“The Creator-First Generative AI Platform”
Leonardo.AI is a generative AI platform for image, video, design, and motion workflows.
Officially, the product is positioned for creating high-quality visuals from prompts or reference images, for precise editing, upscaling, as well as for API-powered production workflows. The platform also offers team collaboration and developer access via API.
Leonardo.AI
The Creator-First Generative AI Platform
Location: Australia ⓘ Suite 1007, 120 High St, North Sydney, NSW 2060, Australia
Subscription Premium For semi-professionals and active creators; includes more monthly Fast Tokens, a larger Token Bank, private generations, Enhanced Quality, unlimited collections, more personal AI models, higher parallelization, queue, top-up tokens, and unlimited Relaxed Image Generation for selected models.
Subscription Ultimate For professional creators, small businesses, and content producers; includes significantly more monthly Fast Tokens, a larger Token Bank, private generations, Enhanced Quality, many personal AI models, higher parallelization, a larger queue, top-up tokens, as well as unlimited Relaxed Image and Video Generation for selected models.
Subscription / Team Starter Team plan with Shared Tokens, Bank Capacity, Fast Tokens per seat, private team generations, team token usage for model training, unlimited collections, unlimited Realtime Canvas and Realtime Generation actions, Enhanced Quality, and team workflow features.
Subscription / Team Growth Advanced team plan with more Shared Tokens, higher Bank Capacity, more Fast Tokens per seat, private team generations, model training with Team Tokens, unlimited collections, unlimited Realtime actions, and Enhanced Quality. Other Custom Plan Individually tailored plan for larger workflows; includes custom Fast Tokens per seat, all Starter and Growth features, as well as bespoke requirements.
Pay as you go / API Usage-based API option with no long-term commitment, automatic top-ups, access to the latest models, and parallel generations.
API Custom For higher production volumes and long-term scaling; includes custom limits for parallel generations, model-based discounts, and dedicated support for production deployments.
Target audience
Leonardo.AI is officially aimed at creators, artists, designers, makers, founders, solo builders, and teams that produce visual content or want to automate production workflows. On its website, Leonardo lists marketing, graphic design, print on demand, photography, interior design, and architecture, among others, as relevant industries. Thanks to team and API offerings, the tool is interesting not only for individual users, but also for creative teams, start-ups, and product-focused development teams.
Outstanding features
Leonardo.AI is particularly strong where pure prompt generators are often weaker: in consistent style control, iterative visual work, and production readiness. These include Blueprints for preconfigured workflows, Flow State for rapid idea exploration, Realtime Canvas for sketch-based work in real time, Universal Upscaler for quality enhancement, as well as Elements and Custom Models for recognizable styles, characters, or products. For developers, Leonardo also stands out through a visual API approach in which workflows can be designed and then exported as production-ready code.
Key application areas
The most obvious use cases are campaign visuals, social assets, banners, concept graphics, product and brand visuals, mood boards, as well as short AI videos or animated content. Leonardo’s own pages explicitly mention Marketing Tools, Graphic Design, and the use cases Art Generator, Banner Generator, and Social Media Post Generator. Through upscaling, editing, and API integration, the platform is also suitable for recurring visual production processes where speed and consistency matter.
Usage & notes
For productive or sensitive use, the key note is: free content is public by default; if you do not want content to be publicly visible or used for model training, you should, according to the Privacy Policy, work in a paid plan with private generation. The platform operates on a token basis; paid plans include monthly token allowances, token banks, and top-ups, and higher-tier plans also offer “Relaxed Generation” for selected models. Rights to generated images also differ depending on the plan: paying users retain full ownership of their private generations, while in the free tier Leonardo retains extensive usage rights and content is publicly accessible.
| Target audience | Assessment |
|---|---|
| Private individuals | Suitable – for AI images, creative experiments, avatars, social media graphics, and simple image editing. |
| Creators / Designers / Artists | Highly suitable – especially for concept art, illustrations, product visuals, style variations, image ideas, and fast creative iterations. |
| Self-employed / Freelancers | Highly suitable – for marketing images, advertising motifs, social posts, mockups, product images, website graphics, and client drafts. |
| SMEs / Marketing teams | Suitable to highly suitable – for scalable visual content production, branding-related visual worlds, campaign motifs, and rapid asset creation. |
| Developers / Product teams | Suitable – thanks to API and pay-as-you-go options for integrating image and video AI into their own applications. |
| Large enterprises / regulated industries | Conditionally suitable – functionally strong, but due to US hosting, subprocessors, and training-related issues, only recommended with a data protection review. |
Hosting & Data
1) On-prem / local hosting
Meaning: The company operates the solution on its own hardware or within its own infrastructure. In the strictest sense, not only the application runs locally, but ideally the model as well.
