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

Leonardo Acts as Processor for Commercial Customers

Medium severity Explicit document language Common · 279 of 352 platforms
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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

Clause Stability Stable

0
Changes
3
Months Monitored
Jul 10, 2026
First Seen
Jul 10, 2026
Last Seen
This clause type exists across 3333 other provisions on other platforms.

How other platforms handle this

ZipRecruiter Medium

In certain instances, our clients hire ZipRecruiter to provide services on behalf of the client. In such case, we process Personal Data under the direction of that client (the data controller) and have no direct relationship with the individuals...

Microsoft Medium

We do not use what you say in email, chat, video calls or voice mail, or your documents, photos or other personal files, to target advertising to you.

MyFitnessPal Medium

We use your personal information to send you newsletters and other promotional communications, including information about MyFitnessPal's new offerings, features, offers, events, webinars, and other information.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
In certain circumstances, we process personal data as a processor on behalf of our commercial customers... it is our customer that is responsible for the processing of your personal data

Excerpt from Leonardo AI's Privacy Policy

Applicable regulations

EU AI Act
European Union
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
ePrivacy Directive
European Union
EU AI Act - High Risk Provisions
EU
FTC Act Section 5
United States Federal
GDPR
European Union

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-044474
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-044474
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-044474/leonardo-acts-as-processor-for-commercial-customers/
Accessed: July 30, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Leonardo AI's Leonardo Acts as Processor for Commercial Customers clause do?

The clause states: “In certain circumstances, we process personal data as a processor on behalf of our commercial customers... it is our customer that is responsible for the processing of your personal data”

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 279 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.