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Cohere Inc | Trust Center Cohere Trust Center Cohere prioritizes your data's confidentiality, integrity, and availability. Our Trust Center offers insights into our data management, security measures, and compliance. See Certifications Compliance SOC 2 Type 2 Service Organization Controls (SOC 2) (Type II) Trust Services Principles ISO 27001 Information Security Management System (ISMS) ISO 42001 Artificial Intelligence Management System (AIMS) U.K. Cyber Essentials U.K. Gov't-backed Cybersecurity Standard GDPR Protect the personal data and privacy of EU citizens for transactions that occur within EU member states CCPA California Consumer Privacy Act HIPAA Health Insurance Portability and Accountability Act (please see FAQ). Resources Get our latest security and compliance resources and reports SOC 2 Type II Cohere undergoes an annual SOC 2 Type II audit. Request here to see our report. ISO 27001 Certification Official Certificate ISO 42001 Certification Official Certificate U.K. Cyber Essentials Certificate for Cohere Inc. U.K. Cyber Essentials Certificate for Cohere UK, LTD Latest Penetration Test Report API Penetration Test Results Latest Penetration Test Report Web Application test results Responsible Disclosure Policy Rules of engagement for conducting and performing security research (i.e. vulnerability discovery) activities for participating in our Bug Bounty Program. Cohere Enterprise Data Commitments EU AI Act FAQs FAQs regarding the GPAI Code of Practice View all Subprocessors Google Cloud Infrastructure Service Provider Location: USA Fullstory Software Delivery Platform Location: USA LaunchDarkly Feature Flagging Location: USA New Relic Platform Monitoring Location: USA Retool Software Delivery Platform Location: USA Sentry IO Software Delivery Platform Location: USA Segment Event and Error Handling Location: USA Sendgrid Email Communications Location: USA Vercel Web Application Hosting Location: USA View all FAQs Can I request a copy of your SOC 2? Yes, you can request a copy above. Prior to receiving a copy of our SOC 2 Type 2 report, we will need a signed mNDA. How do we manage risk and compliance? Cohere maintains robust security practices to ensure that our customers' data are maintained to the highest degree. Is the company GDPR compliant? What steps have you taken to ensure this? As a service provider that operates in multiple jurisdictions, including Canada, the EU and the US, Cohere has designed its services with Privacy-by-Design in mind, and we have processes in place to assist our customers to comply with their obligations under applicable privacy laws, including the GDPR. In particular, we have a robust Information Security program designed to safeguard the information that our customers share with us, which, in certain circumstances, may contain personal information. In addition, we have implemented GDPR-specific compliance training through Secureframe and have prepared a multi-jurisdictional Data Processing Addendum designed to give our customers contractual assurances regarding Cohere’s handling of customer data on their behalf in compliance with applicable privacy laws, including the GPDR. Further, we rely on appropriate mechanisms for international data transfers as required by the GDPR. We also monitor guidance around GDPR compliance from privacy-related regulatory bodies and will update our product features and contractual commitments accordingly. Do you have a Data Processing Agreement? Yes, Cohere has a DPA. If you would like to receive a copy, we will need a signed NDA. Please contact [email protected] for more information. Where are your hosting centers located and do you have options to use centers outside of the US? Are there options to not send data to the US at all? Our hosting centers are on Google Cloud Platform servers located in US-Central. We do not use servers outside of the US; however, we can, in certain circumstances, configure our offering to ensure that no customer data is stored on Cohere’s systems. When the Cohere offering is configured in this way, the customer data is considered “ephemeral”, as it transits through Cohere’s systems only briefly for the purposes of providing the services and is purged immediately after processing. There are drawbacks to this approach as it limits some features and Cohere’s ability to improve the user experience and/or address certain issues efficiently by reviewing customer data. What has been your response to the Schrems II ruling and have you conducted a transfer impact assessment? Following the Schrems II ruling, companies transferring EU personal data to non-EU countries that have not been deemed adequate by the relevant governmental body, such as the US, must conduct assessments to identify any necessary supplemental measures to protect the personal data being transferred. Cohere has conducted, with the assistance of EU counsel, a Transfer Impact Assessment (TIA) that assesses the impact and security considerations in connection with transfers of customer data originating in the EU (and that is subject to the GDPR) to the US for processing. The TIA details the “relevant contractual, technical or organisational safeguards” Cohere