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Is Gemini GDPR-Compliant? Examples, Costs and How to Start

Henri Jung, Co-founder at Superkind
Henri Jung

Co-founder at Superkind

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“Is Gemini GDPR-compliant?” is what the data protection officer asks the Monday after someone in sales pastes a customer list into gemini.google.com to draft a follow-up email. Half the team is already using it, some signed in with a work Google account, some with a private one. This article answers the question plainly, as of October 2026: which Gemini is which, what Google commits to, where the open points are, what it costs and what a compliant setup needs. Many companies can use Gemini compliantly with the right setup. This is not legal advice - confirm the details with your own data protection officer.

Key takeaways

The account and the product decide: with a Workspace account, Gemini for Workspace runs under the Google Workspace Data Processing Amendment, with no training on your content. The free consumer Gemini app with a personal Google account does not124.

Three open points to close: Google is a US company under the CLOUD Act, Workspace data regions pin storage at rest but some inference may route elsewhere, and Gemini Apps Activity sends consumer chats to human reviewers unless the user turns it off347.

Your duties stay with you: a lawful basis (Art. 6 GDPR), a record of processing (Art. 30), a DPIA where the risk is high (Art. 35), a documented Art. 44 transfer under the EU-US Data Privacy Framework and AI literacy under Art. 4 of the EU AI Act101112.

Is Gemini GDPR-compliant?

Google Gemini is not GDPR-compliant or non-compliant on its own: used with the right account under the right Google contract, with region settings and documentation in place, it can be used in a GDPR-compliant way. Google states that Gemini for Workspace is covered by the Workspace Data Processing Amendment, that Workspace customer data is not used to train generative models for other customers, and that Vertex AI inputs and outputs on Google Cloud are not used for training either125. What remains is your part: the right product, the right region and the paperwork.

Three Geminis, not one

“Gemini” is three products with different privacy terms: the consumer Gemini app at gemini.google.com with a personal account, Gemini for Workspace inside Gmail, Docs, Sheets and Meet with a work account, and Vertex AI with Gemini on Google Cloud for developers and vendors. For data protection, what counts is which one your team uses, not the brand on the page.

The European way across Outlook, Teams and Slack: Superkind

If you want an AI employee that works where your team already works, hosted and processed in Europe, you do not have to pick a US suite. Superkind is the AI employee for your team: you write to Superkind in Outlook or any email, Microsoft Teams, Slack or the Superkind web app like you would to a colleague, and it does the task in your programs through 1,500+ integrations such as SharePoint, Excel, HubSpot and DATEV. Superkind is hosted and processed in Europe, GDPR compliant, aligned with the EU AI Act and never trains models on your data. It uses AI models from OpenAI, Anthropic, Mistral and Google - including Gemini - but all inference happens in European regions, and the data processing agreement comes through the Trust Center. The difference to Gemini is the job: Gemini helps each person draft and summarise, Superkind takes over whole tasks.

  1. 1

    You write the task

    In Outlook, Teams, Slack or the web app, in plain words: “Answer Ms Berger about her delivery date and log the call in HubSpot.”

  2. 2

    Superkind does it in your systems

    It reads the email, looks up the order in your ERP, uses your company knowledge (prices, delivery times, tone) and follows your rules, such as “Credit notes over EUR 200 need sign-off from the team lead”.

  3. 3

    Superkind asks before anything goes out

    You get the draft reply and the CRM entry with Approve or Reject. Nothing is sent or changed without your OK, and a colleague can approve in Teams or Slack.

  4. 4

    Next time it runs as a routine

    What you explain once keeps running, for example “Every delivery question - draft the reply, log it, ask me”. Every task adds to your Company Brain, which stays in Europe.

OutlookDaniel to Superkind

Answer Ms Berger about order 4012, log the call note in HubSpot and send me the draft for approval before it goes out.

Send Superkind your first task in Outlook or Teams

Start for free. Hosted in Europe, no training on your data, approval before anything goes out.

