The notice states that information collected through Gemini apps is shared with Google affiliates and third-party service providers in accordance with the Google Privacy Policy, which governs the scope and conditions of such sharing.
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 establishes that conversation data and associated user information collected through Gemini may be shared with Google's affiliated entities and external service providers, with the full scope of sharing governed by the broader Google Privacy Policy rather than solely the Gemini-specific notice.
Interpretive note: The full scope of affiliate and third-party sharing is governed by the Google Privacy Policy rather than this document, requiring review of both to assess sharing practices comprehensively.
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 →Under this clause, data collected through Gemini apps, including conversation content, may be shared with Google affiliates and third-party service providers as described in the Google Privacy Policy. Users seeking to understand the full scope of data sharing must review the Google Privacy Policy in addition to this notice.
How other platforms handle this
By using the Services, you authorize Affirm to share your information, including personal information and information related to your transactions and use of the Services, with merchants, service providers, and other third parties as further described in our Privacy Policy.
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.
We may receive information, including the following, from third party sources and combine it with information we already directly collect from you. We will handle the information in accordance with this Privacy Policy. Game, social media, or other information, from those third parties or services yo...
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"Google shares information as described in the Google Privacy Policy, including with Google's affiliates. This includes sharing data with third-party service providers who help Google operate Gemini apps.— Excerpt from Google Gemini's Gemini Apps Privacy Notice
1) REGULATORY LANDSCAPE: This provision engages GDPR data sharing and controller-processor obligations, CCPA data sharing disclosure requirements, and applicable contractual data protection frameworks for third-party service providers. The scope of affiliate and third-party sharing determines whether additional data transfer mechanisms are required for cross-border data flows. 2) GOVERNANCE EXPOSURE: Medium. The provision delegates the full disclosure of sharing practices to the Google Privacy Policy, which means Gemini-specific compliance assessments require review of both documents. This layered disclosure structure is common in large platform ecosystems but may complicate user comprehension and regulatory assessment of data sharing practices. 3) JURISDICTION FLAGS: EEA and UK users face heightened exposure regarding cross-border data transfers to US-based Google affiliates and service providers, where Standard Contractual Clauses or equivalent transfer mechanisms must be in place. California residents may evaluate sharing with third-party service providers under CCPA sharing and sale provisions. 4) CONTRACT AND VENDOR IMPLICATIONS: Institutional deployers should request a full list of Google's sub-processors and verify that data processing agreements address the scope of affiliate and third-party data sharing. Enterprise agreements may include modified sharing terms that supersede the standard consumer notice. 5) COMPLIANCE CONSIDERATIONS: Data mapping exercises should trace the flow of Gemini conversation data through Google's affiliate and service provider network. Transfer impact assessments may be required for EU/UK deployments. Procurement teams should verify that sub-processor agreements meet applicable contractual standards.
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This provision establishes that conversation data and associated user information collected through Gemini may be shared with Google's affiliated entities and external service providers, with the full scope of sharing governed by the broader Google Privacy Policy rather than solely the Gemini-specific notice.
Under this clause, data collected through Gemini apps, including conversation content, may be shared with Google affiliates and third-party service providers as described in the Google Privacy Policy. Users seeking to understand the full scope of data sharing must review the Google Privacy Policy in addition to this notice.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Google Gemini.