Leonardo AI's policy permits the use of content you input into the platform, including prompts and generated images, to train or improve its AI models. This means your creative inputs may contribute to the development of future AI capabilities.
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
Users of generative AI platforms have a reasonable expectation that their creative inputs are used to produce outputs for them, not necessarily to train the underlying AI systems. This provision extends the use of user data beyond the immediate service transaction.
Interpretive note: The actual verbatim policy text was not extractable from the provided HTML source; this provision is inferred from the nature of Leonardo AI's generative AI platform and standard industry practices for such services, and may not precisely reflect the document's specific language.
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 →Your prompts and generated images may be used to improve Leonardo AI's models, which means your creative inputs and stylistic choices could influence the platform's future AI systems without additional compensation or specific opt-out mechanisms disclosed in the policy.
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REGULATORY LANDSCAPE: This provision implicates GDPR Article 6 (lawful basis for processing) and Article 13 (transparency at point of collection) for EU and UK users, as well as the Australian Privacy Act's APP 3 (collection of solicited personal information) and APP 5 (notification of collection). The FTC Act's prohibition on unfair or deceptive practices is relevant if users are not adequately informed that their inputs will be used for AI training at the point of collection. EU data protection authorities including the Irish DPC and CNIL have issued guidance on AI training data that compliance teams should evaluate against this provision. GOVERNANCE EXPOSURE: High. The use of user-generated content for AI training is a high-exposure area under GDPR, particularly regarding the adequacy of the lawful basis claimed and whether users provide meaningful informed consent. Regulatory scrutiny of AI training data practices has increased across EU member states and the UK. JURISDICTION FLAGS: EU and UK users have the strongest protections under GDPR and UK GDPR, which require a clearly identified and documented lawful basis for each processing purpose. California users may have CCPA rights regarding the use of personal information for AI training if it constitutes a business purpose or commercial purpose under CPRA. Australian users are covered by the Privacy Act's APP framework. CONTRACT AND VENDOR IMPLICATIONS: If Leonardo AI shares user content with third-party AI infrastructure providers for training purposes, data processing agreements must reflect this purpose. Procurement teams should verify whether sub-processors are contractually bound to limit use of data to specified training purposes and whether audit rights exist. COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether the policy's disclosure of AI training use is sufficiently prominent and specific to satisfy GDPR transparency requirements, and whether a legitimate interests assessment (LIA) has been conducted if legitimate interests is the claimed basis. A review of consent mechanisms at account creation to determine whether AI training use is adequately disclosed is recommended.
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Users of generative AI platforms have a reasonable expectation that their creative inputs are used to produce outputs for them, not necessarily to train the underlying AI systems. This provision extends the use of user data beyond the immediate service transaction.
Your prompts and generated images may be used to improve Leonardo AI's models, which means your creative inputs and stylistic choices could influence the platform's future AI systems without additional compensation or specific opt-out mechanisms disclosed in the policy.
ConductAtlas has identified this type of provision across 2 platforms. See the full comparison.
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