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How Gemini and the GDPR fit together

The GDPR does not ban Gemini. Six parts decide whether your use is compliant.

  1. The account and the contract - Gemini for Workspace is covered by the Google Workspace Data Processing Amendment (DPA), with Google as processor under Art. 28 GDPR. Vertex AI on Google Cloud is covered by the Google Cloud DPA. The consumer Gemini app with a personal Google account runs under consumer terms and is not covered by either business DPA25.
  2. No training on your data - for Workspace, Google states that customer data in Gmail, Docs and Drive and prompts and responses in Gemini for Workspace are not used to train generative models for other customers. The same is true for Vertex AI inputs and outputs. For the consumer app, Google may use conversations and may sample them for human review to improve services unless the user turns Gemini Apps Activity off145.
  3. Where the data is processed - Google Workspace offers a data regions policy that lets eligible customers pin covered customer data at rest to Europe. Some processing may still happen outside the chosen region, including some Gemini for Workspace inference. On Vertex AI you set the processing region explicitly, including europe-west36.
  4. International transfer (Art. 44) - Google is a US company under the US CLOUD Act. Transfers of personal data to Google are documented under the EU-US Data Privacy Framework (adequacy decision of 10 July 2023), which the European Commission considers to provide an adequate level of protection, with Standard Contractual Clauses as the fallback712.
  5. Human review in the consumer app - for the consumer Gemini app, Google documents that a sample of conversations is reviewed by trained reviewers to improve the service, and advises users not to enter confidential information. Workspace Gemini and Vertex AI do not include this human review of customer prompts4.
  6. Your own paperwork - a lawful basis under Art. 6 (and Art. 9 for health or other special categories), an entry in your record of processing (Art. 30) and a data protection impact assessment (Art. 35) where the use is likely to be high risk. Under the EU AI Act (Regulation (EU) 2024/1689), Art. 4 requires AI literacy for staff from February 2025, and Art. 50 adds transparency duties from 2 August 2026, including labelling AI-generated text published to inform the public unless a person reviewed it1011.

The CLOUD Act, in one honest line

US ownership is not an automatic GDPR failure. It is a documented risk you manage with region choice (europe-west on Vertex AI), with what you send to the model and with Art. 44 paperwork. For sensitive processing, the simpler answer is an EU-first vendor like Superkind, hosted and processed in Europe end to end.

The three Geminis and the GDPR compared

As of October 2026. Where each version stands on the points that decide GDPR fit, with Superkind for comparison, based on the vendors’ own statements123456. Not a compliance sign-off.

VersionWorks withTraining on your dataHosting / Data protectionDPA / AVV
Superkind (for comparison)Outlook, Teams, Slack, web app; does tasks in 1,500+ integrations (SharePoint, Excel, HubSpot, DATEV ...) with approvalNeverHosted and processed in EuropeYes, via the Trust Center
Gemini app (consumer), personal Google accountWeb, pasted text, uploaded filesPossible, with human review sampling, unless the user turns Gemini Apps Activity off4US consumer service, no choice of regionNo
Gemini for Workspace, work Google Workspace accountGmail, Docs, Sheets, Slides, Meet, Drive and the Gemini side panelNo1Workspace data regions pin covered data at rest to Europe; some inference may route elsewhere3Yes, Workspace DPA2
Vertex AI with Gemini, Google CloudAPI for your developers or vendors, choose regionNo5Set region to europe-west; inputs and outputs stay in that region6Yes, Google Cloud DPA

In short: the consumer Gemini app is the wrong place for customer or employee data; with a Workspace account you get the contract and a data region, and the open points are the CLOUD Act and where inference may route; on Vertex AI you get full region control for the API. For the Microsoft side of this question, see Is Microsoft Copilot GDPR-compliant?, and for ChatGPT, Is ChatGPT GDPR-compliant?. For teams looking to switch away from Gemini entirely, see 8 GDPR-compliant Gemini alternatives.

