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The policy states that Midjourney does not sell personal information but does share it with third-party advertising partners through cookies for personalized advertising purposes, and that users can opt out of this sharing at any time via the Privacy Settings page.
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
This provision establishes that personal data sharing occurs through advertising cookies with third-party partners for personalized ad delivery, and that an opt-out mechanism is available via the Privacy Settings page. For EEA and UK users, the policy separately states that non-essential cookies require explicit consent prior to use.
The agreement authorizes sharing of personal data with third-party advertising partners through cookies for personalized ad delivery. Users can opt out of this sharing at any time through the Privacy Settings page, and EEA and UK users must provide explicit consent before non-essential advertising cookies are activated.
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"Do Not Sell or Share Opt-Out Rights You have the right to opt-out of any "sale" or "sharing" , as defined by the CCPA, of Personal Information by Midjourney. While, Midjourney does not sell your information , we may share it, for example, through advertising cookies that allow our third party partners to deliver relevant and personalized ads. You can opt-out of such sharing at any time by updating your preferences in the Privacy Settings page.Excerpt from Midjourney's Privacy Policy
1. REGULATORY LANDSCAPE: This provision implicates the CCPA's definition of sharing for cross-context behavioral advertising, enforced by the California Privacy Protection Agency. For EEA and UK users, the provision engages GDPR and the ePrivacy Directive regarding cookie consent requirements, enforced by EU supervisory authorities and the UK Information Commissioner's Office. The FTC Act applies at the federal level regarding advertising data practices. 2. GOVERNANCE EXPOSURE: Medium. The policy discloses third-party advertising cookie sharing and provides an opt-out mechanism, satisfying baseline CCPA disclosure requirements. For GDPR-governed users, the policy states that explicit consent is required for non-essential cookies, but the adequacy of the consent mechanism as implemented is not verifiable from the policy text alone. 3. JURISDICTION FLAGS: California residents have a statutory right to opt out of sharing for cross-context behavioral advertising under the CCPA. EEA and UK users operate under a prior-consent model for non-essential cookies, which creates a stricter standard than the opt-out model applicable to US users. Organizations deploying Midjourney for business use should assess whether employee activity on the platform is subject to advertising cookie tracking. 4. CONTRACT AND VENDOR IMPLICATIONS: Business users should confirm through vendor assessment whether third-party advertising partners receiving shared data via cookies are subject to data processing agreements and whether the scope of data shared is documented. The policy does not name specific advertising partners, which may limit vendor due diligence. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should audit the Privacy Settings page to confirm the opt-out mechanism functions as described and that cookie consent banners for EEA and UK users meet granularity and specificity requirements under applicable supervisory authority guidance. Data mapping should include advertising cookie sharing as a processing activity with third-party advertising partners identified as separate controllers or processors.
Regulatory citations, enforcement risk, and due diligence action items.
Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
This provision establishes that personal data sharing occurs through advertising cookies with third-party partners for personalized ad delivery, and that an opt-out mechanism is available via the Privacy Settings page. For EEA and UK users, the policy separately states that non-essential cookies require explicit consent prior to use.
The agreement authorizes sharing of personal data with third-party advertising partners through cookies for personalized ad delivery. Users can opt out of this sharing at any time through the Privacy Settings page, and EEA and UK users must provide explicit consent before non-essential advertising cookies are activated.
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