The policy states that user-submitted prompts and generated images may be used by Leonardo AI to train and improve its AI models, with an opt-out available by contacting the company's privacy team.
This analysis describes what Leonardo AI'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 establishes a default-on data practice in which user-submitted creative prompts and generated outputs are authorized for use in AI model training; the opt-out mechanism places the procedural burden on users to contact the company rather than providing an in-platform toggle.
Interpretive note: The exact wording of the opt-out mechanism and the lawful basis asserted for AI training use under GDPR are not fully detailed in the publicly available policy text, creating interpretive uncertainty regarding GDPR compliance.
Provision was expanded with explicit opt-out mechanism and severity escalated from medium to high, with excerpt now provided detailing the specific use of prompts and generated images.
View full change record →Under this clause, prompts and generated images submitted by users are authorized for AI model training by default. Users who do not contact privacy@leonardo.ai to opt out will have their content used for this purpose as stated in the terms.
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"We may use the content you generate, upload, or submit through our Services, including prompts and generated images, to train, improve, and develop our AI models and Services. If you do not want your content used for this purpose, you may opt out by contacting us at privacy@leonardo.ai.— Excerpt from Leonardo AI's Leonardo AI Privacy Policy
REGULATORY LANDSCAPE: This provision implicates GDPR Article 6 (lawful basis for processing) and Article 13/14 (transparency obligations) for EU/EEA users, as the use of personal data embedded in prompts for model training requires a clearly stated and legally sufficient basis. Where prompts contain special category data, GDPR Article 9 applies. The Australian Privacy Act 1988 (APP 3 and APP 6) governs collection and secondary use for Australian users. The EU AI Act may impose additional transparency and documentation obligations for generative AI systems trained on user data. Enforcement authorities include EU national data protection authorities and the Australian Information Commissioner. GOVERNANCE EXPOSURE: High. The default-on model training use of user-submitted content, with opt-out only by email contact, may not satisfy GDPR's requirement for a lawful basis where consent is the asserted ground, as consent must be freely given, specific, informed, and unambiguous. If legitimate interests is the asserted basis, a documented balancing test is required. JURISDICTION FLAGS: EU/EEA users face the highest exposure given GDPR's requirements for lawful basis and data subject rights. California residents may have rights under CPRA regarding the sharing or use of personal information for cross-context behavioral purposes. Australian users are subject to APP 6 secondary use limitations. CONTRACT AND VENDOR IMPLICATIONS: Organizations deploying Leonardo AI for commercial workflows should assess whether employee or client data embedded in prompts is subject to this training use provision, and whether their own data processing agreements permit such downstream use. COMPLIANCE CONSIDERATIONS: Legal teams should verify the lawful basis documented for AI training use, assess whether the opt-out mechanism is operationally accessible and prominently disclosed, and determine whether data subject rights requests (including deletion of training data) can be fulfilled. A data mapping update to capture prompt data flows into model training pipelines is advisable.
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This provision establishes a default-on data practice in which user-submitted creative prompts and generated outputs are authorized for use in AI model training; the opt-out mechanism places the procedural burden on users to contact the company rather than providing an in-platform toggle.
Under this clause, prompts and generated images submitted by users are authorized for AI model training by default. Users who do not contact privacy@leonardo.ai to opt out will have their content used for this purpose as stated in the terms.
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