Midjourney Privacy Policy

This document is Midjourney's privacy policy (last updated June 2, 2025) governing the collection, use, and disclosure of personal data collected through midjourney.com, Discord servers administered by Midjourney, and any other means of accessing the Services, with legal bases including consent, contract performance, and legitimate interests. The agreement states that Midjourney collects identifiers, IP addresses, user prompts (including text, images, and spoken input converted to text), usage data, cookies, contact information, organizational information, commercial information, internet activity, sensory data (uploaded images), and inferences drawn about users; the terms authorize sharing this data with service providers, analytics and advertising partners, and third parties in the context of business transfers or law enforcement requests. The policy discloses that Midjourney draws inferences about users to create profiles reflecting preferences, characteristics, and behavior, and that personal data may be used for machine learning training, which represents a materially distinct operational scope compared to many consumer-facing service privacy policies; the agreement asserts that cross-border data transfers are authorized by user consent to the policy itself, a mechanism whose adequacy under GDPR and UK data protection law may require evaluation beyond the assertion made here. The policy engages GDPR and UK GDPR for EEA, Switzerland, and UK users, citing consent, contract performance, and legitimate interests as legal bases, and the CCPA for California residents, disclosing collection and disclosure across multiple data categories including identifiers, commercial information, internet activity, sensory data, and inferences; EU users are provided rights to access, correction, deletion, portability, and objection, while California residents receive CCPA-specific rights including a do-not-sell or share opt-out. Compliance teams should note that the policy's use of personal data to train machine learning models, combined with the breadth of collected data categories including user-submitted prompts and uploaded images, creates material data governance obligations under GDPR and CCPA that warrant ongoing audit of consent mechanisms, data retention schedules, and vendor data processing agreements.