Is a free, open-source BYOK desktop application for university students in the EEA allowed under the Gemini API Terms?

Gemini API
1

Hello Google AI team,

I am developing a free and open-source desktop application for university students.

The application uses the Gemini API to transform recorded university lectures (audio/video) into structured study notes.

Architecture:

  • The application is completely free and open source.
  • It has no backend or server operated by the developer.
  • It uses a BYOK (Bring Your Own Key) model.
  • Each user independently creates their own Gemini API key and Google Cloud project.
  • The user enters their own key directly into the desktop application.
  • The key is stored locally on the user’s device.
  • API requests are sent directly from the user’s computer to the Gemini API.
  • The developer never receives, stores, or proxies users’ API keys or Gemini requests.
  • The developer does not charge users for the application or for Gemini usage.

Intended use:

The application is intended for personal educational use by university students in Italy/EEA.

I have read the Gemini API Additional Terms and would like clarification on the following:

  1. Does this type of free, open-source, BYOK desktop application constitute “consumer use” under the Gemini API Terms, given that the developer does not provide or resell API access and each user supplies their own credentials?
  2. Does making such an application available to users in the EEA, Switzerland, or the UK require Paid Services, even when each user independently owns and controls their own Google Cloud project and API key?
  3. If Paid Services are required for EEA users, does enabling Cloud Billing on the user’s project satisfy this requirement even if the user continues to stay within the Free Tier usage limits and incurs no actual charges?
  4. Is this architecture otherwise permitted under the Gemini API Terms, assuming compliance with the applicable usage and safety policies?

The purpose of the BYOK architecture is specifically to avoid operating a centralized API service and to let each user control their own credentials, project, quota, and billing.

I would appreciate confirmation regarding whether this specific architecture is permitted.

Thank you.