2) Private cloud / data center
Meaning: The solution runs in a dedicated or more clearly separated cloud environment, often with a hosting provider or hyperscaler, but in a German data center or in a particularly controlled environment.
3) EU SaaS / managed
Meaning: The provider operates the solution itself as a service. The company uses the tool as a ready-made cloud service, ideally with EU data residency.
4) Hybrid
Meaning: One part of the processing remains internal / local / in a private cloud, while another part runs in an external cloud or EU SaaS.
5) AVV / DPA
Meaning: This is the data processing agreement or Data Processing Addendum. It governs that the provider processes personal data on behalf of the customer and is bound by the customer's instructions.
6) No training
Meaning: The provider does not use your prompts, uploads, attachments, chat histories, or outputs for training or improving the general model — ideally excluded by contract.
7) Open-source / transparency path
Meaning: There is a path toward greater technical transparency and sovereignty, for example through:
- open models
- documented components
- self-hostable parts
- traceable architecture
- export / switching options
| On-prem / local hosting | ❓ |
| Private cloud / data center | ❓ |
| EU SaaS / Managed | ⚠️ |
| Hybrid | ❓ |
| DPA / AVV | ✅ |
| No training on customer data | ❓ |
| Open source / transparency path | ❓ |
On-prem / local hosting: indirect / not available
The website describes Leonardo.Ai as a cloud-based platform. The website does not mention an on-premises, local, or self-hostable product variant.
Private cloud / data center: unclear
There are references to AWS hosting and a processing role for certain customer scenarios, but no clear statement regarding dedicated private cloud environments, isolated EU environments, or customer-specific data center options.
EU SaaS / Managed: Partially
This is a managed SaaS service. For Europe, there are data protection notices and an EEA representative, but no guaranteed EU/EEA data residency. Instead, the website mentions storage in the U.S. and processing in Australia as well as other countries.
Hybrid: unclear
The website does not specify a hybrid deployment with partial internal/on-premises processing and partial external processing.
T&Cs / DPA: Covered
A Data Processing Addendum is published on the website. It governs processing as a data processor, documented client instructions, SCCs, subprocessors, erasure/return, and support for data subject rights.
No training: indirect / not available
The privacy policy explicitly states that content and associated account data may be used to improve the service and to train algorithms, models, and AI products. A general opt-out option for this training is not specified on the website. Although paid users can mark content as private, there is no evidence on the website of a contractual general exclusion of training for all user-generated content.
Open Source / Transparency Path: Indirect / Not Available
The website does not specify an open-source, self-hosting, or transparency-oriented sovereignty path for Leonardo.Ai itself. Only individual subprocessors and contractual data protection documents are documented.
Data Processing
The website describes Leonardo.Ai as a cloud-based platform. The DPA names AWS as the hosting and infrastructure provider; according to the privacy policy, data is stored in the U.S. and processed in Australia and other countries. The DPA contains a list of subprocessors with providers in the U.S., Singapore, and Germany. For restricted transfers to third countries, SCCs and, additionally, the UK Addendum are cited. A mandatory EU/EEA data residency requirement or exclusively European hosting is not specified on the website.
Conclusion
From a data protection perspective, Leonardo.Ai can only be classified as an EU/EEA tool directory to a limited extent. Positive aspects include the DPA, SCCs, list of subprocessors, EEA representative, and SOC 2 references. However, the lack of EU data residency, documented processing in the U.S. and Australia, and the use of content for service improvement and AI training—as described on the website—all argue against clear EU/EEA-compliant standard use. Anyone wishing to use the tool in the EU/EEA in a data-protection-sensitive manner would need to examine the specific use, data types, and contractual terms very carefully.
Sources
| On-prem / local hosting | ❓ |
| Private cloud / data center | ❓ |
| EU SaaS / Managed | ⚠️ |
| Hybrid | ❓ |
| DPA / AVV | ✅ |
| No training on customer data | ❓ |
| Open source / transparency path | ❓ |
On-prem / local hosting: indirect / not available
The website describes Leonardo.Ai as a cloud-based platform. The website does not mention an on-premises, local, or self-hostable product variant.
Private cloud / data center: unclear
There are references to AWS hosting and a processing role for certain customer scenarios, but no clear statement regarding dedicated private cloud environments, isolated EU environments, or customer-specific data center options.
