Midjourney states its service is not for children under 13 and will delete any data it discovers was collected from a child under 13.
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 establishes a minimum age of 13 and invokes a COPPA-aligned framework for handling children's data, but relies on a reactive deletion approach rather than proactive age verification at point of registration.
This provision states that users under 13 should not use Midjourney and that any such data discovered will be deleted; parents who believe their child has created an account can contact privacy@midjourney.com to request data deletion.
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"The Services are not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will take steps to delete that information as soon as possible.— Excerpt from Midjourney's Midjourney Data Retention & Privacy FAQ
REGULATORY LANDSCAPE: This provision engages the Children's Online Privacy Protection Act (COPPA), enforced by the FTC, which requires verifiable parental consent before collecting personal information from children under 13. The policy's reactive approach (delete upon discovery) may be evaluated against COPPA's affirmative requirement for parental consent mechanisms. The EU's GDPR and UK GDPR set a digital age of consent at 16 (with member state flexibility down to 13), which may require additional protections for users aged 13 to 15 in certain EU jurisdictions. GOVERNANCE EXPOSURE: Medium. The absence of an affirmative age verification mechanism at registration creates potential COPPA exposure if children under 13 access the platform. The FTC has taken enforcement action against platforms that relied on age attestation alone without verification. EU jurisdictions with a digital consent age above 13 create additional exposure for users in that age bracket. JURISDICTION FLAGS: COPPA applies in the United States. GDPR Article 8 applies to users in EU/EEA member states, with digital consent ages varying by country (13 in some, 16 in others). The UK Children's Code (Age Appropriate Design Code) may apply if UK minors are reasonably likely to access the service. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers deploying Midjourney in educational or youth-facing contexts should confirm that Midjourney's age verification and parental consent practices are adequate for their use case and applicable regulations. COMPLIANCE CONSIDERATIONS: Legal teams should assess whether the reactive deletion approach satisfies COPPA's requirements and whether a more robust age verification mechanism is warranted. For EU deployments, review of digital consent age by member state is recommended.
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The policy establishes a minimum age of 13 and invokes a COPPA-aligned framework for handling children's data, but relies on a reactive deletion approach rather than proactive age verification at point of registration.
This provision states that users under 13 should not use Midjourney and that any such data discovered will be deleted; parents who believe their child has created an account can contact privacy@midjourney.com to request data deletion.
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