The notice states that Gemini apps require users to meet the minimum age to manage their own Google Account, and that in some countries additional age restrictions apply to users under 18.
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 age-based access restrictions for Gemini apps, with jurisdiction-specific variations that create compliance obligations for Google and operational considerations for institutional deployments. The document does not detail the enforcement mechanism for these age restrictions.
Interpretive note: The notice does not enumerate which countries apply under-18 restrictions or describe the technical mechanism for age verification, creating ambiguity about enforcement scope.
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 →Changed minimum age from 13 to alignment with Google Account management age, and raised minimum age in some countries from undefined 'minors' status to explicit 18.
View full change record →Under this clause, access to Gemini apps is restricted to users who meet applicable age requirements, with country-specific restrictions that may prohibit access for users under 18 in certain jurisdictions. The notice does not specify the technical or procedural mechanisms used to verify user age.
How other platforms handle this
Depending on where you are located, you may have certain rights regarding your personal information, including the right to access, correct, delete, or restrict processing of your personal information, the right to data portability, and the right to object to or withdraw consent for certain processi...
For individuals in the United States, please also refer to our Notice For Individuals Residing In Certain US States below and the Consumer Health Data Policy.
If you do not have a social security number you may still be eligible to open a limited Revolut personal account. Depending on your immigration status, we may ask you to provide us with a copy of your supported U.S. visa and may limit your access to certain products and features.
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"Gemini apps are only available to users who meet the age requirements to manage their own Google Account. In addition, in some countries, Gemini apps aren't available for users under 18.— Excerpt from Google Gemini's Gemini Apps Privacy Notice
1) REGULATORY LANDSCAPE: This provision implicates COPPA for US users under 13, and the EU's GDPR provisions regarding children's data (including national implementations that may set consent age at 16 in some member states). The UK Age Appropriate Design Code (Children's Code) may also be relevant for UK deployments. Enforcement authorities include the FTC (COPPA), national DPAs in EU member states, and the UK ICO. 2) GOVERNANCE EXPOSURE: Medium. The notice asserts age restrictions but does not describe the technical enforcement mechanism, creating uncertainty about whether minors may access Gemini in practice. Regulators have taken enforcement action against platforms that assert age restrictions without adequate technical controls. 3) JURISDICTION FLAGS: The EU, UK, and US create the highest compliance exposure for minor user data. Country-specific restrictions for users under 18 are referenced but not enumerated in the document, which may create disclosure gaps for institutional deployers operating across multiple jurisdictions. 4) CONTRACT AND VENDOR IMPLICATIONS: Educational institutions or platforms deploying Gemini for student populations should confirm applicable age restrictions and verify that enterprise agreements address COPPA and FERPA compliance for student data. Standard consumer terms may not provide sufficient protections for deployment in K-12 contexts. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should map the age restriction provisions against their user population and verify that onboarding and identity verification mechanisms are consistent with the restrictions disclosed in this notice. Jurisdictions with higher minimum ages should be specifically addressed in deployment documentation.
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This provision establishes age-based access restrictions for Gemini apps, with jurisdiction-specific variations that create compliance obligations for Google and operational considerations for institutional deployments. The document does not detail the enforcement mechanism for these age restrictions.
Under this clause, access to Gemini apps is restricted to users who meet applicable age requirements, with country-specific restrictions that may prohibit access for users under 18 in certain jurisdictions. The notice does not specify the technical or procedural mechanisms used to verify user age.
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