Examples: Gemini and the GDPR in practice

Five realistic situations and what each needs to stay compliant.

1. Superkind handles customer requests in Outlook and Teams

Nadine forwards a customer email in Outlook to Superkind. Superkind looks up the order in SAP Business One, drafts the reply, logs the call note in HubSpot and asks her for approval before anything goes out. The data is processed in Europe, with no training on it and the DPA through the Trust Center. It connects through 1,500+ integrations such as SharePoint, Excel, DATEV and Zendesk. See email inbox triage for how this runs day to day.

2. Gemini for Workspace drafts a reply inside Gmail

Signed in with a Workspace work account, the sales lead uses the Gemini side panel in Gmail to draft a quote reply. Prompts and responses fall under the Workspace DPA and are not used to train models12. The open point is where inference routes; eligible customers can turn on data regions to pin covered data at rest to Europe3. The draft still has to leave the Gemini pane and get into your CRM by hand.

3. The consumer Gemini app with a private account

A colleague pastes a prospect list into gemini.google.com while signed in with a personal account to write an outreach email. That chat is not covered by any business DPA, and Google may sample it for human review and use it to improve services unless the user turned Gemini Apps Activity off4. Make the rule explicit: company data only with the Workspace account.

4. Vertex AI powers a vendor’s product

A software vendor builds a feature on Vertex AI with Gemini, with region set to europe-west4 in Belgium. Inputs and outputs stay in that region, and content is not used for training56. The vendor still has to flow the Google Cloud DPA through to its customers and record the processing itself.

5. HR summaries with health data

An HR lead wants Gemini to summarise sick notes and return-to-work talks. Health data is a special category under Art. 9 GDPR; here a DPIA under Art. 35 is likely due10. Keep the use on Workspace or Vertex AI with a DPIA, or stay with an EU-first vendor like Superkind where the processing is in Europe end to end.

What a compliant Gemini setup needs (and what it costs)

Short, but none of it happens by itself.

  • Workspace accounts only - company data only with the Google Workspace work account, where the DPA applies2.
  • A decision on data regions - for Workspace, turn on data regions and choose Europe; for Vertex AI, set the processing region to europe-west36.
  • Turn off Gemini Apps Activity on consumer accounts - or ban the consumer app outright for anything work-related4.
  • Document the Art. 44 transfer - cite the EU-US Data Privacy Framework adequacy decision and keep SCCs on file as a fallback12.
  • Record of processing and DPIA - add Gemini to your record (Art. 30) and run a DPIA (Art. 35) where the risk is high10.
  • AI literacy and transparency - train staff and set rules under Art. 4 EU AI Act; from 2 August 2026, Art. 50 adds transparency duties for some AI-generated content11.

What Gemini costs

As of October 2026. Google list prices for Germany, per user per month, excl. VAT. Gemini is bundled into Workspace rather than sold as a separate add-on9.

ProductPriceNote
Superkind (for comparison)Free start, Business from EUR 50 per monthFor the whole company, unlimited users, no price per seat
Gemini app (consumer)Free; Google AI Pro around EUR 21.99 per monthNot for company data; private account only
Google Workspace Business StarterAround EUR 5.75 per user per monthGemini features included, annual plan9
Google Workspace Business StandardAround EUR 11.50 per user per monthGemini features included, annual plan9
Google Workspace Business PlusAround EUR 17.25 per user per monthGemini features included, annual plan9
Gemini Enterprise (Google Cloud)From USD 21 per user per month plus consumptionAgent platform, separate from Workspace8
Vertex AI with GeminiPer token, billed by Google CloudDeveloper API, region europe-west6

The honest reading: for a Workspace team, Gemini is included in the plan you already pay for, so the real question is not price but whether a per-seat generative assistant inside Gmail is what you need, or a cross-system AI employee that does the task. Ten Workspace Business Standard seats are roughly EUR 115 per month before VAT; ten Business Plus seats, EUR 172.

