Gemini is not available to children under 13, and in some countries it may not be available to any minors under local law.
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 age restriction disclosure creates compliance obligations for Google regarding enforcement of the age limit, and the country-specific minor restriction acknowledges that applicable law in certain jurisdictions sets higher age thresholds than the global 13-year minimum.
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 →Renamed from 'Minor User Protections' and now provides specific age threshold (under 13) with explicit text about availability restrictions for minors.
View full change record →Children under 13 are prohibited from using Gemini under the stated terms. Parents or guardians who manage children's Google accounts should be aware of this restriction and verify that age-based access controls are in place.
How other platforms handle this
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"Gemini apps aren't available for children under 13. In some countries, Gemini apps may not be available for users who are minors under the law of their country.— Excerpt from Google Gemini's Gemini Apps Privacy Notice
REGULATORY LANDSCAPE: This provision directly engages COPPA in the United States, which restricts collection of personal data from children under 13 without verifiable parental consent. The EU's GDPR Article 8 sets the age of digital consent at 16 (or lower with member state authorization, minimum 13), which is the likely basis for the country-specific minor restriction. The UK GDPR and Age Appropriate Design Code impose additional obligations for services accessible to minors. Enforcement authorities include the FTC (COPPA), EU supervisory authorities, and the UK ICO. GOVERNANCE EXPOSURE: Medium. The notice discloses the restriction but does not detail the technical or procedural mechanisms used to enforce age verification, which is a known area of regulatory scrutiny under COPPA and the EU GDPR children's provisions. JURISDICTION FLAGS: EU/EEA countries where the age of digital consent is set above 13 create heightened exposure. The UK Age Appropriate Design Code imposes specific design and data minimisation obligations for services that may be accessed by minors. US states including California have enacted additional minor privacy protections. CONTRACT AND VENDOR IMPLICATIONS: Organizations providing Gemini access to users should assess whether their user base includes minors and whether appropriate controls or parental consent mechanisms are in place. Schools and educational institutions should evaluate whether student use of Gemini is compliant with FERPA and applicable state student privacy laws. COMPLIANCE CONSIDERATIONS: Compliance teams deploying Gemini in consumer-facing or education contexts should assess age verification procedures. The notice's country-specific minor restriction may require localized compliance assessments.
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The age restriction disclosure creates compliance obligations for Google regarding enforcement of the age limit, and the country-specific minor restriction acknowledges that applicable law in certain jurisdictions sets higher age thresholds than the global 13-year minimum.
Children under 13 are prohibited from using Gemini under the stated terms. Parents or guardians who manage children's Google accounts should be aware of this restriction and verify that age-based access controls are in place.
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