The agreement grants Leonardo AI a worldwide, royalty-free, sublicensable license to use, reproduce, modify, distribute, and publish content users submit or generate through the platform across any current or future media, including for service promotion and syndication to third parties.
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 a broad license that covers both user-uploaded content and AI-generated outputs, and extends to sublicensing to third parties for syndication, distribution, and promotional purposes. The scope of permitted uses, including AI model improvement, engages data protection and intellectual property considerations across multiple jurisdictions.
Interpretive note: The precise scope of AI training uses and third-party syndication rights is not exhaustively defined in the provision; the extent of sublicensing to unspecified third parties introduces operational ambiguity.
Under this clause, content submitted to or generated on the Leonardo AI platform is subject to a worldwide license that permits Leonardo AI to reproduce, modify, distribute, and sublicense that content to third parties for promotional and syndication purposes. The agreement does not specify a documented opt-out mechanism for AI training uses of submitted content.
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"By submitting, posting, or displaying Content on or through the Services, you grant us a worldwide, non-exclusive, royalty-free license (with the right to sublicense) to use, copy, reproduce, process, adapt, modify, publish, transmit, display and distribute such Content in any and all media or distribution methods now known or later developed. You agree that this license includes the right for Leonardo AI to provide, promote, and improve the Services and to make Content submitted to or through the Services available to other companies, organizations or individuals for the syndication, broadcast, distribution, promotion or publication of such Content on other media and services.— Excerpt from Leonardo AI's Leonardo AI Terms of Service
(1) REGULATORY LANDSCAPE: This provision implicates GDPR where user-submitted content contains personal data, requiring a lawful basis for processing under GDPR Article 6 and potentially Article 9 for special category data. The Australian Privacy Act applies as the governing data protection framework for the entity. The FTC Act may be relevant if the scope of use is not adequately disclosed at point of collection. Relevant enforcement authorities include EU data protection authorities, the OAIC, and the FTC. (2) GOVERNANCE EXPOSURE: High. The license asserts rights to use submitted and generated content for AI model improvement and third-party syndication without a documented opt-out pathway. Where user content contains personal data, the absence of a clear lawful basis disclosure for AI training use creates GDPR exposure. The sublicensing right to third parties for distribution and promotion warrants review of downstream data sharing obligations. (3) JURISDICTION FLAGS: EU/EEA users face heightened exposure given GDPR's requirements for specific, informed consent or an alternative documented lawful basis for processing personal data embedded in content. California users should assess whether CCPA rights to opt out of data sharing apply to content licensing arrangements. Australian users are subject to the Privacy Act 1988. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise procurement teams should assess whether a Data Processing Agreement (DPA) or data processing addendum is available to supplement these terms, as the ToS alone may be insufficient for GDPR-compliant processing. The sublicensing right to unspecified third parties warrants identification of downstream vendors or partners in due diligence. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should conduct a data mapping exercise to identify whether user-submitted content constitutes personal data under applicable frameworks, and evaluate whether the consent mechanism at account creation adequately covers AI training uses. If the platform is used in an enterprise context, a DPA should be requested and the third-party sublicensing chain should be documented.
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This provision establishes a broad license that covers both user-uploaded content and AI-generated outputs, and extends to sublicensing to third parties for syndication, distribution, and promotional purposes. The scope of permitted uses, including AI model improvement, engages data protection and intellectual property considerations across multiple jurisdictions.
Under this clause, content submitted to or generated on the Leonardo AI platform is subject to a worldwide license that permits Leonardo AI to reproduce, modify, distribute, and sublicense that content to third parties for promotional and syndication purposes. The agreement does not specify a documented opt-out mechanism for AI training uses of submitted content.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Leonardo AI.