California residents can ask Midjourney what data it holds on them, request its deletion, or correct it, and Midjourney states it does not sell personal data under California law.
This analysis describes what Midjourney'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
The policy discloses that Midjourney does not sell personal information under CCPA but does not address whether data shared with business partners for advertising or other purposes constitutes CPRA-regulated sharing, which may carry its own opt-out requirement distinct from the sale opt-out.
Interpretive note: The policy does not explicitly address whether data sharing with business partners for advertising-related purposes constitutes CPRA-regulated sharing requiring a separate opt-out mechanism, creating interpretive ambiguity.
California residents can submit data access, deletion, or correction requests to privacy@midjourney.com; the policy's assertion that it does not sell personal information does not necessarily preclude sharing that may require a separate opt-out under CPRA's cross-context behavioral advertising provisions.
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"If you are a California resident, you have the right to know what personal information we collect, use, and disclose about you; the right to request deletion of your personal information; the right to correct inaccurate personal information; and the right to opt out of the sale or sharing of your personal information. We do not sell your personal information as that term is defined under the California Consumer Privacy Act. To exercise your rights, please contact us at privacy@midjourney.com.— Excerpt from Midjourney's Midjourney Data Retention & Privacy FAQ
REGULATORY LANDSCAPE: This provision engages the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), enforced by the California Privacy Protection Agency (CPPA) and the California Attorney General. The policy's no-sale assertion should be evaluated against CPRA's definition of sharing for cross-context behavioral advertising, which is a distinct category from selling and carries its own opt-out obligation (CPRA Section 1798.120). The FTC also has parallel authority over deceptive privacy practices. GOVERNANCE EXPOSURE: Medium. The policy asserts no sale of personal information but does not address the CPRA sharing category explicitly; if Midjourney shares data with advertising or analytics partners in ways that meet the CPRA definition of sharing, an opt-out mechanism may be required that is not described in this policy. Compliance teams should assess whether a Do Not Share opt-out link is required on the Midjourney website. JURISDICTION FLAGS: Applies to California residents. The CPPA has rulemaking and enforcement authority. Businesses meeting CCPA thresholds (over $25 million in gross annual revenue, processing data of 100,000 or more consumers, or deriving 50% of revenue from selling personal information) are subject to CPRA obligations. CONTRACT AND VENDOR IMPLICATIONS: California-based enterprise customers should verify that Midjourney's data processing practices for California employees and customers comply with CPRA, including whether a Data Processing Agreement reflects CPRA service provider restrictions on secondary use of personal information. COMPLIANCE CONSIDERATIONS: Legal teams should evaluate whether Midjourney's sharing of behavioral or advertising-related data with third parties triggers CPRA's sharing opt-out requirements. The policy should be reviewed to confirm it includes all required CPRA disclosures, including categories of personal information shared with third parties in the preceding 12 months.
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The policy discloses that Midjourney does not sell personal information under CCPA but does not address whether data shared with business partners for advertising or other purposes constitutes CPRA-regulated sharing, which may carry its own opt-out requirement distinct from the sale opt-out.
California residents can submit data access, deletion, or correction requests to privacy@midjourney.com; the policy's assertion that it does not sell personal information does not necessarily preclude sharing that may require a separate opt-out under CPRA's cross-context behavioral advertising provisions.
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