CA-C-001358 Top 5%
Midjourney — Midjourney Privacy Policy
Entity
Date detected
April 21, 2026
Effective date
April 21, 2026
Severity
Direction
Negative
Affected users
all users minors parents
Taxonomy
Transparency removal
Changes
−7 sentences removed
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Event Summary

Midjourney removed 7 sentences and structural elements from its Privacy Policy on April 21, 2026, including the introduction, sections on sharing personal data, security, children's privacy, links to other websites, and policy change procedures. The document now contains 127 sentences. The removed language appears to include core privacy disclosures and procedural safeguards that were previously indexed as separate policy sections.

HIGH

Consumer Impact

The updated privacy policy removed language describing how Midjourney shares personal data, the security measures protecting that data, children's privacy safeguards, procedures for notifying users of policy changes, and links to related policies. Users no longer have explicit disclosure of these practices within the privacy policy itself. The removal of language on how policy changes are communicated may mean users have less notice of future privacy modifications than previously stated.

Governance Analysis

The updated privacy policy removes explicit disclosures of how Midjourney shares data, protects it, handles children's information, and notifies users of policy changes. These removals may create compliance gaps under GDPR and CCPA, which require transparent disclosure of data practices. The removal of children's privacy safeguards is particularly material for organizations serving minors and potentially creates COPPA compliance considerations.

Available Actions

Request a copy of Midjourney's current data handling practices and security procedures in writing through support channels, as these are no longer explicitly disclosed in the policy

If No Action Is Taken

Users will not have explicit reference to how their data is shared with third parties under the privacy policy terms

Parents and guardians will not have explicit reference to children's privacy protections within the policy structure

Users will not have notice of the specific procedure Midjourney uses to inform them of future privacy policy changes

Key Clauses Affected

Data Sharing Disclosure

Removed explicit section describing how personal data is shared with third parties.

Security of Personal Data

Removed section describing security measures and protections for user data.

Children's Privacy

Removed safeguards and procedures for handling minors' personal data.

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This change record describes what was added, removed, or modified in the document. Analysis reflects what the updated agreement states or permits. It does not constitute a legal determination about enforceability. Applicability may vary by jurisdiction. Methodology

Evidence Verification

✓ Verified
Previous Version
54958988f20c01144b3671c992c379c048552e8b0471617c6b4c8285aef0cb18
April 19, 2026 06:06 UTC
✓ Verified
Current Version
31a78fe46275c58bc78432dcb6f1164a07d9bb61c0ea0f36d50b715fa5c4ffc7
April 21, 2026 06:06 UTC
✓ Verified
Change Detected
April 21, 2026 06:06 UTC
Analysis Methodology
Citation Record
Entity: Midjourney
Document: Midjourney Privacy Policy
Record ID: CA-C-001358
Captured: 2026-04-21 06:06:50 UTC
URL: https://conductatlas.com/change/2026-04-21-midjourney-midjourney-privacy-policy-1358/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.

Impact Summary

5
Protections removed
Consumers Removed

Users can no longer reference a dedicated section describing which parties Midjourney shares data with.

Consumers Removed

Users can no longer reference a dedicated section describing how Midjourney protects their data from unauthorized access.

+ 3 more obligation changes. Full breakdown available with Watcher.

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Institutional Analysis

Assessment

Midjourney removed core privacy policy sections covering data sharing, security, children's privacy, and the procedure for notifying users of policy changes. This reduction in disclosed practices and procedural safeguards may create compliance exposure under GDPR (which requires transparent disclosure of data processing and recipients), CCPA (which requires clear disclosure of information practices), and COPPA (which requires reasonable steps to protect children's privacy). Organizations using Midjourney for their own services should assess whether the removal of these disclosures affects their downstream privacy notices and vendor assessment practices.

Regulatory Exposure

GDPR (Articles 13-14 transparency and disclosure requirements), CCPA (disclosure of information practices), COPPA (children's online privacy protections), FTC Act Section 5 (unfair or deceptive practices)

Full compliance analysis

Obligation analysis, escalation trigger, board language, and recommended action.

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ConductAtlas provides verified policy intelligence sourced directly from platform documents. All analysis is intended to support, not replace, legal and compliance review. Record CA-C-001358.

Full Changes

See the full side-by-side comparison of every sentence added, removed, and modified.

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Document Context

Version history → Policy drift analysis → Document page →
Document
Midjourney Privacy Policy
Entity
Midjourney
Captured
April 21, 2026
Source URL
https://docs.midjourney.com/docs/privacy-policy
Other changes to Midjourney Privacy Policy
Previous change Apr 19, 2026
Midjourney's privacy policy was reorganized on April 19, 2026 to add structural headings and table of contents entries. The update …
Low Neutral
Next change May 2, 2026
Midjourney restructured its Privacy Policy on May 2, 2026 by adding table of contents entries and section headers for standard …
Low Neutral
View full version history →
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