AI data governance disclosure
How Crosscheck uses Gemini API data through Google Cloud
Last updated: May 21, 2026
Document owner: Crosscheck
Purpose: Vendor and procurement review
This document summarizes how Crosscheck uses the Gemini API through Google Cloud, the conditions under which Google applies its published data processing terms, and the representations Crosscheck makes for customer security, privacy, and procurement review.
Table of contents
1. Scope of use
Crosscheck uses Gemini API services through a Google Cloud project controlled by Crosscheck and attached to an active Cloud Billing account. This page concerns that specific usage model.
Crosscheck does not present this disclosure as a statement about consumer Google AI services generally. It is limited to the Gemini API usage Crosscheck operates within its Google Cloud commercial environment.
2. Paid service posture
Google's Gemini API terms distinguish paid usage from other contexts. For vendor review, this matters because the cleaner contractual posture is tied to Gemini API Paid Services used through a Google Cloud project with active billing.
Crosscheck's representation is that Gemini API processing is performed under Crosscheck's billed Google Cloud project.
3. Model training position
Google states in its Gemini for Google Cloud data governance documentation that Gemini does not use customer prompts or responses as data to train its models. Crosscheck relies on that published statement when describing the training posture of customer-submitted content processed through this setup.
For Crosscheck's paid Google Cloud Gemini usage, submitted prompts and received responses are represented as not being used by Google for model training.
4. Data categories covered in Google's published terms
Based on Google's Gemini API paid-service terms, the following categories are described as part of the relevant processing scope.
5. DPA and contractual posture
Google does not typically provide a bespoke countersigned PDF for ordinary self-serve Gemini API adoption. The standard path is acceptance of Google's Cloud Data Processing Addendum and related Google Cloud terms.
Crosscheck therefore describes its position as acceptance of Google's standard DPA framework, rather than a custom bilateral negotiated agreement.
6. Crosscheck attestation
Officer attestation
Crosscheck accepted Google's standard Cloud Data Processing Addendum in its Google Cloud console on May 21, 2026. This acceptance was completed on behalf of Crosscheck by Raphael William Costa, CTO of Crosscheck.
7. Source documents
The following Google documents are the primary references for this disclosure.
Summary statements
- Crosscheck uses the Gemini API through its own Google Cloud project with active Cloud Billing enabled.
- For paid Gemini API usage, Google states that prompts, system instructions, cached content, uploaded files, and responses are processed under Google's Cloud Data Processing Addendum.
- Google documents that prompts and responses for Gemini for Google Cloud are not used to train Google's models.
- Crosscheck accepted Google's standard Cloud Data Processing Addendum in its Google Cloud console on May 21, 2026.