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
Characterizing cookie use as a potential sale or sharing under California law is consequential because it triggers specific consumer rights and opt-out obligations under that law.
Interpretive note: The clause uses 'may be considered,' preserving uncertainty about whether the activity definitively constitutes a sale or sharing. This qualifier is preserved in all fields.
The updated policy removes explicit language describing data retention timelines and deletion request procedures that were previously available. The prior policy stated that Enterprise Users' inputs and outputs were retained for 30 days, that Trial Users and Researchers were not intended to process personal information, and that deletion requests would normally be responded to within one month (up to three months for complex requests). The updated policy now contains only a general reference to 'retention practices' without specifying these timelines, response windows, or user-type distinctions. Users cannot determine from the updated policy what retention periods apply to their account category or what timeline to expect for deletion requests.
View change record →If you are subject to California privacy law, Cohere's use of advertising cookies may constitute a sale or sharing of your data, which could entitle you to opt-out rights.
How other platforms handle this
Whenever we transfer personal data internationally, we use tools and transfer agreements to: make sure the data transfer complies with applicable law; and help to give your data the same level of protection as it has in the EU...
we may use, retain or share information with law enforcement or others in circumstances where a person's vital interests require protection, such as in the case of emergencies.
Any such de-identified genetic information and phenotypic information we share with third parties for research purposes is done in accordance with Part 46 (beginning with Section 46.101) of Title 45 of the Code of Federal Regulations.
"The use of cookies for this purpose may be considered a "sale" or "sharing" under California privacy law.Excerpt from Cohere's Privacy Policy
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Characterizing cookie use as a potential sale or sharing under California law is consequential because it triggers specific consumer rights and opt-out obligations under that law.
If you are subject to California privacy law, Cohere's use of advertising cookies may constitute a sale or sharing of your data, which could entitle you to opt-out rights.
ConductAtlas has identified this type of provision across 288 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Cohere.