Clarification on “Only Paid Services” for EEA/CH/UK

Gemini API
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Hi Google AI team,

We’re reviewing the Gemini API Additional Terms. Relevant text includes:

“You may use only Paid Services when making API Clients available to users in the European Economic Area, Switzerland (CH), or the United Kingdom.”

“When you activate a Cloud Billing account, all use of Gemini API and Google AI Studio is a ‘Paid Service’ with respect to how Google Uses Your Data, even when using free tiers.”

Could you please clarify:

  1. Scope (global product with mixed audience) — Our service is globally available and serves both EEA/CH/UK and non-EEA users. Which of the following is compliant?

    A. Differentiated routing/billing: Requests from EEA/CH/UK users are served via Paid Services, while requests from non-EEA users may still use Unpaid Services (free tiers).

    B. Global paid requirement: If any portion of our user base is in EEA/CH/UK, then our entire product (all regions) must operate using Paid Services only, with no Unpaid Services anywhere.

    If neither A nor B is correct, please state the correct interpretation explicitly.

  2. Cloud Billing — If we enable Cloud Billing, does that satisfy the “Paid Services” requirement for EEA/CH/UK traffic even when it consumes free tiers (since, for data-use purposes, such usage is treated as “Paid Service”)?

  3. Location signal — Is IP geolocation an acceptable signal to determine a user’s location for this requirement, or should we combine it with account country, billing address, etc.?

Thanks a lot for the clarification!