Cohere · Cohere Terms of Use · View original document ↗

Privacy and Data Handling Reference

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Document Record

What it is

The Terms of Use reference or incorporate Cohere's Privacy Policy, which governs how Cohere collects, uses, and shares user data including information submitted through the API.

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)

Data handling provisions define the operational scope of personal information collection and use, establish legal bases for processing, and specify third-party recipients, which determines compliance obligations and user disclosure requirements under applicable privacy laws.

Interpretive note: Specific privacy and data handling clause language was not extractable from the truncated HTML document; this provision is inferred from the document's stated scope covering the API and all content, and from standard AI API terms of service structures.

Consumer impact (what this means for users)

Data submitted to Cohere's API and website is subject to the Privacy Policy referenced in or incorporated by these Terms of Use; users and enterprise customers should review the Privacy Policy to understand how input data, usage data, and account information are processed and whether model training on user inputs is permitted.

How other platforms handle this

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Information You Provide may include sensitive personal information, as defined under applicable state privacy laws. We process such information in accordance with applicable law, such as to provide the Services and other permitted purposes under state privacy laws, like the California Consumer Priva...

Best Buy Medium

Depending on where you live, you may have certain rights regarding your personal information. These rights may include the right to know what personal information we have collected about you, the right to delete your personal information, the right to correct inaccurate personal information, the rig...

OpenAI Medium

Depending on where you live, you may have certain rights regarding your personal information, including: the right to know what personal information we have collected about you; the right to delete personal information we have collected from you; the right to correct inaccurate personal information;...

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ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: Data handling provisions in AI API terms engage GDPR (particularly Articles 6, 13, and 28 regarding lawful basis, transparency, and processor obligations), CCPA, and Canada's PIPEDA. Where Cohere processes personal data submitted through the API on behalf of enterprise customers, a Data Processing Agreement may be required under GDPR Article 28. The EU AI Act also imposes transparency obligations on general-purpose AI model providers regarding training data. (2) GOVERNANCE EXPOSURE: High. Enterprise customers who submit personal data to the Cohere API without a Data Processing Agreement in place may be in breach of GDPR. The question of whether Cohere uses API inputs for model training is particularly material for customers handling proprietary or sensitive data. (3) JURISDICTION FLAGS: EU/EEA organizations face the highest exposure due to GDPR's strict processor agreement requirements. California-based organizations should assess CCPA compliance, including whether any sharing of user data with Cohere constitutes a sale or sharing of personal information under California law. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise procurement teams should request and review Cohere's Data Processing Agreement (DPA) before processing any personal data through the API. The DPA should address sub-processor lists, data retention, deletion rights, and breach notification obligations. (5) COMPLIANCE CONSIDERATIONS: Organizations should conduct a data mapping exercise to identify what personal data, if any, is submitted to the Cohere API, confirm that an appropriate legal basis exists for that processing, and ensure that a DPA is in place before any personal data is processed.

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 handling practices for US-based users and businesses using Cohere's services
    File a complaint →

Applicable regulations

EU AI Act
European Union
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
EU AI Act - High Risk Provisions
EU
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Cohere Terms of Use
Entity
Cohere
Document last updated
May 5, 2026
Tracking information
First tracked
April 30, 2026
Last verified
May 12, 2026
Record ID
CA-P-011100
Document ID
CA-D-00441
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
fce6a3fe9260708841b139a17617c1f2c9485f652de86766eaaf928e6f5e0872
Analysis generated
April 30, 2026 06:55 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Cohere
Document: Cohere Terms of Use
Record ID: CA-P-011100
Captured: 2026-04-30 06:55:06 UTC
SHA-256: fce6a3fe92607088…
URL: https://conductatlas.com/platform/cohere/cohere-terms-of-use/privacy-and-data-handling-reference/
Accessed: May 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Cohere's Privacy and Data Handling Reference clause do?

Data handling provisions define the operational scope of personal information collection and use, establish legal bases for processing, and specify third-party recipients, which determines compliance obligations and user disclosure requirements under applicable privacy laws.

How does this clause affect you?

Data submitted to Cohere's API and website is subject to the Privacy Policy referenced in or incorporated by these Terms of Use; users and enterprise customers should review the Privacy Policy to understand how input data, usage data, and account information are processed and whether model training on user inputs is permitted.

Is ConductAtlas affiliated with Cohere?

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