The notice states that conversations and user feedback submitted to Gemini apps may be used to train and improve Google's AI models, and that users can disable Gemini Apps Activity to opt out of this use.
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 user-generated conversation content, including feedback, constitutes training data for Google's AI models unless users actively opt out via Gemini Apps Activity controls. The opt-out is available but is not the default state described in the notice, requiring affirmative user action.
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 →Expanded scope to explicitly mention AI model improvement, added clarification about conversation history feature, and added information about ability to opt-out via Gemini Apps Activity.
View full change record →Under this clause, conversations with Gemini and user feedback are used by default to improve Google's AI models, and users must actively disable Gemini Apps Activity to prevent this use. The agreement states that turning off Gemini Apps Activity prevents future conversations from being used for model training.
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"Your conversations with Gemini apps and your feedback are used to provide Gemini apps and related features, like conversation history. They may also be used to improve Google's AI models that power Gemini apps. You can turn off Gemini Apps Activity to prevent this.Excerpt from Google Gemini's Gemini Apps Privacy Notice
1) REGULATORY LANDSCAPE: This provision engages GDPR principles regarding consent and legitimate interests as a lawful basis for processing personal data for AI training purposes.
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This provision establishes that user-generated conversation content, including feedback, constitutes training data for Google's AI models unless users actively opt out via Gemini Apps Activity controls. The opt-out is available but is not the default state described in the notice, requiring affirmative user action.
Under this clause, conversations with Gemini and user feedback are used by default to improve Google's AI models, and users must actively disable Gemini Apps Activity to prevent this use. The agreement states that turning off Gemini Apps Activity prevents future conversations from being used for model training.
ConductAtlas has identified this type of provision across 289 platforms. See the full comparison.
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