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When a user interacts with a Canvas app created by another user, the app creator can view all data the user shares and can save it to any location of the creator's choosing, including outside Google's infrastructure. Data saved with the app is viewable and editable by anyone with the public link.
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 data shared within Canvas apps is accessible to the app creator and potentially to any public link holder, with no restriction on where the creator may store that data. Compliance teams should note that this creates a data flow to third-party individuals outside Google's data governance framework, with no stated limitations on the creator's use or retention of that data.
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, any data a user shares while interacting with a Canvas app created by another user is visible to that creator and can be saved by the creator to any location outside Google's systems. Data saved within the Canvas app is also accessible to anyone who has the public link, with editing permissions.
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"When you interact with a user-generated Canvas app, the creator of the app can see any data you share and can save it where they choose. Google provides storage for Canvas app data in Firebase, but the app creator can also save your data elsewhere. Anyone with the public link can also view and edit data saved with the app. Be cautious and only share data with Canvas apps you trust.Excerpt from Google Gemini's Gemini Apps Privacy Notice
1. REGULATORY LANDSCAPE: This provision implicates GDPR obligations regarding data transfers to third parties (in this case, individual Canvas app creators who may be located anywhere globally), as well as CCPA disclosure requirements. There is no stated data processing agreement or accountability mechanism between Google and Canvas app creators as data recipients. EU data protection authorities are the primary enforcement bodies for EU users. 2. GOVERNANCE EXPOSURE: Medium. The provision is explicitly disclosed, and Google's notice advises caution and limiting data sharing to trusted Canvas apps. However, the absence of any stated limitation on how Canvas app creators may use, share, or retain user data creates governance exposure for organizations whose personnel interact with Canvas apps. 3. JURISDICTION FLAGS: EU member states and the UK face heightened exposure given GDPR requirements for lawful data transfers to third parties. The lack of any contractual mechanism governing Canvas app creators' use of user data may be difficult to reconcile with GDPR accountability requirements. 4. CONTRACT AND VENDOR IMPLICATIONS: Organizations should assess whether employee use of Canvas apps in Gemini is governed by internal acceptable use policies, given that user data may flow to external individuals without organizational oversight or data processing agreements. 5. COMPLIANCE CONSIDERATIONS: Legal teams should evaluate whether interactions with Canvas apps in Gemini are addressed in internal data handling and acceptable use policies, particularly for use cases involving personal or sensitive data. The public link access mechanism should be noted as a potential data exposure vector.
This provision establishes that user data shared within Canvas apps is accessible to the app creator and potentially to any public link holder, with no restriction on where the creator may store that data. Compliance teams should note that this creates a data flow to third-party individuals outside Google's data governance framework, with no stated limitations on the creator's use …
Under this clause, any data a user shares while interacting with a Canvas app created by another user is visible to that creator and can be saved by the creator to any location outside Google's systems. Data saved within the Canvas app is also accessible to anyone who has the public link, with editing permissions.
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