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The policy states that Google uses publicly available information to train AI models used in products including Google Translate, Gemini Apps, and Cloud AI capabilities.
This analysis describes what YouTube Ads'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 discloses that publicly accessible data, which may include user-generated content indexed by Google, is used for AI model training purposes. This disclosure is relevant to ongoing regulatory discussions regarding AI training data provenance, copyright, and privacy obligations under emerging frameworks including the EU AI Act.
Interpretive note: The legal basis under GDPR for using publicly available personal data for AI model training is subject to ongoing regulatory interpretation; the policy does not specify the lawful basis asserted for this processing.
The updated policy makes several material clarifications about how Google links your activity across websites and apps. It shifts from describing analytics tools in isolation to framing them as part of a broader 'ad and analytics services' ecosystem, and broadens the scope of data linking to explicitly include 'cookies and other technologies'. The policy also clarifies that data sharing occurs even in private browsing modes. Review your Google Account activity controls to understand what data is being collected and linked across services you use.
View change record →Under this clause, information that is publicly available online, which may include content users have published or that appears in Google's search index, may be used by Google to train AI models. The policy does not provide a specific opt-out mechanism for this use of publicly available information.
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"Research and development: Google uses information to improve our services and to develop new products, features and technologies that benefit our users and the public. For example, we use publicly available information to help train Google's AI models and build products and features like Google Translate, Gemini Apps, and Cloud AI capabilities.Excerpt from YouTube Ads's Google Privacy Policy
1. REGULATORY LANDSCAPE: This provision engages the EU AI Act's requirements for transparency about training data for general-purpose AI models, enforced by EU national market surveillance authorities and the AI Office. It also implicates copyright law considerations regarding the use of publicly available web content for AI training, which is subject to ongoing regulatory and judicial proceedings in multiple jurisdictions. GDPR Article 6 lawful basis requirements may apply where publicly available information includes personal data. 2. GOVERNANCE EXPOSURE: Medium. The disclosure is present and explicit, which addresses transparency obligations. However, the adequacy of 'publicly available' as a sufficient descriptor of training data provenance, and the legal basis for using publicly available personal data for AI training under GDPR, remain areas of regulatory uncertainty and ongoing scrutiny across multiple jurisdictions. 3. JURISDICTION FLAGS: EU/EEA users are subject to GDPR requirements regarding the processing of personal data for AI training purposes, including requirements for lawful basis where publicly available data includes personal information. UK users are subject to UK GDPR. The EU AI Act's obligations for providers of general-purpose AI models apply to Google's AI products deployed in the EU. 4. CONTRACT AND VENDOR IMPLICATIONS: Organizations that publish data publicly and use Google services should be aware that publicly accessible content may be incorporated into AI training datasets. Organizations deploying Gemini Apps or Cloud AI capabilities should assess the data governance implications of AI models trained on publicly available data for their specific use cases. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should monitor regulatory developments regarding AI training data under the EU AI Act and applicable GDPR guidance from data protection authorities. Organizations with publicly accessible content that may be indexed by Google should assess whether any such content constitutes personal data subject to GDPR protections against use for AI training without a valid legal basis.
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This provision discloses that publicly accessible data, which may include user-generated content indexed by Google, is used for AI model training purposes. This disclosure is relevant to ongoing regulatory discussions regarding AI training data provenance, copyright, and privacy obligations under emerging frameworks including the EU AI Act.
Under this clause, information that is publicly available online, which may include content users have published or that appears in Google's search index, may be used by Google to train AI models. The policy does not provide a specific opt-out mechanism for this use of publicly available information.
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