Provision record
Leonardo AI · Leonardo AI Privacy Policy · View original document ↗

AI Model Training Use of User Content and Prompts

High severity Medium confidence Explicitdocumentlanguage Common · 289 of 352 platforms
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Document Record

What it is

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

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.

Clause Stability Stable

0
Changes
3
Months Monitored
May 20, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 5149 other provisions on other platforms.

Change history

modified Jun 2, 2026

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 →

Consumer impact (what this means for users)

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.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Email privacy@leonardo.ai to request that your content not be used for AI model training. State your account details and the specific opt-out request clearly.

How other platforms handle this

Tinder Medium

If you choose to reveal any personal information about yourself to other users, you do so at your own risk. We strongly encourage you to use caution in disclosing any personal information online.

Skillshare Medium

When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide some of our Services, you may not be able to use those Services.

Square Medium

You may contact our privacy team with any requests of disclosure, correction, or deletion of your personal information. You may also request suspension of use or suspension of sharing of your personal information with certain third parties.

See all platforms with this clause type →

Monitoring

Leonardo AI has changed this document before.

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▸ View Original Clause Language DOCUMENT RECORD
"
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 Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

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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Full institutional analysis

Regulatory citations, enforcement risk, and due diligence action items.

Applicable agencies

  • FTC
    The FTC has jurisdiction over unfair or deceptive data practices involving consumer data used for AI training, including the adequacy of opt-out disclosures
    File a complaint →

Applicable regulations

EU AI Act
European Union
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
EU AI Act - High Risk Provisions
EU
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Leonardo AI Privacy Policy
Entity
Leonardo AI
Document last updated
May 5, 2026
Tracking information
First tracked
May 20, 2026
Last verified
May 20, 2026
Record ID
CA-P-012582
Document ID
CA-D-00480
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
0ba9b7d269b5cd0431aa2c34babd080d0a40f42bd0ba3161212af22698b0b17f
Analysis generated
May 20, 2026 23:09 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Leonardo AI
Document: Leonardo AI Privacy Policy
Record ID: CA-P-012582
Captured: 2026-05-20 23:09:47 UTC
SHA-256: 0ba9b7d269b5cd04…
URL: https://conductatlas.com/platform/leonardo-ai/leonardo-ai-privacy-policy/provision/CA-P-012582/ai-model-training-use-of-user-content-and-prompts/
Accessed: July 28, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

Related Analysis

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Frequently Asked Questions

What does Leonardo AI's AI Model Training Use of User Content and Prompts clause do?

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.

How does this clause affect you?

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.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 289 platforms. See the full comparison.

Is ConductAtlas affiliated with Leonardo AI?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Leonardo AI.