The policy authorizes sharing of personal data with advertising, analytics, and operational service providers, stating that these parties access data only for specified purposes on Leonardo AI's behalf.
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 data sharing with advertising and analytics partners, categories that under CCPA/CPRA may constitute sharing personal information for cross-context behavioral advertising, triggering opt-out rights for California residents.
Interpretive note: The policy does not enumerate specific advertising or analytics partners or categorize the data shared with each, creating uncertainty about whether the disclosure is sufficient under GDPR Article 13 or CCPA transparency requirements.
Provision was renamed to include specific mention of 'Advertising and Analytics Partners' and now includes detailed excerpt specifying the scope and limitations of third-party access.
View full change record →Under this clause, personal data such as identifiers, usage activity, and device information may be shared with advertising and analytics partners. California residents may have the right to opt out of this sharing under CCPA/CPRA by contacting Leonardo AI.
How other platforms handle this
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...
We may display advertisements on our Services and those advertisements may be targeted to your interests based on your personal information. We may share your personal information with advertising partners for interest-based advertising purposes. You may opt out of interest-based advertising by visi...
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"We may share your personal information with third-party service providers, advertising partners, and analytics providers who assist us in operating our Services, conducting our business, and serving you. These third parties may have access to your personal information only to perform these tasks on our behalf.— Excerpt from Leonardo AI's Leonardo AI Privacy Policy
REGULATORY LANDSCAPE: Sharing personal data with advertising partners may constitute sharing personal information for cross-context behavioral advertising under CCPA/CPRA, which grants California residents the right to opt out. Under GDPR, sharing with advertising partners requires a lawful basis and, where based on legitimate interests, a documented balancing test. The FTC Act applies to the adequacy of disclosures about third-party data sharing practices. Enforcement authorities include the California Privacy Protection Agency and the FTC. GOVERNANCE EXPOSURE: Medium. The policy discloses third-party advertising and analytics sharing but does not enumerate specific named partners or provide a detailed list of data categories shared with each partner type, which may affect the adequacy of GDPR Article 13/14 disclosures and CCPA transparency obligations. JURISDICTION FLAGS: California residents have heightened rights under CCPA/CPRA regarding sharing with advertising partners. EU/EEA users have rights under GDPR to object to processing for advertising purposes. CONTRACT AND VENDOR IMPLICATIONS: Vendor management teams should verify that data processing agreements are in place with all advertising and analytics partners, and that those agreements restrict onward sharing and specify data retention limits. COMPLIANCE CONSIDERATIONS: Legal teams should audit the list of advertising and analytics vendors, confirm DPAs are executed, assess whether the sharing constitutes a sale under CCPA/CPRA, and ensure opt-out mechanisms are operationally available and disclosed in the policy.
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This provision establishes data sharing with advertising and analytics partners, categories that under CCPA/CPRA may constitute sharing personal information for cross-context behavioral advertising, triggering opt-out rights for California residents.
Under this clause, personal data such as identifiers, usage activity, and device information may be shared with advertising and analytics partners. California residents may have the right to opt out of this sharing under CCPA/CPRA by contacting Leonardo AI.
ConductAtlas has identified this type of provision across 7 platforms. See the full comparison.
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