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The policy prohibits using Cohere services for illegal profiling or surveillance, untargeted facial image scraping for facial recognition databases, and predictive policing applications that assess or predict the likelihood of a person committing a criminal offense.
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
This provision explicitly prohibits biometric data aggregation and predictive criminal risk scoring, both of which are subject to heightened regulatory scrutiny under the EU AI Act and applicable privacy laws in multiple jurisdictions. The restriction on untargeted facial image scraping addresses a specific technical practice associated with mass biometric surveillance.
Interpretive note: The policy's use of 'illegal' as a qualifier for profiling and surveillance means that the scope of this prohibition depends on applicable law in each jurisdiction, which varies significantly across geographies.
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 →Under this clause, Cohere services may not be used to build or expand facial recognition databases through untargeted image scraping, conduct predictive policing, or engage in illegal surveillance or profiling activities. This prohibition applies to all users and Customer Application operators.
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"Surveillance and Predictive Policing. Any activities involving illegal profiling or surveillance, including spyware or communications surveillance, untargeted scraping of facial images to create or expand a facial recognition database, or predictive policing, i.e., assessing or predicting the risks of a person committing a criminal offence.Excerpt from Cohere's Usage Policy
1) REGULATORY LANDSCAPE: The prohibition on untargeted facial image scraping and predictive policing directly engages the EU AI Act, which classifies real-time remote biometric identification systems and AI systems used for criminal risk assessment as prohibited or high-risk practices. GDPR provisions on biometric data as a special category of personal data are also relevant. In the US, Illinois BIPA and similar state biometric privacy laws apply to facial recognition data collection. The FTC has taken enforcement actions related to biometric data misuse under the FTC Act. 2) GOVERNANCE EXPOSURE: High. The specific enumeration of untargeted facial image scraping and predictive policing reflects areas of active regulatory enforcement globally. Organizations deploying Cohere in law enforcement, security, or public safety contexts should assess their specific use case against these prohibitions. 3) JURISDICTION FLAGS: EU and EEA deployments face the most significant exposure given the EU AI Act's explicit prohibition on mass biometric surveillance and criminal risk assessment AI. Illinois BIPA creates heightened exposure for any biometric data processing involving Illinois residents. California CCPA/CPRA's treatment of biometric data as sensitive personal information is also relevant for US deployments. 4) CONTRACT AND VENDOR IMPLICATIONS: Procurement teams in public sector, security, and law enforcement contexts should evaluate whether their intended use cases fall within these prohibitions before contracting for Cohere services. The policy's qualifier 'illegal' before 'profiling or surveillance' means that some surveillance activities permissible under applicable law may not be prohibited by this clause, though other provisions in the policy may apply. 5) COMPLIANCE CONSIDERATIONS: Legal teams should note that the prohibition on predictive policing applies regardless of the technical accuracy or claimed utility of the system. Organizations using Cohere for any form of criminal justice or law enforcement application should obtain specific legal review of whether their use case falls within this prohibition, particularly given the broad definition of predictive policing provided in the policy.
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This provision explicitly prohibits biometric data aggregation and predictive criminal risk scoring, both of which are subject to heightened regulatory scrutiny under the EU AI Act and applicable privacy laws in multiple jurisdictions. The restriction on untargeted facial image scraping addresses a specific technical practice associated with mass biometric surveillance.
Under this clause, Cohere services may not be used to build or expand facial recognition databases through untargeted image scraping, conduct predictive policing, or engage in illegal surveillance or profiling activities. This prohibition applies to all users and Customer Application operators.
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