Gmail with Gemini and the GDPR: AI training, data location and DPA

Doesn't train on your data.

No. Google will not use customer data to train or fine-tune its generative AI models behind Workspace without the customer's prior permission or instruction. Optional feedback is also not used for training.

Vendor's wording: “Google will not use Customer Data to train or fine-tune any of its generative artificial intelligence models supporting the Google Workspace Generative AI Services without Customer's prior permission or instruction.”

Source: workspace.google.com12.11 Training RestrictionChecked on 19 October 2026

No fixed region by default. Unless an admin selects a Data Region (US or Europe), Google may store or process data wherever it or its subprocessors have facilities.

Vendor's wording: “Google may store or process any Customer Data that is not covered by the Data Regions Policy wherever Google or its Subprocessors maintain facilities”

Source: workspace.google.com1.3 Limitations (Data Regions)Checked on 19 October 2026

EU hosting available.

Yes, partly. Business Standard includes Fundamental Data Regions: an admin can pin Gmail content and Gemini app prompts at rest to Europe. Keeping processing in use in Europe needs Enterprise Data Regions (Enterprise Plus or add-on).

Vendor's wording: “Business Standard Fundamental Data Regions*”

Source: knowledge.workspace.google.comSupported editionsChecked on 19 October 2026

DPA in the terms.

Yes. The Cloud Data Processing Addendum is incorporated into the Workspace agreement and covers customer data, including Gemini prompts.

Vendor's wording: “This Cloud Data Processing Addendum (including its appendices, the "Addendum") is incorporated into the Agreement(s)”

Source: workspace.google.comPreambleChecked on 19 October 2026

Published.

Yes: https://workspace.google.com/terms/subprocessors.html (last modified Oct 19, 2026). 14 third-party entities (support and security-review firms) plus separate Google-affiliate tables; no outside AI model providers listed.

Vendor's wording: “Google and its affiliates engage the third-party entities in the table below to perform limited activities in connection with the Google Workspace Core Services and Cloud Identity Services.”

Source: workspace.google.comThird-Party SubprocessorsChecked on 19 October 2026

On the list.

Active (Google LLC; EU-US DPF, Swiss-US DPF, UK Extension)

Source: dataprivacyframework.govSearch 'Google LLC'Checked on 19 October 2026

Gemini prompts and responses in Workspace: kept 90 days to indefinite, set by admins; users can delete them unless admins block it. Deleted data is removed within a maximum of 180 days; generated content in Gmail follows normal deletion terms.

Vendor's wording: “Prompts and responses 90 days to indefinite, as determined by admins”

Source: knowledge.workspace.google.comGemini data retentionChecked on 19 October 2026

Google names SOC 1/2/3 plus ISO 9001, 27001, 27701, 27017, 27018 and 42001 (9 items) and FedRAMP High authorization for Gemini; Gemini Notebook is not yet covered.

Vendor's wording: “Gemini has attained SOC 1/2/3, ISO 9001, ISO/IEC 27001, 27701, 27017, 27018, and 42001 certifications. Gemini has FedRAMP High authorization.”

Source: knowledge.workspace.google.comDoes using Gemini impact any existing compliance certificationsChecked on 19 October 2026

Yes. On supported editions, admins can enable or disable Gemini features and the side panel in Gmail (and Drive, Docs, Meet, Chat); the Gemini app can be switched off for users.

Vendor's wording: “Additionally, for supported Workspace editions, admins can enable or disable Gemini features and the side panel in the following Workspace services: Gmail”

Source: knowledge.workspace.google.comAs an admin, can I turn Gemini on and off for users?Checked on 19 October 2026

See details.

13.60 EUR per user per month, excluding tax (Business Standard, max 300 users; all plans billed monthly). The page has a toggle 'Jährlich (16 % sparen bei einjähriger Vertragsdauer)', so the commitment term behind 13.60 is not clear from the text. Intro offer: 50% off for 3 months, new customers only, first 20 users.

Vendor's wording: “Ab dem 02.02.2027 Für alle Nutzer 13,60 € • Der Preis gilt pro Nutzer und pro Monat und beinhaltet keine Steuern”

Source: workspace.google.comStandard plan cardChecked on 19 October 2026