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
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.
if you are accessing and using Lime Services under a corporate account...you acknowledge and agree that Lime may share certain of your usage information with whomever provided you with access to the Lime Services
Monitoring
Cohere has changed this document before.
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"The use of cookies for this purpose may be considered a "sale" or "sharing" under California privacy law.— Excerpt from Cohere's Cohere Privacy Policy
ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.
Your genetic data may be transferred to a new owner as a business asset. Here is what the Terms of Service actually say and what you can do right now.
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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 290 platforms. See the full comparison.
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