has in place to supplement protections under the Standard Contractual Clauses where necessary. These safeguards include encryption at rest and in transit, administrative access control, system monitoring, logging and alerting and more. Based on the Transfer Impact Assessment, Cohere considers that the transfer of customer data to the US is, taking account of all the circumstances of the transfer, compatible with the GDPR read in light of the Charter of Fundamental Rights of the EU. In addition, our multi-jurisdictional Data Processing Addendum (DPA) contains the following commitments, among others: 1. Standard Contractual Clauses: The DPA incorporates the Standard Contractual Clauses, approved by the European Commission on 4 June 2021, allowing customers to apply the protections in the Standard Contractual Clauses to personal data originating in the EU (and that is subject to the GDPR) to the US for processing. 2. Security: Cohere commits to implementing appropriate technical and organisational measures to protect customer data. A description of Cohere’s security measures are included in Annex B to the DPA. 3. Government Requests and Orders: Unless legally prohibited, Cohere commits to promptly notify customers of any communications received from a governmental agency requesting or purporting to compel the production of customer data that contains personal information so that the customer can work with the governmental agency directly to respond. Will Cohere sign a Business Associate Agreement under HIPAA (i.e. HIPAA Compliance)? After a review of the customers use case and internal HIPAA-related compliance checks, Cohere may execute a Business Associate Agreement (BAA) for custom model development engagements. Cohere's BAA only covers engagements where Cohere develops a custom model on behalf of a customer. It does not cover Cohere hosted products and applications such as Cohere's SaaS services. Enterprise customers should not submit Personal Health Information through the Cohere SaaS services. For more information, please contact your Account Executive or [email protected]. Monitoring Continuously monitored by Secureframe View all Monitoring Change Management Production Data Use is Restricted Production data is not used in the development and testing environments, unless required for debugging customer issues. Change Management Policy A Change Management Policy governs the documenting, tracking, testing, and approving of system, network, security, and infrastructure changes. Configuration and Asset Management Policy A Configuration and Asset Management Policy governs configurations for new sensitive systems Secure Development Policy A Secure Development Policy defines the requirements for secure software and system development and maintenance. Software Change Testing Software changes are tested prior to being deployed into production. Segregation of Environments Development, staging, and production environments are segregated. Availability Backup Restoration Testing Backed-up data is restored to a non-production environment at least annually to validate the integrity of backups. Automated Backup Process Full backups are performed and retained in accordance with the Business Continuity and Disaster Recovery Policy. Uptime and Availability Monitoring System tools monitors for uptime and availability based on predetermined criteria. Testing the Business Continuity and Disaster Recovery Plan The Business Continuity and Disaster Recovery Plan is periodically tested via tabletop exercises or equivalents. When necessary, Management makes changes to the Business Continuity and Disaster Recovery Plan based on the test results. Business Continuity and Disaster Recovery Policy Business Continuity and Disaster Recovery Policy governs required processes for restoring the service or supporting infrastructure after suffering a disaster or disruption. Organizational Management Acceptable Use Policy An Acceptable Use Policy defines standards for appropriate and secure use of company hardware and electronic systems including storage media, communication tools and internet access. Performance Review Policy A Performance Review Policy provides personnel context and transparency into their performance and career development processes. Internal Control Policy An Internal Control Policy identifies how a system of controls should be maintained to safeguard assets, promote operational efficiency, and encourage adherence to prescribed managerial policies. Organizational Chart Management maintains a formal organizational chart to clearly identify positions of authority and the lines of communication, and publishes the organizational chart to internal personnel. Independent Advisor The board of directors or equivalent entity function includes senior management and external advisors, who are independent from the company's operations. An information security team has also been established to govern cybersecurity. Roles and Responsibilities Information security roles and responsibilities are outlined for personnel responsible for the security, availability, and confidentiality of the system. Code of Conduct A Code of Conduct outlines ethical expectations, behavior standards, and ramifications of