Cohere

Data use, retention, sub-processor disclosure, jurisdiction-specific rights, tracking, and support-ticket processing changed; six changes are reported.

• Inputs and outputs from free-trial and research-platform users are now collected and used for research and model improvement; the data is de-identified before this use. (Section 2.3, Research and Model Improvement.)
• A fixed retention period is introduced for Enterprise Users' Platform inputs and outputs: generally 30 days. The previous version stated no fixed retention period for this data. (Section 4, Safeguards, Retention, and Privacy Governance.)
• A new EEA/UK/Switzerland addendum is added, setting out GDPR legal bases for each processing purpose, additional rights (restriction, objection, portability, complaint), a one-month response target with three months for complex requests, and transfer mechanisms. (Section 10.2, Additional Information for European Residents.)
• The policy now points Platform and Cohere API users to a consultable list of sub-processors, including data processing locations. No such list was referenced before. (Sections 3 and 10.2.)
• Fullstory is added as an analytics provider that captures mouse movements, clicks, scrolling, and typing on the Website or Platform. Google Analytics was previously the only analytics provider named. (Section 9, Cookies and Interest-Based Advertising.)
• Support-ticket contents may now be analyzed by Cohere's own AI technology or third-party AI tools to summarize inquiries and draft responses. The previous version described using support information only to answer inquiries and improve customer service. (Section 2.7, Customer Support.)

Nine further changes remove the surveys collection item, add third-party marketing data enrichment, add Cohere Labs program data collection, broaden advertising-cookie targeting to business-prospect identification, add a CCPA statement that Cohere does not sell personal information for monetary compensation, state that private and third-party managed deployments are never used to train models, add international-transfer mechanisms to the main policy, replace the stated objection right in the general rights list with an objection right confined to the EEA addendum, and update the policy date.