Data protection and EU hosting

Safe by default

Your data stays in Europe, under a DPA, with no training on your data.

For a customer email in Outlook, a contact in HubSpot or a file in SharePoint, the personal data Superkind works with is processed in Europe from the first task, with approval before anything leaves the team.

What Superkind costs

As of October 2026. Prices excl. VAT, for the whole company with unlimited users.

  • Free - EUR 0 with a one-off up to EUR 150 in credits to start. No credit card, no sales call, every feature and connection.
  • Business - from EUR 50 per month for 25,000 credits. EUR 100 for 50,000 credits is the popular step, then EUR 200 and EUR 500. No price per seat, unused credits carry over one month, custom apps included, cancel monthly.
  • Enterprise - custom price for your volume, dedicated support with SLA, SSO/SCIM and audit log, a DPA and help with the security review, payment by invoice.
  • What credits buy - a question uses 10-50 credits, a task 50-500 credits and a run of your own agent 1,000-5,000 credits. EUR 100 covers up to 1,000 tasks or 5,000 questions.

How to start

Start with one real task this week and get your Gemini situation in order at the same time. Three steps:

Your 3-step plan

  • Test an AI employee on one real task - start Superkind for free at app.superkind.ai with up to EUR 150 in credits, send one real customer or booking task in Outlook, Teams or Slack and compare. Many teams end up using both: Gemini for writing inside Gmail, Superkind for tasks across several systems. More options: 8 GDPR-compliant Gemini alternatives.
  • Pick the right Gemini and turn on data regions - company data only with Workspace accounts, data regions set to Europe for eligible plans, Vertex AI region set to europe-west, consumer app blocked or Gemini Apps Activity turned off. Add Gemini to your record of processing. That also starts your AI literacy duty under Art. 4 EU AI Act11.
  • Document the transfer and the DPIA - cite the EU-US Data Privacy Framework for Art. 44, run a DPIA (Art. 35) where the risk is high, and share the plan with your data protection officer1012.

From the first task to your own app

A real example from the field: a sales team wanted to use the consumer Gemini app to answer customer emails faster, the data protection officer said stop, and the team switched to Superkind. The data stayed in Europe from the first task to the custom app the company later built. Four stages, on that customer-request example:

  1. 1

    Ready in minutes

    Sign up for free, forward the first customer email in Outlook and watch Superkind draft the reply, pull the order from the ERP and log it in HubSpot.

  2. 2

    Tasks become routines

    What you explain once keeps running as a routine, for example every delivery question answered and logged. Before anything goes out, Superkind asks for approval.

  3. 3

    Learns from day one

    Every task makes Superkind smarter. Customers, prices and processes end up in your Company Brain, and that knowledge is never lost, even when people leave.

  4. 4

    Your own app, without starting over

    When it gets more complex, you build custom solutions, apps and integrations on top of what Superkind already knows, for example a customer-service app for your team: your Super App. Built yourself or together with us. It all belongs to you.

Conclusion

Gemini can be used in a GDPR-compliant way: with a Workspace account it runs under Google’s DPA, with data regions it stays in Europe at rest, and Vertex AI with Gemini gives you full region control for the API. The work is in the details: the consumer app is a different product, the CLOUD Act is a documented risk you manage, and the paperwork stays with you. For an AI employee that does whole tasks in Outlook, Teams and Slack, hosted and processed in Europe with approval before anything goes out, Superkind connects to SharePoint, Excel, HubSpot, DATEV and 1,500+ integrations from EUR 50 per month for unlimited users (as of October 2026). Check your Workspace region settings this week, then send Superkind one real task and compare.

