Cohere · Cohere Usage Policy · View original document ↗

Prohibition on Unauthorized Surveillance

High severity Medium confidence Explicitdocumentlanguage Unique · 0 of 343 platforms
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Recent governance activity Cohere recorded 4 documented changes in the last 30 days.
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Document Record

What it is

Developers are prohibited from using Cohere's models to build unauthorized surveillance tools, including systems designed to monitor individuals without their knowledge or consent.

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 prohibition covers AI-assisted surveillance applications, which are an increasingly scrutinized category under both privacy law and the EU AI Act; deploying such applications on Cohere's infrastructure without authorization would constitute a policy breach and may engage independent legal liability.

Interpretive note: The policy does not define what constitutes 'authorized' surveillance, creating interpretive uncertainty for edge cases such as enterprise employee monitoring or parental control applications.

Recent Activity

This document changed recently

High May 24, 2026

The updated policy removes all substantive acceptable use requirements that were previously posted and enforceable. Users no longer have a referenced standard defining what conduct is prohibited on the platform. The removal of enforcement procedures means users cannot verify what conduct may trigger access restriction, suspension, or termination. The elimination of the child safety and sexually explicit content prohibitions from the posted policy creates uncertainty about whether these protections remain in effect through other terms or have been abandoned.

View change record →

Consumer impact (what this means for users)

This provision protects individuals from being monitored through applications built on Cohere's API without their knowledge or consent, directly addressing privacy rights related to personal data and behavioral monitoring.

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▸ View Original Clause Language DOCUMENT RECORD
"
Certain use cases, such as violence, hate speech, fraud, and privacy violations, are strictly prohibited. [The policy specifically identifies unauthorized surveillance as a prohibited use category.]

— Excerpt from Cohere's Cohere Usage Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: Unauthorized surveillance engages GDPR Articles 5 and 6 (lawfulness of processing), CCPA's sensitive data provisions, the EU AI Act's prohibitions on real-time remote biometric identification in public spaces, and the Electronic Communications Privacy Act in the US. State-level biometric privacy laws including Illinois BIPA may also apply where surveillance involves biometric identifiers. The FTC has authority over unfair surveillance practices in consumer contexts. (2) GOVERNANCE EXPOSURE: High. The term 'unauthorized' introduces interpretive complexity; the policy does not define the authorization standard, which means developers must exercise judgment about whether a given surveillance use case would qualify as authorized. This ambiguity creates compliance exposure in edge cases such as employee monitoring or location tracking applications. (3) JURISDICTION FLAGS: EU and EEA deployments face the highest exposure under the EU AI Act's explicit prohibition on certain biometric surveillance systems. Illinois deployments involving biometric data face BIPA exposure. California deployments involving location or behavioral monitoring engage CCPA sensitive data rules. (4) CONTRACT AND VENDOR IMPLICATIONS: Platform operators offering monitoring, analytics, or tracking features built on Cohere should review whether their use case constitutes surveillance and whether appropriate user consent or legal authorization exists. B2B contracts involving employee monitoring or customer behavioral analytics should be specifically reviewed against this prohibition. (5) COMPLIANCE CONSIDERATIONS: Legal teams should assess whether any proposed analytics, monitoring, or tracking feature built on Cohere's API requires disclosure or consent under applicable law and whether that disclosure satisfies the 'authorized' standard implied by this prohibition.

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC has authority over unfair or deceptive surveillance and privacy practices in consumer-facing applications.
    File a complaint →
  • State AG
    State attorneys general enforce biometric privacy laws including Illinois BIPA and California CCPA, which may be engaged by surveillance applications built on Cohere's API.
    File a complaint →

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 Usage Policy
Entity
Cohere
Document last updated
May 5, 2026
Tracking information
First tracked
April 30, 2026
Last verified
May 12, 2026
Record ID
CA-P-011006
Document ID
CA-D-00442
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
2937f674a79ab03784eab9a8774b7c807068d6f695cd81b3eb7bc9419a338c76
Analysis generated
April 30, 2026 06:46 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Cohere
Document: Cohere Usage Policy
Record ID: CA-P-011006
Captured: 2026-04-30 06:46:20 UTC
SHA-256: 2937f674a79ab037…
URL: https://conductatlas.com/platform/cohere/cohere-usage-policy/prohibition-on-unauthorized-surveillance/
Accessed: June 27, 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 Prohibition on Unauthorized Surveillance clause do?

This prohibition covers AI-assisted surveillance applications, which are an increasingly scrutinized category under both privacy law and the EU AI Act; deploying such applications on Cohere's infrastructure without authorization would constitute a policy breach and may engage independent legal liability.

How does this clause affect you?

This provision protects individuals from being monitored through applications built on Cohere's API without their knowledge or consent, directly addressing privacy rights related to personal data and behavioral monitoring.

Is ConductAtlas affiliated with Cohere?

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