noncompliance. Information Security Policy An Information Security Policy establishes the security requirements for maintaining the security, confidentiality, integrity, and availability of applications, systems, infrastructure, and data. Advisor Meetings on Security Senior management and/or board of directors meets at least annually to review business goals, company initiatives, resource needs, risk management activities, and other internal/external matters. The information security team meets at least annually to discuss security risks, roles & responsibilities, controls, changes, audit results and/or other matters as necessary. Disciplinary Action Personnel who violate information security policies are subject to disciplinary action and such disciplinary action is clearly documented in one or more policies. Cybersecurity Insurance Cybersecurity insurance has been procured to help minimize the financial impact of cybersecurity loss events. Confidentiality Data Classification Policy A Data Classification Policy details the security and handling protocols for sensitive data. Data Retention and Disposal Policy A Data Retention and Disposal Policy specifies how customer data is to be retained and disposed of based on compliance requirements and contractual obligations. Disposal of Customer Data Upon customer request, Company requires that data that is no longer needed from databases and other file stores is removed in accordance with agreed-upon customer requirements. Vulnerability Management Vulnerability and Patch Management Policy A Vulnerability Management and Patch Management Policy outlines the processes to efficiently respond to identified vulnerabilities. Third-Party Penetration Test A 3rd party is engaged to conduct a network and application penetration test of the production environment at least annually. Critical and high-risk findings are tracked through resolution. Incident Response Incident Response Plan Testing The Incident Response Plan is periodically tested via tabletop exercises or equivalents. When necessary, Management makes changes to the Incident Response Plan based on the test results. Incident Response Plan An Incident Response Plan outlines the process of identifying, prioritizing, communicating, assigning and tracking confirmed incidents through to resolution. Risk Assessment Risk Assessment Formal risk assessments are performed, which includes the identification of relevant internal and external threats related to security, availability, confidentiality, and fraud, and an analysis of risks associated with those threats. Vendor Risk Management Policy A Vendor Risk Management Policy defines a framework for the onboarding and management of the vendor relationship lifecycle. Vendor Due Diligence Review Vendor SOC 2 reports (or equivalent) are collected and reviewed on at least an annual basis. Risk Assessment and Treatment Policy A Risk Assessment and Treatment Policy governs the process for conducting risk assessments to account for threats, vulnerabilities, likelihood, and impact with respect to assets, team members, customers, vendors, suppliers, and partners. Risk tolerance and strategies are also defined in the policy. Network Security Automated Alerting for Security Events Alerting software is used to notify impacted teams of potential security events. Network Security Policy A Network Security Policy identifies the requirements for protecting information and systems within and across networks. Access Security Unique Access IDs Personnel are assigned unique IDs to access sensitive systems, networks, and information Access Control and Termination Policy An Access Control and Termination Policy governs authentication and access to applicable systems, data, and networks. Encryption-in-Transit Service data transmitted over the internet is encrypted-in-transit. Removal of Access Upon termination or when internal personnel no longer require access, system access is removed, as applicable. Encryption and Key Management Policy An Encryption and Key Management Policy supports the secure encryption and decryption of app secrets, and governs the use of cryptographic controls. Asset Inventory A list of system assets, components, and respective owners are maintained and reviewed at least annually Physical Security Physical Security Policy A Physical Security Policy that details physical security requirements for the company facilities is in place. Communications Terms of Service Terms of Service or the equivalent are published or shared to external users. Description of Services Descriptions of the company's services and systems are available to both internal personnel and external users. Communication of Security Commitments Security commitments and expectations are communicated to both internal personnel and external users via the company's website. Communication of Critical Information Critical information is communicated to external parties, as applicable. Privacy Policy A Privacy Policy to both external users and internal personnel. This policy details the company's privacy commitments. Confidential Reporting Channel A confidential reporting channel is made available to internal personnel and external parties to report security and other identified concerns.