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 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 →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.
How other platforms handle this
We use information to enhance the quality, reliability, and/or accuracy of our AI Features by creating, developing, training, testing, improving, and maintaining AI and ML models run by Strava or our service providers. We use aggregated, de-identified data for this purpose. We also use personal info...
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...
Monitoring
Google Gemini has changed this document before.
Receive same-day alerts, structured change summaries, and monitoring for up to 25 platforms.
"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. The EU AI Act may also be relevant to the extent it addresses data governance for general-purpose AI systems. The FTC has oversight over data use representations. For minors, COPPA requirements regarding data collection and use apply to the extent Gemini is accessible to users under 13. 2) GOVERNANCE EXPOSURE: Medium. The use of conversation data for AI model training on an opt-out rather than opt-in basis may require evaluation under GDPR legitimate interests balancing tests for EEA users, particularly where conversations contain sensitive personal data. The notice does not specify the legal basis for this processing in GDPR terms. 3) JURISDICTION FLAGS: EEA users have the strongest grounds to request clarification of the lawful basis for AI training data use. UK users face similar considerations under UK GDPR. California residents may assess whether this use constitutes a form of data sharing subject to CCPA opt-out rights. 4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers should confirm whether their Workspace or enterprise agreements exclude conversation data from AI model training by default, as the standard consumer notice permits this use subject to opt-out. B2B contracts in regulated sectors should address this explicitly. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether the opt-out mechanism for AI training data use is sufficiently accessible and prominent for users who wish to exercise it. Data protection impact assessments may be warranted for EEA deployments given the scale and sensitivity of conversation data used for AI training.
Full compliance analysis
Regulatory citations, enforcement risk, and due diligence action items.
Free: track 1 platform + weekly digest. Monitor: 25 platforms + same-day alerts. No credit card required.
Compliance Governance Intelligence
Need to monitor specific governance provisions?
Compliance includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.
Built from archived source documents, structured governance mappings, and historical version tracking.
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.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Google Gemini.