The policy states the platform is not directed to users under 13 and that the company does not knowingly collect personal data from children under 13, with a parental contact mechanism for reported violations.
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 Leonardo AI's stated COPPA compliance posture; the policy does not describe the technical or operational mechanism by which users under 13 are identified and excluded from the platform.
Interpretive note: The policy does not describe the operational mechanism for enforcing the under-13 restriction, making it uncertain whether the stated policy satisfies COPPA's operational compliance requirements.
Under this clause, users under 13 are stated to be excluded from the service and their data is stated not to be knowingly collected. Parents or guardians who believe a child's data has been collected may contact privacy@leonardo.ai to request deletion.
How other platforms handle this
The Service is intended for general audiences and is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe that your child under the age of 13 has provided us with personal information without your cons...
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...
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"Our Services are not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe we have collected information from your child, please contact us at privacy@leonardo.ai.— Excerpt from Leonardo AI's Leonardo AI Privacy Policy
REGULATORY LANDSCAPE: This provision directly engages COPPA (Children's Online Privacy Protection Act), which applies to operators of services directed to children under 13 or that have actual knowledge of collecting data from children under 13. The FTC is the primary enforcement authority for COPPA. For EU users, GDPR Article 8 establishes age-based consent requirements (typically 16, with member state opt-down to 13). The Australian Privacy Act and Online Safety Act may also be relevant. GOVERNANCE EXPOSURE: Medium. The policy asserts a no-collection policy for under-13s but does not describe the age verification or operational enforcement mechanism, which is a standard area of FTC scrutiny in COPPA enforcement actions. JURISDICTION FLAGS: US-based operations face FTC COPPA enforcement risk. EU member states have varying age thresholds under GDPR Article 8. The UK Age Appropriate Design Code (Children's Code) may apply if the service is accessible to UK minors. CONTRACT AND VENDOR IMPLICATIONS: Platforms integrating Leonardo AI's API should assess whether their user base may include minors and whether downstream COPPA obligations apply to their use of the service. COMPLIANCE CONSIDERATIONS: Legal teams should review whether the age restriction is operationally enforced through account registration controls, assess whether any data collected prior to knowledge of a user's age is promptly deleted upon discovery, and confirm that the parental notification and deletion workflow is operational.
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This provision establishes Leonardo AI's stated COPPA compliance posture; the policy does not describe the technical or operational mechanism by which users under 13 are identified and excluded from the platform.
Under this clause, users under 13 are stated to be excluded from the service and their data is stated not to be knowingly collected. Parents or guardians who believe a child's data has been collected may contact privacy@leonardo.ai to request deletion.
ConductAtlas has identified this type of provision across 6 platforms. See the full comparison.
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