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
It establishes that a user's deletion of their own activity does not result in deletion of human-reviewed chats, creating a category of data outside the user's control for up to three years.
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 →Deleting your Gemini Apps activity will not delete chats that were reviewed by human reviewers; those chats and associated data persist for up to three years.
How other platforms handle this
We may retain your Personal Data for a period of time consistent with the original purpose of collection...or as long as required to fulfill our legal and/or regulatory obligations.
we will only retain your personal information for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements...
We keep your personal information where we have an ongoing legitimate business need to do so (for example, to provide you with our Services or to comply with applicable legal, tax or accounting requirements).
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"Chats reviewed by human reviewers (and related data like your language, device type, location info, or feedback) are not deleted when you delete your activity. Instead, they are retained for up to three years.— Excerpt from Google Gemini's Gemini Apps Privacy Notice
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It establishes that a user's deletion of their own activity does not result in deletion of human-reviewed chats, creating a category of data outside the user's control for up to three years.
Deleting your Gemini Apps activity will not delete chats that were reviewed by human reviewers; those chats and associated data persist for up to three years.
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