Cohere states that it does not sell or share enterprise customer data with outside companies for business or commercial reasons.
This analysis describes what Cohere's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision addresses a key concern for enterprise customers about whether their proprietary business data submitted to an AI platform could be disclosed or monetized by the platform provider.
Interpretive note: The document does not specify whether this commitment extends to sub-processors or is limited to direct commercial sale; review of the sub-processor list and executed agreement is required to assess full scope.
According to this document, Cohere does not sell or share enterprise customer data with third parties for commercial purposes. Enterprise customers whose data includes proprietary business information, trade secrets, or personal data should confirm this commitment is binding under their executed service agreement.
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"Cohere does not sell or share enterprise customer data with third parties for commercial purposes.— Excerpt from Cohere's Cohere Enterprise Data Commitments
(1) REGULATORY LANDSCAPE: A commitment not to sell customer data engages CCPA's definition of 'sale' of personal information and the associated opt-out rights. Under GDPR, sharing personal data with third parties for commercial purposes would require a legal basis and likely controller-to-controller transfer mechanisms. The FTC Act prohibition on unfair or deceptive practices is relevant if this commitment is not operationally implemented. Relevant enforcement authorities include the California Privacy Protection Agency, EU data protection authorities, and the FTC. (2) GOVERNANCE EXPOSURE: Medium. This is a common commitment in enterprise AI agreements. The key compliance question is whether the commitment extends to all forms of data disclosure (including to sub-processors) or only to direct commercial sale. The document should be reviewed against Cohere's sub-processor list to confirm consistency. (3) JURISDICTION FLAGS: California enterprise customers should confirm that this commitment satisfies CCPA requirements regarding service provider restrictions on data use. EU customers should verify that the commitment is reflected in the data processing agreement's restrictions on sub-processor engagement. Regulated industries (healthcare, financial services) may have additional non-disclosure requirements. (4) CONTRACT AND VENDOR IMPLICATIONS: The master service agreement should expressly prohibit Cohere from selling or sharing customer data for commercial purposes and should specify permitted sub-processor disclosures. Procurement teams should request and review the current sub-processor list to confirm alignment with this commitment. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether the no-sharing commitment is documented in the executed contract and whether it covers all relevant categories of customer data including metadata, usage logs, and fine-tuning datasets. Regular review of Cohere's sub-processor list and prompt notification of sub-processor changes are standard due diligence steps for GDPR-compliant vendor management.
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This provision addresses a key concern for enterprise customers about whether their proprietary business data submitted to an AI platform could be disclosed or monetized by the platform provider.
According to this document, Cohere does not sell or share enterprise customer data with third parties for commercial purposes. Enterprise customers whose data includes proprietary business information, trade secrets, or personal data should confirm this commitment is binding under their executed service agreement.
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