Aleph Alpha vs. Gemini Notebook: data protection per plan

not publicly documented (no public DPA text; the privacy notices cover only the website, no product/customer contract; when retrieved on 2026-10-18 the documentation link "Data privacy" leads to the website privacy notices, and the support portal is accessible only after logging in)

no (the Google Terms of Service and the Google Privacy Policy apply; no DPA)

no (the Google Terms of Service and the Google Privacy Policy apply; no DPA)

yes (as a core service under the Workspace contract including the Cloud Data Processing Addendum)

yes (Generative AI Service under the Google Cloud contract; Cloud Data Processing Addendum)

not publicly documented: The privacy notices apply to the website aleph-alpha.com. Regarding customer data in PhariaAI operation, there is no statement on training on the platform, documentation or press release pages. The platform page states: "You retain full control over your data and processes." (translated) (no statement on training). Kolibri training data: according to the press release of 2026-10-05, checked against a blocklist of more than 4.5 million URLs; this concerns the origin of the model training data, not customer data. Technical Report on Kolibri (q13): "we redact PII from all training sources" (likewise concerns model training data, not customer data).

Help 'Privacy and Terms of Use': 'The content in Gemini Notebook will not be used to directly train our foundational AI models, unless you choose to provide feedback.' With thumbs up/down feedback, prompts, sources, uploads and outputs are reviewed by trained teams and used to improve products and machine-learning technologies. Data that Gemini Notebook shares with other Google services (e.g. the Gemini app) is used according to their notices, 'including for product improvement'.

Plans page: 'Your data is protected, and is not used to train Gemini Notebook unless you provide feedback.' With feedback, the full context (queries, uploads, responses) may be reviewed. Help 'Privacy and Terms of Use': no direct use for training the foundational models without feedback; data shared with other Google services is used according to their notices, including for product improvement.

Workspace Privacy Hub: 'your uploads, queries and the model's responses in Gemini Notebook will not be reviewed by human reviewers, and will not otherwise be used to train generative AI models.' Help: no human review and no training even with thumbs up/down feedback.

Plans page (Upgrading via Google Cloud): 'all files, chats and model outputs won't be reviewed by human reviewers or used to improve generative AI models.'

Platform page: "Available on-premise, air-gapped or in a sovereign SaaS solution" (translated); models are provided "in sovereign cloud, hybrid and on-premises environments" (translated). Press release 2025-05-26: PhariaAI-as-a-Service on STACKIT (Schwarz Group), "hosted entirely on European infrastructure". PhariaAI launch 2024-08-26: "available as SAAS solutions or on-premise in the customers' own datacenter"; hybrid execution (on-prem + cloud) possible. Specific data centre locations per operating model, and whether any operating mode runs exclusively in Germany: not publicly documented. Note: when retrieved on 2026-10-14, the model page (q9) contains the statement "Ownership, development and supply chain lie entirely in Germany and the EU" (translated) and "Confidential data always remains with the customer" (translated) (no information on data centre locations); the previously recorded wording "No foreign jurisdiction has access" (translated) is no longer contained there. Release notes PhariaAI v1.260900.0 (2026-09-03, q14): "Availability: On-premise and hosted". Technical Report (q13) on model training (not on customer operation): "train it on infrastructure in Germany and Finland".

Gemini Notebook Enterprise documentation (comparison table): with the personal Gemini Notebook, users cannot specify data residency ('Users can't specify'). Google LLC is certified under the EU-U.S. Data Privacy Framework (Google Privacy Policy, Data transfer frameworks). Google Privacy Policy (Data transfer frameworks): 'We maintain servers around the world and your information may be processed on servers located outside of the country where you live.' A storage location specific to Gemini Notebook is not documented.

As Standard: data residency cannot be selected for personal accounts (Enterprise documentation); Google LLC certified under the EU-U.S. Data Privacy Framework. Google Privacy Policy (Data transfer frameworks): 'We maintain servers around the world and your information may be processed on servers located outside of the country where you live.' A storage location specific to Gemini Notebook is not documented.

not publicly documented: Workspace Privacy Hub: 'Your organization's file sharing and data region settings do not apply to data in Gemini Notebook.' Workspace Admin Help 'Data covered by data regions': Data Regions are not supported for Gemini Notebook. The pages do not name a storage location. Sources added from Drive are stored as a copy with the Gemini Notebook data.

Enterprise documentation: data stays in the customer's Google Cloud project; Gemini Notebook Enterprise is available in the 'eu' and 'us' multi-regions and 'global', with data residency commitments for storage (at rest) and ML processing depending on the location; for data in the EU, licences from an 'eu' subscription are required. Google recommends 'global' if there are no regulatory reasons for a region.

• not publicly documented (no list published). Named as infrastructure partner for PhariaAI-as-a-Service: STACKIT (Schwarz Group), press release 2025-05-26.

• not publicly documented (no sub-processor list for consumer services; feedback is reviewed by 'specially trained teams')

• not publicly documented (no sub-processor list for consumer services)

• Google Workspace Third-Party Subprocessors (applies to all Workspace core services, i.e. also Gemini Notebook): including Accenture, Cognizant, EPAM, Deloitte, GlobalLogic for technical support with processing in, among others, the US, India, Canada, Japan, Romania and Bulgaria

• Google Cloud Subprocessors list (for Google Cloud services; an allocation specific to Gemini Notebook is not shown there)

not publicly documented (no public plan; contact via "Contact sales" (translated))

EUR 0 with a Google Account (subscriptions page gemini.google, German version)

Google AI Plus EUR 4.99/month; Google AI Pro EUR 21.99/month; Google AI Ultra EUR 99.99/month (5x the limits of AI Pro) or EUR 219.99/month (20x) (subscriptions page gemini.google, German version, as of 2026-10-18); Gemini Notebook is included in the subscriptions

Per user/month with monthly billing, excl. taxes: Business Starter EUR 6.80; Business Standard EUR 13.60; Business Plus EUR 21.10; introductory discounts for new customers (Workspace pricing page, German version, as of 2026-10-18). Enterprise editions via sales.

USD 9 per licence per month, minimum 15 licences, 30-day trial (Google Cloud product page); monthly or annual subscriptions, up to 5,000 licences per subscription (licensing documentation; the documentation states a 14-day trial)

yes (PhariaAI stack according to the documentation: PhariaAssistant, PhariaStudio, PhariaOS, PhariaCatch; models including Kolibri, available since 2026-10-03)

yes (notebooks with own sources, chat, audio and video overviews, mind maps, reports, flashcards, infographics, slides; 100 notebooks and 50 sources per notebook)

yes (as Standard with higher limits and premium features: Plus 200 notebooks/100 sources, Pro 500/300, Ultra 500/500 or 600; earlier access to features, advanced sharing, with Pro/Ultra removal of the visible watermark)

yes (Gemini Notebook as a Workspace core service; Business Starter with standard access, Business Standard and Plus with extended access and higher limits per edition)

yes (Gemini Notebook with at least the same limits as the consumer version, additionally DOCX/PPTX/XLSX sources, sign-in via Cloud Identity or external IdP, VPC Service Controls, IAM, CMEK, audit logs, API)