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The notice states that location data is always collected when a user uses Gemini Apps, using the general area from the IP address or Home or Work addresses by default, with precise location available via device permission or received from other Google services such as Google Maps even when the precise location setting in the Google app is off. Precise location may also be shared with other Google services to fulfill user requests.
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 location data collection is a non-optional baseline for Gemini Apps use, and that precise location data may be received from other Google services regardless of the precise location setting in the Google app itself. Compliance teams should note that this creates a location data flow that may not be fully controllable through the Gemini app's own settings alone.
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, some form of location data is collected during every Gemini Apps session, and precise location may flow to Gemini from other Google services such as Google Maps even when the user has disabled the precise location setting in the Google app. Users can manage device-level location permissions for Gemini mobile apps and review location data stored in Gemini Apps Activity.
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"Location data is always collected if you use Gemini Apps so that they can provide you with a response that is relevant to your query. ... Gemini may also receive precise location data from another Google service, like Google Maps, even if the precise location setting in the Google app is off. ... Gemini Apps may share your precise location data with another Google service, like Google Maps, to fulfill your request.Excerpt from Google Gemini's Gemini Apps Privacy Notice
1. REGULATORY LANDSCAPE: This provision implicates GDPR requirements for lawful processing of location data, which may constitute sensitive data in certain contexts, as well as CCPA requirements regarding disclosure of location data collection and sharing. The FTC has previously taken enforcement action regarding deceptive location data practices. EU data protection authorities are the primary enforcement bodies for EU users. 2. GOVERNANCE EXPOSURE: Medium. The notice is explicit that location data is always collected, and provides detail on sources and uses. The disclosure that precise location may be received from other Google services even when the Gemini-specific precise location setting is off may require evaluation under applicable transparency and consent requirements. 3. JURISDICTION FLAGS: EU member states and the UK face heightened exposure given GDPR requirements for transparent and lawful processing of location data. California users have CCPA rights regarding location data. Illinois users should note that location data combined with other identifiers may engage state-specific privacy frameworks. 4. CONTRACT AND VENDOR IMPLICATIONS: Organizations deploying Gemini should assess whether employee location data collection through Gemini Apps is disclosed in applicable workplace privacy notices and whether it is consistent with organizational data governance policies. 5. COMPLIANCE CONSIDERATIONS: Legal teams should assess whether the cross-service location data flow (from services like Google Maps to Gemini, even with Gemini precise location settings off) is adequately addressed in user-facing disclosures and whether it satisfies applicable consent or transparency requirements in relevant jurisdictions.
This provision establishes that location data collection is a non-optional baseline for Gemini Apps use, and that precise location data may be received from other Google services regardless of the precise location setting in the Google app itself. Compliance teams should note that this creates a location data flow that may not be fully controllable through the Gemini app's own …
Under this clause, some form of location data is collected during every Gemini Apps session, and precise location may flow to Gemini from other Google services such as Google Maps even when the user has disabled the precise location setting in the Google app. Users can manage device-level location permissions for Gemini mobile apps and review location data stored in …
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