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Compromising Privacy or Identity Prohibition

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Document Record

What it is

The policy prohibits using Cohere services for unlawful location tracking, social scoring, real-time biometric identification, emotion inference from biometric data, inference of protected characteristics such as race or political opinions from biometric data, or other unauthorized access to personal information.

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 provision specifically enumerates real-time biometric identification and emotion inference from biometric data as prohibited uses, both of which are classified as prohibited or high-risk practices under the EU AI Act. The reference to 'applicable privacy regulations' incorporates compliance obligations under GDPR, CCPA, and other applicable privacy frameworks by reference.

Interpretive note: The scope of prohibited activities under this provision depends on 'applicable privacy regulations,' which vary significantly by jurisdiction and require independent legal assessment for each deployment context.

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.

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Consumer impact (what this means for users)

Under this clause, Cohere services may not be used to infer emotions, race, political opinions, or other protected characteristics from biometric data, or to conduct real-time identification of individuals. The prohibition on social scoring covers automated systems that assign scores to individuals based on their behavior or characteristics.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
Compromising Privacy or Identity. Violation of a person's privacy rights or applicable privacy regulations, including unlawful access to or tracking of a person's physical location; unlawful social scoring; real-time identification of a person or inference of emotions or protected characteristics of a person such as race or political opinions based on biometric data (including facial recognition); or other unauthorized access to personal information.

Excerpt from Cohere's Usage Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: The prohibition on real-time biometric identification and emotion inference from biometric data directly engages the EU AI Act's list of prohibited AI practices, which includes real-time remote biometric identification in public spaces and AI systems that infer emotions or political opinions from biometric data. GDPR Articles on special categories of personal data require explicit consent or another legal basis for biometric data processing. CCPA/CPRA classifies biometric data as sensitive personal information with specific opt-out rights. The FTC has signaled enforcement interest in emotion recognition and biometric inference technologies. 2) GOVERNANCE EXPOSURE: High. The specific enumeration of emotion inference and protected characteristic inference from biometric data reflects practices that are subject to active regulatory prohibition in the EU and increasing scrutiny in the US. The reference to 'applicable privacy regulations' means that the scope of this prohibition expands to incorporate all privacy obligations applicable to a given user's jurisdiction. 3) JURISDICTION FLAGS: EU and EEA deployments face the highest exposure, as emotion recognition and real-time biometric identification from public-space data are explicitly prohibited under the EU AI Act for most use cases. Illinois BIPA applies to biometric identifiers and information collected from Illinois residents. The policy's reference to social scoring may engage specific provisions in jurisdictions that have enacted or proposed social credit restrictions. 4) CONTRACT AND VENDOR IMPLICATIONS: Developers building applications involving any biometric data processing should assess whether their intended use case falls within the prohibited categories enumerated in this provision. The policy's incorporation of 'applicable privacy regulations' by reference means that compliance obligations vary by jurisdiction and require independent legal assessment. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should inventory any Cohere deployment use cases that involve biometric data inputs, including facial images, voice data, or other biometric identifiers, and assess whether the intended outputs would constitute real-time identification, emotion inference, or protected characteristic inference under applicable law. Data protection impact assessments may be required for biometric data processing in EU jurisdictions.

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Applicable agencies

  • FTC
    The FTC has enforcement authority over biometric data practices and privacy violations affecting consumers that fall within the scope of this provision.
    File a complaint →
  • State AG
    State attorneys general in jurisdictions with biometric privacy laws such as Illinois BIPA and California CCPA/CPRA have enforcement authority over biometric data processing practices covered by this provision.
    File a complaint →

Provision details

Document information
Document
Cohere Usage Policy
Entity
Cohere
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-015306
Document ID
CA-D-00442
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
d54fb0cb544115e31c8ba69f43a76f050bb92af77f6bf7bc14f2f17bca76e972
Analysis generated
July 9, 2026 07:41 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Cohere
Document: Cohere Usage Policy
Record ID: CA-P-015306
Captured: 2026-07-09 07:41:41 UTC
SHA-256: d54fb0cb544115e3…
URL: https://conductatlas.com/platform/cohere/cohere-usage-policy/provision/CA-P-015306/compromising-privacy-or-identity-prohibition/
Accessed: July 23, 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 Compromising Privacy or Identity Prohibition clause do?

This provision specifically enumerates real-time biometric identification and emotion inference from biometric data as prohibited uses, both of which are classified as prohibited or high-risk practices under the EU AI Act. The reference to 'applicable privacy regulations' incorporates compliance obligations under GDPR, CCPA, and other applicable privacy frameworks by reference.

How does this clause affect you?

Under this clause, Cohere services may not be used to infer emotions, race, political opinions, or other protected characteristics from biometric data, or to conduct real-time identification of individuals. The prohibition on social scoring covers automated systems that assign scores to individuals based on their behavior or characteristics.

Is ConductAtlas affiliated with Cohere?

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