI training use, as some enterprise terms provide different defaults than consumer terms. This distinction is material for due diligence and vendor risk assessments. COMPLIANCE CONSIDERATIONS: Privacy impact assessments should address AI training as a secondary processing purpose. Consent or legitimate interest assessments may be required under GDPR. Organizations should evaluate whether employee acceptable use policies address the AI training use of conversations submitted through Gemini.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has authority over unfair or deceptive data practices involving secondary use of consumer data, including use of personal data for AI training purposes.
    File a complaint →

Applicable regulations

EU AI Act
European Union
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
EU AI Act - High Risk Provisions
EU
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Gemini Apps Privacy Notice
Entity
Google Gemini
Document last updated
May 5, 2026
Tracking information
First tracked
May 10, 2026
Last verified
May 12, 2026
Record ID
CA-P-003712
Document ID
CA-D-00326
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
d426afff362d09899b216ff87ee56636f0153c90c344ada869c6a4501c1ef7ba
Analysis generated
May 10, 2026 08:54 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Google Gemini
Document: Gemini Apps Privacy Notice
Record ID: CA-P-003712
Captured: 2026-05-10 08:54:31 UTC
SHA-256: d426afff362d0989…
URL: https://conductatlas.com/platform/google-gemini/gemini-apps-privacy-notice/ai-model-training-use-of-conversations/
Accessed: June 18, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Google Gemini's AI Model Training Use of Conversations clause do?

The terms authorize Google to use conversation content for AI model training and product improvement, which means information submitted in conversations may inform future AI outputs and training datasets. The policy's advisory against submitting confidential information confirms the operational scope of this use.

How does this clause affect you?

Content you submit in Gemini conversations may be used to train Google's AI systems, meaning personal details, questions, and context shared with the assistant may contribute to AI model development. The notice explicitly advises against submitting confidential or sensitive information.

Is ConductAtlas affiliated with Google Gemini?

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