Midjourney may use the text prompts you type and the images the AI generates for you to train and improve its AI models.
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 provision establishes the operational scope of data collection and processing beyond immediate service delivery. It defines a core business practice—using user-generated content and interaction data as inputs for model training—as part of the service terms.
Interpretive note: The policy does not specify the legal basis for AI training data use under GDPR, and the scope of any opt-out mechanism for this processing is not clearly described in the available document text.
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 →Prompts you enter and images generated from them may be used to train Midjourney's AI models, meaning your creative and potentially personal content contributes to the development of a commercial product beyond your immediate use of the service.
How other platforms handle this
To improve the quality of our services, we analyse texts submitted for translation. We ensure that this analysis cannot be traced back to individual users by anonymising the data before analysis. DeepL Pro subscribers' texts are not used to train our machine translation systems.
Only models with a post-mitigation score of "medium" or below can be deployed. Only models with a post-mitigation score of "high" or below can be developed further.
engage in any of the foregoing in connection with any use, creation, development, modification, prompting, fine-tuning, training, testing, benchmarking or validation of any artificial intelligence or machine learning tool, model, system, algorithm, product or other technology ("AI Tool").
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"We use the information we collect to provide, maintain, and improve our Services, including to train and improve our AI models. This includes using your prompts, generated images, and other interactions with the Services.— Excerpt from Midjourney's Midjourney Privacy Policy
REGULATORY LANDSCAPE: This provision engages GDPR Articles 6 and 13 regarding lawful basis and transparency for processing personal data for AI training purposes, as well as CCPA provisions on the use of personal information beyond the context of collection. The FTC has indicated interest in AI training data practices under its unfair or deceptive practices authority. The policy does not specify the legal basis relied upon for this processing under GDPR, which may create exposure with EU supervisory authorities. GOVERNANCE EXPOSURE: High. The use of user-generated content including prompts that may contain personal information about the user or third parties for AI training is a high-sensitivity processing activity. Prompts may contain names, locations, personal circumstances, or other identifiable information, and the policy does not clearly describe an opt-out mechanism for this specific use. JURISDICTION FLAGS: EU and UK users face heightened exposure because GDPR requires a clear and documented legal basis for processing personal data for AI training, and consent must be freely given, specific, and withdrawable. California residents may have rights to opt out of uses of personal information that extend beyond the primary service transaction. Illinois users should note that prompts referencing biometric identifiers could implicate BIPA considerations, though this is speculative without more specific document language. CONTRACT AND VENDOR IMPLICATIONS: Organizations deploying Midjourney for enterprise or business use should assess whether employee-generated prompts constitute organizational data and whether the AI training use is compatible with their data processing agreements or internal data governance policies. This clause may create tension with vendor contracts that restrict secondary use of proprietary or confidential information entered into third-party platforms. COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether Midjourney provides a meaningful opt-out mechanism for AI training data use and document that assessment. Legal teams advising EU or UK clients should evaluate whether the absence of a specified legal basis for this processing warrants a formal inquiry or adjustment to usage policies. Data mapping exercises should capture prompts and generated images as a data category with AI training as a secondary use.
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The provision establishes the operational scope of data collection and processing beyond immediate service delivery. It defines a core business practice—using user-generated content and interaction data as inputs for model training—as part of the service terms.
Prompts you enter and images generated from them may be used to train Midjourney's AI models, meaning your creative and potentially personal content contributes to the development of a commercial product beyond your immediate use of the service.
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