Cohere states that your data may be stored and processed in Canada and the United States, which may have different privacy protections than your home country.
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 is particularly significant for EU and UK users because transfers of personal data from the EEA and UK to the United States require a lawful transfer mechanism under GDPR and UK GDPR, and the adequacy or sufficiency of those mechanisms is subject to ongoing regulatory scrutiny.
Interpretive note: The specific transfer mechanisms relied upon by Cohere for EU-to-US transfers are not detailed in the available document text; the description reflects the standard framework applicable to companies of this profile.
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 →Severity downgraded from high to medium, and specific jurisdictions (Canada and United States) and infrastructure details added for transparency.
View full change record →If you are based in the EU, UK, or another jurisdiction with cross-border transfer restrictions, your personal data may be transferred to Canada and the United States under the transfer mechanisms Cohere relies upon, which may include Standard Contractual Clauses or adequacy decisions depending on the destination.
How other platforms handle this
to request that your data be transferred to a third party (data portability)
Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.
Further, you may take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data prot...
"Your personal information may be transferred to and processed in countries other than your country of residence, including Canada and the United States, where our servers are located and our central database is operated. These countries may have data protection laws that are different from those in your country.Excerpt from Cohere's Privacy Policy
(1) REGULATORY LANDSCAPE: This provision directly engages GDPR Chapter V (Articles 44-49) governing cross-border data transfers, and the equivalent provisions of UK GDPR.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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This provision is particularly significant for EU and UK users because transfers of personal data from the EEA and UK to the United States require a lawful transfer mechanism under GDPR and UK GDPR, and the adequacy or sufficiency of those mechanisms is subject to ongoing regulatory scrutiny.
If you are based in the EU, UK, or another jurisdiction with cross-border transfer restrictions, your personal data may be transferred to Canada and the United States under the transfer mechanisms Cohere relies upon, which may include Standard Contractual Clauses or adequacy decisions depending on the destination.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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