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

Cross-Border Personal Data Transfers

Medium severity Medium confidence Explicit document language Common · 289 of 352 platforms
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Document Record

What it is

The policy states that personal data may be transferred to countries outside Australia and the EEA, and that the company states it uses mechanisms such as Standard Contractual Clauses for EEA transfers.

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 authorizes international transfers of user personal data and asserts that transfer safeguards such as Standard Contractual Clauses are in place, but does not identify specific recipient countries or named third-party recipients for these transfers.

Interpretive note: The policy asserts SCC use but does not identify specific recipient countries or document transfer impact assessment procedures, leaving the completeness of the transfer framework uncertain.

Consumer impact (what this means for users)

Under this clause, personal data including identifiers, usage activity, and payment information may be transferred to and processed in countries outside Australia and the EEA. The policy states that safeguards such as SCCs are applied for EEA transfers, but does not specify recipient jurisdictions.

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.

Square Medium

to request that your data be transferred to a third party (data portability)

Google Cloud Medium

Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
We may transfer your personal information to countries outside of Australia and the European Economic Area. When we transfer personal information outside of the EEA, we ensure appropriate safeguards are in place, such as standard contractual clauses approved by the European Commission.

Excerpt from Leonardo AI's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

REGULATORY LANDSCAPE: This provision directly engages GDPR Chapter V (restrictions on transfers to third countries), which requires an adequacy decision, SCCs, or other approved transfer mechanism for transfers from the EEA.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

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-012583
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-012583
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-012583/cross-border-personal-data-transfers/
Accessed: Sept. 12, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Leonardo AI's Cross-Border Personal Data Transfers clause do?

This provision authorizes international transfers of user personal data and asserts that transfer safeguards such as Standard Contractual Clauses are in place, but does not identify specific recipient countries or named third-party recipients for these transfers.

How does this clause affect you?

Under this clause, personal data including identifiers, usage activity, and payment information may be transferred to and processed in countries outside Australia and the EEA. The policy states that safeguards such as SCCs are applied for EEA transfers, but does not specify recipient jurisdictions.

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.