Cohere · Cohere SaaS Agreement · View original document ↗

Customer Data Use for Model Training

High severity Medium confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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Document Record

What it is

Unless you opt out, Cohere may use the text you send to and receive from the API to train and improve its AI models.

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)

The agreement authorizes use of customer-submitted inputs and model outputs for model training by default; enterprise customers transmitting confidential, regulated, or sensitive data should confirm their opt-out status before using the API in production.

Interpretive note: The exact opt-out procedure and its operational scope are not fully described in the document excerpt provided; the availability and mechanism of the opt-out may vary by account type or subscription tier.

Consumer impact (what this means for users)

The terms authorize Cohere to use API inputs and outputs for model improvement unless the customer has completed an opt-out, which is directly relevant for organizations processing confidential business information, personal data, or regulated data through the API.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Contact Cohere's privacy team to confirm your account's opt-out status for model training data use and to request completion of the opt-out procedure before submitting sensitive data via the API.

How other platforms handle this

Writer Medium

Writer does not use Customer Data to train its AI models without explicit customer permission. Customer Data means the data, content, and information that customers and their end users submit to or through the Services.

Windsurf Medium

We may leverage OpenAI models independent of user selection for processing other tasks (e.g. for summarization). We may leverage Anthropic models independent of user selection for processing other tasks (e.g. for summarization). We may leverage these models independent of user selection for processi...

Ideogram Medium

We may use the content you provide to us, including prompts and generated images, to train and improve our AI models and services.

See all platforms with this clause type →

Monitoring

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▸ View Original Clause Language DOCUMENT RECORD
"
Cohere may use Inputs and Outputs to provide, maintain, and improve the Services, including to train or fine-tune Cohere's models, unless Customer has opted out of such use in accordance with Cohere's then-current opt-out procedures.

— Excerpt from Cohere's Cohere SaaS Agreement

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision engages GDPR Article 5 (purpose limitation and data minimization), Article 6 (lawful basis for processing), and Article 9 where sensitive personal data categories are involved. EU supervisory authorities are the relevant enforcement bodies for EEA customers. CCPA Section 1798.100 may apply where California residents' personal data is included in API inputs. HIPAA's minimum necessary standard and business associate requirements are also implicated where health information is processed. (2) GOVERNANCE EXPOSURE: High. Default opt-in to model training data use creates compliance exposure for organizations processing personal data, confidential business information, or regulated data, as the processing purpose (model training) may not align with the original purpose for which data was collected. GDPR's purpose limitation principle requires that data not be further processed in a manner incompatible with the original collection purpose. (3) JURISDICTION FLAGS: EU and EEA customers face the highest regulatory exposure, as GDPR's requirements for explicit lawful basis for secondary processing are stringent. California customers should evaluate CCPA obligations around data use notification. Healthcare customers in the US must assess HIPAA compatibility. Financial services customers in regulated jurisdictions should review whether transmitting client data for model training is permissible under applicable regulations. (4) CONTRACT AND VENDOR IMPLICATIONS: The opt-out mechanism should be identified and documented before production deployment. Vendor assessment processes should include confirmation of the current opt-out procedure and whether it can be incorporated into a data processing addendum. The existence of a default opt-in rather than explicit opt-in may require evaluation under GDPR's consent and legitimate interest frameworks. (5) COMPLIANCE CONSIDERATIONS: Data protection officers should conduct a data protection impact assessment (DPIA) for use cases involving personal data. Privacy notices may need to be updated to reflect that data is processed by a third-party AI provider that may use it for model training. Contract templates should be updated to require opt-out confirmation as a condition of production API deployment.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has jurisdiction over unfair or deceptive data practices and has published guidance on AI training data use that is relevant to this provision.
    File a complaint →

Applicable regulations

EU AI Act
European Union
California AB 2013 AI Training Data Transparency
US-CA
Colorado AI Act
US-CO
EU AI Act - High Risk Provisions
EU
GDPR
European Union
Texas AI Act
Texas, USA
Trump Executive Order on AI Policy Framework
US

Provision details

Document information
Document
Cohere SaaS Agreement
Entity
Cohere
Document last updated
May 11, 2026
Tracking information
First tracked
May 11, 2026
Last verified
May 12, 2026
Record ID
CA-P-011557
Document ID
CA-D-00768
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
cf319db4fb54c8ae019dfe7b3515b554f5c486a7dd84bfbb5ce64abed79b18c3
Analysis generated
May 11, 2026 11:52 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Cohere
Document: Cohere SaaS Agreement
Record ID: CA-P-011557
Captured: 2026-05-11 11:52:52 UTC
SHA-256: cf319db4fb54c8ae…
URL: https://conductatlas.com/platform/cohere/cohere-saas-agreement/customer-data-use-for-model-training/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

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Frequently Asked Questions

What does Cohere's Customer Data Use for Model Training clause do?

The agreement authorizes use of customer-submitted inputs and model outputs for model training by default; enterprise customers transmitting confidential, regulated, or sensitive data should confirm their opt-out status before using the API in production.

How does this clause affect you?

The terms authorize Cohere to use API inputs and outputs for model improvement unless the customer has completed an opt-out, which is directly relevant for organizations processing confidential business information, personal data, or regulated data through the API.

Is ConductAtlas affiliated with Cohere?

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