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For users aged 18 or older who upgrade to Gemini Apps, calling and texting history previously saved in Web and App Activity may be imported to Gemini Apps Activity in certain regions, where it is used to improve Gemini Apps features such as contact suggestions.
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
This provision discloses that an upgrade to Gemini Apps may trigger an import of pre-existing calling and texting history from Web and App Activity into Gemini Apps Activity, where it becomes subject to Gemini Apps data handling terms including potential human review and AI model training use. Compliance teams should note that this creates a retroactive data re-categorization that may affect data previously saved under different processing terms.
Interpretive note: The notice does not specify which regions trigger the calling and texting history import, creating uncertainty about geographic scope and whether advance notice or opt-out is provided before the import occurs.
The updated privacy notice establishes that Google collects data from third-party services you connect to Gemini, including Model Context Protocol server tools, and that such connections are not monitored or secured by Google. The notice explicitly states that choosing to connect third-party apps may expose your data, passwords, devices, and accounts to unauthorized access. The revised terms also clarify that you can use temporary chats, which are not retained for AI improvement purposes with human reviewer assistance. You can manage connected app permissions through Gemini Spark settings.
View change record →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 →Under this clause, users aged 18 or older who upgrade to Gemini Apps may have their existing calling and texting history imported from Web and App Activity into Gemini Apps Activity in applicable regions, making that historical data subject to Gemini Apps processing terms including potential use for AI model training and human review.
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"If you are 18 or older and upgrade to Gemini Apps, your calling or texting history may be imported from your Web & App Activity to Gemini Apps Activity in some regions. This helps improve your Gemini Apps experience, like contact suggestions.Excerpt from Google Gemini's Gemini Apps Privacy Notice
1. REGULATORY LANDSCAPE: This provision implicates GDPR and UK GDPR requirements for transparency regarding new processing purposes applied to previously collected data, as well as CCPA requirements regarding disclosure of personal information use. The import of communication history as a consequence of a product upgrade may require evaluation under applicable notice and consent frameworks. 2. GOVERNANCE EXPOSURE: Medium. The retroactive import of calling and texting history into Gemini Apps Activity, where it becomes subject to AI model training and human review terms, is an operationally distinct disclosure. The notice does not specify which regions are affected or whether users are given advance notice or an opt-out opportunity before the import occurs. 3. JURISDICTION FLAGS: EU member states and the UK create heightened exposure given GDPR transparency requirements for new processing purposes. The notice does not specify which regions trigger this import, creating uncertainty about geographic scope. 4. CONTRACT AND VENDOR IMPLICATIONS: Organizations managing Google Workspace or consumer Google Account deployments should assess whether this import mechanism applies to their users and whether it is consistent with applicable data governance policies and privacy notices. 5. COMPLIANCE CONSIDERATIONS: Legal teams should assess whether the import of calling and texting history as a consequence of a product upgrade satisfies applicable transparency and notice requirements. The notice's reference to 'some regions' without specifying which creates an ambiguity that may warrant follow-up with Google's compliance contacts.
This provision discloses that an upgrade to Gemini Apps may trigger an import of pre-existing calling and texting history from Web and App Activity into Gemini Apps Activity, where it becomes subject to Gemini Apps data handling terms including potential human review and AI model training use. Compliance teams should note that this creates a retroactive data re-categorization that may …
Under this clause, users aged 18 or older who upgrade to Gemini Apps may have their existing calling and texting history imported from Web and App Activity into Gemini Apps Activity in applicable regions, making that historical data subject to Gemini Apps processing terms including potential use for AI model training and human review.
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