Cohere · Cohere Privacy Policy · View original document ↗

Enterprise API Customers as Data Controllers

Medium severity Medium confidence Inferredfromcontext Unique · 0 of 343 platforms
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Recent governance activity Cohere recorded 5 documented changes in the last 30 days.
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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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision allocates data protection responsibilities by designating the customer as the party responsible for lawful basis, compliance obligations, and end-user disclosures, while Cohere assumes processor liability for handling personal information according to customer directions. This allocation determines which party bears primary responsibility for regulatory compliance and data subject rights under frameworks like GDPR.

Interpretive note: The precise contractual terms of Cohere's DPA are referenced but not reproduced in the public privacy policy, so the exact scope of processor obligations and sub-processor disclosure mechanisms cannot be fully assessed from this document alone.

Recent Activity

This document changed recently

Medium Apr 29, 2026

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 →

Consumer impact (what this means for users)

Users of customer-built applications access those applications under terms established by the customer as data controller, not by Cohere directly. Cohere's role is limited to processing personal information according to customer instructions, which means customer privacy policies and data handling practices—not Cohere's—govern how personal information is collected and used in those applications.

How other platforms handle this

Walmart Medium

We collect information about you when you shop in our stores, including through store cameras, loyalty programs, payment processing systems, and other in-store technologies. This information is used to improve store operations, loss prevention, and marketing.

LinkedIn Medium

We target (and measure the performance of) ads to Members, Visitors and others both on and off our Services directly or through a variety of partners, using the following data, whether separately or combined: Data from advertising technologies on and off our Services, like web beacons, pixels, ad ta...

Fiverr Medium

We may de-identify or aggregate your personal information so that it can no longer reasonably identify you, and use such de-identified or aggregated data for any purpose, including sharing with third parties for research, analytics, and marketing purposes, without restriction.

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▸ View Original Clause Language DOCUMENT RECORD
"
When our customers use our API to build their own products and services, they act as data controllers for any personal information their end users provide through those applications. In such cases, Cohere acts as a data processor, processing personal information on behalf of our customers in accordance with their instructions and our Data Processing Agreement.

— Excerpt from Cohere's Cohere Privacy Policy

Applicable regulations

EU AI Act
European Union
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
ePrivacy Directive
European Union
EU AI Act - High Risk Provisions
EU
FTC Act Section 5
United States Federal
GDPR
European Union

Provision details

Document information
Document
Cohere Privacy Policy
Entity
Cohere
Document last updated
May 5, 2026
Tracking information
First tracked
May 10, 2026
Last verified
May 12, 2026
Record ID
CA-P-008245
Document ID
CA-D-00440
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
48f574f6141f754b1e207ebd31ad81a85645609ea91087c0f35d0f4211dd49a2
Analysis generated
May 10, 2026 04:19 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Cohere
Document: Cohere Privacy Policy
Record ID: CA-P-008245
Captured: 2026-05-10 04:19:09 UTC
SHA-256: 48f574f6141f754b…
URL: https://conductatlas.com/platform/cohere/cohere-privacy-policy/enterprise-api-customers-as-data-controllers/
Accessed: July 4, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Cohere's Enterprise API Customers as Data Controllers clause do?

This provision allocates data protection responsibilities by designating the customer as the party responsible for lawful basis, compliance obligations, and end-user disclosures, while Cohere assumes processor liability for handling personal information according to customer directions. This allocation determines which party bears primary responsibility for regulatory compliance and data subject rights under frameworks like GDPR.

How does this clause affect you?

Users of customer-built applications access those applications under terms established by the customer as data controller, not by Cohere directly. Cohere's role is limited to processing personal information according to customer instructions, which means customer privacy policies and data handling practices—not Cohere's—govern how personal information is collected and used in those applications.

Is ConductAtlas affiliated with Cohere?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Cohere.