EU SaaS / Managed: Partially
This is a managed SaaS service. For Europe, there are data protection notices and an EEA representative, but no guaranteed EU/EEA data residency. Instead, the website mentions storage in the U.S. and processing in Australia as well as other countries.
Hybrid: unclear
The website does not specify a hybrid deployment with partial internal/on-premises processing and partial external processing.
T&Cs / DPA: Covered
A Data Processing Addendum is published on the website. It governs processing as a data processor, documented client instructions, SCCs, subprocessors, erasure/return, and support for data subject rights.
No training: indirect / not available
The privacy policy explicitly states that content and associated account data may be used to improve the service and to train algorithms, models, and AI products. A general opt-out option for this training is not specified on the website. Although paid users can mark content as private, there is no evidence on the website of a contractual general exclusion of training for all user-generated content.
Open Source / Transparency Path: Indirect / Not Available
The website does not specify an open-source, self-hosting, or transparency-oriented sovereignty path for Leonardo.Ai itself. Only individual subprocessors and contractual data protection documents are documented.
Data Processing
The website describes Leonardo.Ai as a cloud-based platform. The DPA names AWS as the hosting and infrastructure provider; according to the privacy policy, data is stored in the U.S. and processed in Australia and other countries. The DPA contains a list of subprocessors with providers in the U.S., Singapore, and Germany. For restricted transfers to third countries, SCCs and, additionally, the UK Addendum are cited. A mandatory EU/EEA data residency requirement or exclusively European hosting is not specified on the website.
Conclusion
From a data protection perspective, Leonardo.Ai can only be classified as an EU/EEA tool directory to a limited extent. Positive aspects include the DPA, SCCs, list of subprocessors, EEA representative, and SOC 2 references. However, the lack of EU data residency, documented processing in the U.S. and Australia, and the use of content for service improvement and AI training—as described on the website—all argue against clear EU/EEA-compliant standard use. Anyone wishing to use the tool in the EU/EEA in a data-protection-sensitive manner would need to examine the specific use, data types, and contractual terms very carefully.
Sources
Strengths & weaknesses at a glance
| Strengths | Weaknesses |
|---|---|
| • Very broad visual stack: images, videos, editing, upscaling, real-time tools, API. | • Free use is less attractive from a data protection and IP perspective: content is public by default and can be indexed. |
| • Good options for style consistency through Elements / Custom Models. | • According to the Privacy Policy, content may be used for service improvement and model training unless work is done in the paid Private Mode. |
| • Low barrier to entry thanks to the free plan. | • Storage in the USA and processing also in Australia as well as other countries; in addition, several subprocessors outside the EU. |
| • Team and API offerings for scalable workflows. | • Token-based usage creates a consumption logic instead of a true flat rate; top-ups are only available for paying users. |
| • Publicly documented security and data protection measures including SOC 2, TLS 1.2+, AES-256, DPA, and SCCs. | • Custom/Enterprise/API Custom prices are not published transparently. |
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GDPR-compliant usage possible?
For the EU/EEA region, GDPR-compliant use is partially documented but not fully guaranteed. Positive aspects include a published privacy policy with a European focus, a Data Processing Addendum with SCCs, an EEA representative in Ireland, and a list of subprocessors. However, a negative aspect is that the website itself mentions data storage in the U.S. and processing in Australia and other countries, lists AWS as its hosting provider in the U.S., and does not guarantee EU data residency. Additionally, according to the privacy policy, Leonardo.Ai reserves the right to use content and account data to improve the service and to train algorithms and AI products. Thus, GDPR-compliant use within the EU/EEA appears possible only under certain conditions and following a detailed case-by-case review, rather than as a clearly established standard practice.
Positive
The website includes a privacy policy, a Data Processing Addendum with standard contractual clauses for limited third-country transfers, information on data subject rights, an EEA representative in Ireland, and a published list of subprocessors. For multi-user/team setups, the DPA describes processing as a data processor in accordance with documented customer instructions.
Negative
The website lists the U.S. as the standard storage location and Australia and other countries as processing locations. The list of subprocessors includes several providers in the U.S. and Singapore; a binding EU/EEA data residency is not specified. In addition, the privacy policy states that content and associated account data may be used to improve the service and to train algorithms, models, and AI products. A clear, general opt-out option for AI training is not provided on the website.
Server Location
According to the privacy policy, information is stored in the United States and processed in Australia and other countries. The DPA names AWS as the hosting and infrastructure provider and lists AWS, headquartered in the United States, in the list of subprocessors. The website does not specify a specific EU/EEA server location or EU data residency.