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
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.
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.
View change record →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.
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We may display advertisements on our Services and those advertisements may be targeted to your interests based on your personal information. We may share your personal information with advertising partners for interest-based advertising purposes. You may opt out of interest-based advertising by visi...
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"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
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.
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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.
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.
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