A subset of user chats, along with associated language, device type, location, and feedback data, are reviewed by human reviewers including trained third-party service providers, and retained for up to three years regardless of whether the user deletes their Gemini Apps activity. Reviewed chats are disconnected from the user's Google account before being sent to service providers.
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 a retention mechanism for human-reviewed chat data that operates independently of the user's deletion controls in Gemini Apps Activity, meaning user-initiated deletion of activity does not trigger deletion of this data subset. Compliance teams should assess whether this retention architecture satisfies GDPR and UK GDPR erasure request obligations, particularly given that the three-year retention period applies to data that includes location information, device type, and feedback alongside chat content.
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 →Addition of clarification that chats are disconnected from account before sending to service providers, and explicit instruction to use 'Keep Activity' setting to control future review, replacing the generic activity deletion language.
View full change record →Under this clause, chats that have been reviewed by human reviewers are retained for up to three years and are not deleted when a user deletes their Gemini Apps activity, because they are stored disconnected from the user's Google account. The agreement states that users can prevent future chats from being subject to human review for service improvement purposes by turning off the Keep Activity setting or using temporary chats.
Cross-platform context
See how other platforms handle Human Review and Three-Year Retention of Reviewed Chats and similar clauses.
Compare across platforms →"Chats reviewed by human reviewers (and related data like your language, device type, location info, or feedback) are not deleted when you delete your activity. Instead, they are retained for up to three years. ... Chats are disconnected from your account before being sent to service providers. ... To stop your future chats from being reviewed to improve Google services, turn off your Keep Activity setting.Excerpt from Google Gemini's Gemini Apps Privacy Notice
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This provision establishes a retention mechanism for human-reviewed chat data that operates independently of the user's deletion controls in Gemini Apps Activity, meaning user-initiated deletion of activity does not trigger deletion of this data subset. Compliance teams should assess whether this retention architecture satisfies GDPR and UK GDPR erasure request obligations, particularly given that the three-year retention period applies to …
Under this clause, chats that have been reviewed by human reviewers are retained for up to three years and are not deleted when a user deletes their Gemini Apps activity, because they are stored disconnected from the user's Google account. The agreement states that users can prevent future chats from being subject to human review for service improvement purposes by …
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