Midjourney states that your personal data may be transferred to another company as part of a merger, acquisition, bankruptcy, or sale of business assets.
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 clause establishes the procedural framework under which user personal data may be transferred to a successor entity or acquirer in the event of a material corporate transaction or insolvency event. It clarifies that personal data is treated as a business asset subject to transfer alongside other company assets.
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 collected by Midjourney may be transferred to and processed by an acquiring or successor entity in the event of a merger, acquisition, or asset sale, as stated in the policy; the privacy practices of any successor entity would govern subsequent data processing.
How other platforms handle this
If you are a resident in the EEA, Switzerland or the UK, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We may transfer Personal Information from the EEA, Switzerland or the UK to the U.S. and other third countries ...
We may share or transfer personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
We may share your personal information with third parties in the following circumstances: with service providers who perform services on our behalf; with advertising and analytics partners; with business partners with whom we jointly offer products or services; with other parties with your consent; ...
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"For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.— Excerpt from Midjourney's Midjourney Privacy Policy
1) REGULATORY LANDSCAPE: Business transfer of personal data engages GDPR Article 6 lawful basis requirements, CCPA business purpose disclosures, and applicable merger notification or regulatory review processes. In the EU and UK, data subjects may have the right to object to transfer of their data to a successor entity depending on the lawful basis for the original processing. The FTC may also review data transfer provisions in corporate transactions involving significant consumer data assets. 2) GOVERNANCE EXPOSURE: Low to Medium. This is a standard commercial provision, but the breadth of data categories held by Midjourney, including user prompts, uploaded images, and behavioral inferences, means that a business transfer would involve transfer of operationally significant personal data. Due diligence in any transaction should address data protection obligations in the target company. 3) JURISDICTION FLAGS: EEA and UK users have stronger procedural protections in business transfer scenarios under GDPR, including potential notification obligations and objection rights. California users should be aware that CCPA rights may persist against successor entities depending on jurisdiction-specific application. 4) CONTRACT AND VENDOR IMPLICATIONS: In any M&A context, acquirers should conduct data protection due diligence on Midjourney's data assets, processing activities, consent records, and outstanding data subject requests. The presence of ML training data in the asset base creates specific diligence considerations around data provenance and consent. 5) COMPLIANCE CONSIDERATIONS: In the event of a planned business transfer, Midjourney's legal team should assess notification obligations to data subjects under GDPR and applicable state laws, evaluate whether successor entity data processing agreements need to be updated, and confirm that consent records accompany the transferred data.
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This clause establishes the procedural framework under which user personal data may be transferred to a successor entity or acquirer in the event of a material corporate transaction or insolvency event. It clarifies that personal data is treated as a business asset subject to transfer alongside other company assets.
Personal data collected by Midjourney may be transferred to and processed by an acquiring or successor entity in the event of a merger, acquisition, or asset sale, as stated in the policy; the privacy practices of any successor entity would govern subsequent data processing.
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