Google collects the full content of your conversations with Gemini, including any files or images you share, as well as usage data like location information and time spent in the app.
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 scope of data collection includes not just text conversations but also uploaded files, images, and documents, as well as location information and behavioral usage data, meaning interactions with Gemini generate a broad data profile.
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 →The removal of detailed collection practices disclosure reduces transparency about the scope of data collection, including location information and usage metrics.
View full change record →This new provision explicitly details all data collection categories (conversations, content, usage patterns, location, and feedback) providing users with comprehensive transparency about what information is gathered.
View full change record →Using Gemini results in Google collecting conversation content, uploaded files and images, location information, feature usage patterns, and session duration. Users who share documents or images should be aware that this content is included in data collection under these terms.
How other platforms handle this
to request that your data be transferred to a third party (data portability)
Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.
Further, you may take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data prot...
"When you use Gemini apps, Google collects data you provide, including your conversations and any files, images, documents, and other content you share. Google also collects data about how you use the service, such as your location information, the features you use, and how long you spend using Gemini apps. In addition, Google collects feedback you choose to provide.Excerpt from Google Gemini's Gemini Apps Privacy Notice
REGULATORY LANDSCAPE: Collection of location information, conversation content, and uploaded files implicates GDPR Articles 5 and 13 (data minimisation and transparency), CCPA/CPRA data category disclosure requirements, and potentially COPPA if minors use the service.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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The scope of data collection includes not just text conversations but also uploaded files, images, and documents, as well as location information and behavioral usage data, meaning interactions with Gemini generate a broad data profile.
Using Gemini results in Google collecting conversation content, uploaded files and images, location information, feature usage patterns, and session duration. Users who share documents or images should be aware that this content is included in data collection under these terms.
ConductAtlas has identified this type of provision across 289 platforms. See the full comparison.
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