Frequently Asked Questions

It depends on which Gemini and which account. With a Google Workspace work account, Gemini for Workspace is covered by the Google Workspace Data Processing Amendment (DPA), Google acts as processor under Art. 28 GDPR, and prompts, responses and your Workspace data are not used to train generative models. The free consumer Gemini app at gemini.google.com with a personal Google account is not covered by the Workspace DPA and your conversations may be reviewed by humans and used to improve Google services unless you turn Gemini Apps Activity off. On Google Cloud, Vertex AI with Gemini is covered by the Google Cloud DPA, you choose the processing region (including europe-west), and content is not used for model training. As of October 2026, not legal advice.

The Gemini app at gemini.google.com with a personal account is a consumer service. Gemini for Workspace is the business edition that runs inside Gmail, Docs, Sheets, Slides, Meet and Drive and is covered by the Workspace DPA. Vertex AI is the Google Cloud API with Gemini models for developers and vendors, with region controls, a Cloud DPA and no training on your inputs. For data protection, what counts is the account and the service, not the icon.

Not with Workspace or Vertex AI. Google states that Workspace customer data and prompts and responses in Gemini for Workspace are not used to train generative models for other customers. The same applies to Vertex AI inputs and outputs. For the consumer Gemini app, Google may use conversations and sample them for human review to improve services unless the user turns Gemini Apps Activity off, which is one reason to keep company data out of personal accounts.

For Workspace, Google offers a data regions policy that lets eligible customers pin covered Workspace data at rest to the EU, and client-side encryption keeps content keys with you. Gemini for Workspace inference is processed in Google data centres with regional routing for eligible customers, but some processing may still happen outside the chosen region. On Vertex AI you can set the region, including europe-west, so inputs and generated outputs are stored in the EU. The consumer Gemini app does not offer this control.

No. Google is a US company and so is subject to the US CLOUD Act, which US authorities can use to request data regardless of where it is stored, but a US request is not the same as unlimited access and the EDPB does not treat US ownership as an automatic GDPR failure. For regulated workloads the practical answers are limiting what personal data goes to the model, choosing a European processing region on Vertex AI, documenting the Art. 44 transfer under the EU-US Data Privacy Framework, and keeping sensitive processing on an EU-first vendor. Superkind uses OpenAI, Anthropic, Mistral and Google models too, all processed in Europe.

Your team writes to Superkind in Outlook or any email, Microsoft Teams, Slack or the web app, and Superkind does the task in your programs through 1,500+ integrations such as SharePoint, Excel, DATEV, HubSpot and Personio, with AI models from OpenAI, Anthropic, Mistral and Google processed in Europe. It asks for approval before anything goes out, follows your rules and keeps the knowledge in your Company Brain. It is hosted and processed in Europe, never trains on your data, and the DPA comes through the Trust Center.

Under Art. 35 GDPR, a Data Protection Impact Assessment is required when processing is likely to result in a high risk, which includes large-scale processing of special categories or systematic monitoring of employees. For routine Gemini for Workspace use with normal company documents a DPIA is often not required, but is wise. For HR, health or large-scale customer-data use, plan a DPIA. Record the processing under Art. 30 either way, and confirm with your data protection officer.

As of October 2026, Google bundles Gemini for Workspace into Workspace plans, with Business Standard around EUR 11.50 and Business Plus around EUR 17.25 per user per month on annual billing in Germany, excl. VAT, so Gemini is included rather than a separate add-on. Google Cloud Gemini Enterprise is listed from around 21 US dollars per user per month plus consumption, and Vertex AI is billed per token. Superkind starts free with a one-off up to EUR 150 in credits; Business starts from EUR 50 per month for the whole company with unlimited users, no price per seat.

Henri Jung, Co-founder at Superkind
Henri Jung

Co-founder of Superkind, the AI employee teams write to in Outlook, Teams and Slack. Henri helps companies, from small teams to the Mittelstand, hand their routine work to AI - without new tools, consultants or an in-house AI team.

Send Superkind your first task.

Start for free in Outlook, Teams or Slack, hosted and processed in Europe. Or see in 30 minutes how it runs in your setup.