Google Gemini

Data-handling profile

Trains on input

Yes, on the consumer tier (enterprise tier excluded)

Retention

Consumer activity reviewed/used to improve services unless disabled

Data region

Global

Certifications

ISO 27001SOC 2 Type II

DPA available

Yes

Breach history

none known

EU AI Act

GPAI provider; transparency obligations apply

Sources

• https://support.google.com/gemini/answer/13594961
• https://cloud.google.com/gemini/docs/discover/data-governance

Every fact above is drawn from the vendor's public documentation, reviewed by a human, and version-stamped. Monitored daily for changes.

Control mapping

Obligations this vendor triggers, each attributable to the fact it rests on — for your supplier register, not a compliance determination.

• EU AI Act Art. 50 — Transparency obligations for AI systemsattention

  trains_on_input = consumer_tier. Inputs may be reused for model training — users interacting with this system need to be informed accordingly.

• EU AI Act Art. 26 — Obligations of deployers of high-risk AI systemsapplies

  Applies to your organisation as deployer, independent of vendor. Assign human oversight, keep logs, and monitor operation where this tool is used in a high-risk context (Annex III duties apply from 2 Dec 2027).

• ISO/IEC 27001 A.5.19 — Information security in supplier relationshipsapplies

  Google Gemini processes organisational data as a supplier. Include this vendor in the supplier register and risk assessment.

• ISO/IEC 27001 A.5.20 — Addressing information security within supplier agreementsok

  dpa_available = true. A data processing agreement is available and should be executed.

• ISO/IEC 27001 A.5.23 — Information security for use of cloud servicesattention

  Cloud AI service; trains_on_input = consumer_tier. Data submitted to this cloud service may be retained or reused — define acceptable-use rules for it.

• ISO/IEC 42001 A.10.3 — Suppliers of AI systems and servicesapplies

  certifications: ISO 27001, SOC 2 Type II No AI-management certification identified; assurance must come from your own supplier assessment.

• GDPR Art. 44–49 — International transfers of personal dataattention

  data_region = Global. Processing occurs outside the EU/EEA — a transfer mechanism (SCCs or adequacy) must be in place.

• NIS2 Art. 21(2)(d) — Supply chain securityapplies

  AI vendor forms part of your ICT supply chain. In scope for entities covered by NIS2; include in supply-chain risk measures.

• DORA Art. 28 — General principles for ICT third-party riskapplies

  AI vendor is an ICT third-party service provider. For financial entities: register of information and contractual requirements apply.

Change history

1. Google expanded Gemini Connected Apps data use: opted-in users' Connected Apps data now also personalizes Gemini (e.g. Gemini Spark, Gemini in Chrome)neutral
   2026-07-18 · —

   “If you meet certain eligibility requirements and opt in to personalization with certain Connected Apps, Google also uses data from those Connected Apps to personalize your Gemini experience and do things for you, like when you use Gemini Spark or Gemini in Chrome.”