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 clause creates a differential data retention framework based on user age, establishing default retention periods and limiting modification options for minor users. This affects the scope and duration of activity data preservation across the Gemini Apps service.
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 →Users under 18 operate under a mandatory 18-month retention period for activity data unless they affirmatively modify settings to the 3-month option. Users under 13 have conversations excluded from Google Account storage by default, though this default may be subject to modification through account settings.
How other platforms handle this
For campus users only, we may provide identifiers to select food service providers that operate restaurants and other food ordering and delivery services on your campus so that they can communicate directly with you and send you personalized communications and marketing. Please see Section 2.1 below...
We will share individual user information with companies, organizations or individuals outside of Google if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to: meet any applicable law, regulation, legal process or enforceable govern...
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.
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"For users who are under 18, Gemini Apps Activity is saved for 18 months by default and can only be changed to 3 months. Conversations with Gemini apps from users under 13 are not saved to their Google Account by default.— Excerpt from Google Gemini's Gemini Apps Privacy Notice
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The clause creates a differential data retention framework based on user age, establishing default retention periods and limiting modification options for minor users. This affects the scope and duration of activity data preservation across the Gemini Apps service.
Users under 18 operate under a mandatory 18-month retention period for activity data unless they affirmatively modify settings to the 3-month option. Users under 13 have conversations excluded from Google Account storage by default, though this default may be subject to modification through account settings.
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