Age Requirements clause: offline (developer-side) generation of static audio/images for a children's app

Hello,

We are developing an educational app for children aged 7–10 (iOS/Android) and would like clarification on the “Age Requirements” clause of the Gemini API Additional Terms of Service (effective March 23, 2026).

How we use the Gemini API

  • Only on the developer side, offline, in batch, to create static assets: (1) audio clips from fixed scripts (gemini-3.8-flash-tts), (2) character and scenario images (Gemini image generation), (3) test data / example answers (a Gemini text model).
  • The generated files are bundled inside the app as static files.
  • The app itself never calls any Gemini API at runtime.
  • No end-user data (and no data from children) is ever sent to the API. Our prompts contain only our own scripts and image descriptions.
  • Our project is on the paid tier with billing enabled.

The clause says we “will not use the Services as part of a website, application, or other service … that is directed towards or is likely to be accessed by individuals under the age of 18.”

Questions

  1. Is it permitted to include audio and images generated this way (offline, developer-side) in a children’s app, given that the app itself does not use the Services at runtime?
  2. If not, which product or terms would allow generating such static assets for a child-directed app (for example, Cloud Text-to-Speech under Google Cloud terms, or Vertex AI)?
  3. Are there attribution or other requirements for generated audio and images bundled in an app?
  4. Do the same terms apply to image generation and text generation used in the same way?

Related question from another developer: Age Restrictions in Gemini API Terms: general-audience app (rated 3+) with an adult-only AI feature

We do not plan to call the API at runtime. An official answer would help other developers in the same situation. Thank you!

Hello @White_Coin ,

We can’t provide specific legal guidance on this forum. Please refer to the documents below: