Midjourney · Midjourney Privacy Policy · View original document ↗

Advertising and Analytics Cookie Sharing

Medium severity High confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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Document Record

What it is

Midjourney states it may share your personal information with third-party advertising and analytics partners who use cookies or similar technologies to measure performance and deliver targeted ads.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

The policy authorizes sharing of personal data with advertising partners through cookies, which may result in your browsing activity and profile data being used to deliver targeted advertising.

Recent Activity

This document changed recently

High Apr 21, 2026

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 o…

Consumer impact (what this means for users)

Personal data may be shared with third-party advertising and analytics partners through cookies or similar tracking technologies; EU and UK users must provide explicit consent for non-essential advertising cookies, while California residents have a right to opt out of this sharing.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Opt Out of Arbitration
    Visit the Midjourney Privacy Settings page at https://www.midjourney.com/profile-settings to manage or withdraw your consent for non-essential advertising and analytics cookies.

How other platforms handle this

Shopify Medium

We share information with third parties who help us operate our business, including to assist us with marketing campaigns, advertising, analytics and research. These service providers are given access to your information as reasonably necessary to perform these tasks on our behalf and are obligated ...

Mixpanel Medium

We may share your personal information with third-party vendors and service providers that perform services on our behalf, such as web hosting, email delivery, analytics, marketing, advertising, payment processing, customer support, and data enrichment services. We may share your information with ad...

Groq Medium

There is certain information that we collect automatically from your use of our online Services and from your device(s) used to access those Services, for example by using the types of technologies discussed in the 'Online Analytics' section below. This information includes your IP address, page vie...

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▸ View Original Clause Language DOCUMENT RECORD
"
With Service Providers, Third Party Vendors, Consultants, and other Business Partners: We may share Your personal information with these parties in order to provide the Services to You on our behalf, monitor and analyze the use of our Services, contact You, and for other purposes stated in the Agreement. This may also include third party analytics and advertising partners that use cookies or similar technologies to help measure performance and deliver more relevant ads, where permitted by law.

— Excerpt from Midjourney's Midjourney Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

1) REGULATORY LANDSCAPE: The sharing of personal data with advertising partners through cookies engages GDPR and UK GDPR consent requirements for non-essential cookies, the EU ePrivacy Directive, and CCPA and CPRA do-not-sell and do-not-share provisions. The FTC Act's unfair or deceptive practices standards apply to the adequacy of disclosure. Enforcement authorities include EU national DPAs, the UK ICO, the California Privacy Protection Agency, and the FTC. 2) GOVERNANCE EXPOSURE: Medium. The policy states that non-essential advertising cookies require explicit consent from EEA and UK users and that consent can be managed at the Privacy Settings page. For California users, the policy references a do-not-share opt-out. Compliance exposure exists if the technical implementation of consent management does not match the policy's stated commitments, particularly regarding consent granularity and withdrawal mechanisms. 3) JURISDICTION FLAGS: EEA and UK users face the most significant exposure given GDPR and ePrivacy Directive consent requirements. California users have CPRA opt-out rights for sharing through advertising cookies. The policy explicitly addresses these jurisdictions with specific mechanisms. 4) CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should review data processing agreements with advertising and analytics partners to confirm they satisfy GDPR Article 28 processor requirements and CCPA service provider definitions. If advertising partners use data for their own purposes beyond Midjourney's services, the relationship may constitute a sale or disclosure subject to additional CCPA obligations. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should audit the consent management platform in use to confirm that explicit consent is obtained before advertising cookies are set for EEA and UK users, that consent withdrawal is technically operative and takes effect promptly, and that the CCPA opt-out mechanism for cookie-based sharing is implemented in accordance with CPRA regulations including Global Privacy Control signal recognition.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has jurisdiction over consumer data sharing practices with advertising partners and may evaluate whether disclosures and opt-out mechanisms meet applicable standards.
    File a complaint →

Applicable regulations

EU AI Act
European Union
BIPA
Illinois, USA
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
EU AI Act - High Risk Provisions
EU
FTC Act Section 5
United States Federal
GDPR
European Union
UK GDPR
United Kingdom

Provision details

Document information
Document
Midjourney Privacy Policy
Entity
Midjourney
Document last updated
May 5, 2026
Tracking information
First tracked
May 12, 2026
Last verified
May 12, 2026
Record ID
CA-P-010979
Document ID
CA-D-00094
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
4f973ca215c40ca11dfb698adf7f5dbf2114ba1559811ad1a732eca9efa6c06f
Analysis generated
May 12, 2026 04:55 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Midjourney
Document: Midjourney Privacy Policy
Record ID: CA-P-010979
Captured: 2026-05-12 04:55:54 UTC
SHA-256: 4f973ca215c40ca1…
URL: https://conductatlas.com/platform/midjourney/midjourney-privacy-policy/advertising-and-analytics-cookie-sharing/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Midjourney's Advertising and Analytics Cookie Sharing clause do?

The policy authorizes sharing of personal data with advertising partners through cookies, which may result in your browsing activity and profile data being used to deliver targeted advertising.

How does this clause affect you?

Personal data may be shared with third-party advertising and analytics partners through cookies or similar tracking technologies; EU and UK users must provide explicit consent for non-essential advertising cookies, while California residents have a right to opt out of this sharing.

Is ConductAtlas affiliated with Midjourney?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Midjourney.