Midjourney states it does not sell personal information but acknowledges it may share personal information with advertising cookie partners, and that California residents have the right to opt out of this sharing.
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 distinguishes between selling and sharing personal data under CCPA, acknowledging that advertising cookie sharing may qualify as sharing under CPRA, and provides California residents with a specific opt-out right.
Interpretive note: The document text was truncated at the point of describing the full opt-out mechanism, preventing confirmation of all implementation details referenced in this provision.
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 →California residents have the right under CCPA and CPRA to opt out of Midjourney's sharing of personal information with advertising partners through cookies; the policy states Midjourney does not sell personal information but confirms sharing for advertising purposes may occur.
How other platforms handle this
If you are a California resident, you have the right to know what personal information we collect, use, and disclose about you; the right to request deletion of your personal information; the right to opt out of the sale or sharing of your personal information; the right to correct inaccurate person...
If you are a California resident, you have the right to: Know what personal information is being collected about you; Know whether your personal information is sold or disclosed and to whom; Say no to the sale of personal information; Access your personal information; Request deletion of your person...
Depending on where you live, you may have certain rights with respect to your personal information, such as the right to request access, correction, or deletion of your personal information, or to opt out of the sale or sharing of your personal information. If you are a California resident, you have...
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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 ou— Excerpt from Midjourney's Midjourney Privacy Policy
1) REGULATORY LANDSCAPE: This provision directly engages the CCPA as amended by CPRA, specifically the do-not-sell and do-not-share rights. The California Privacy Protection Agency is the primary enforcement authority, with concurrent enforcement by the California Attorney General. CPRA's definition of sharing includes disclosure to third parties for cross-context behavioral advertising, which the policy's reference to advertising cookies appears to acknowledge. The policy's disclosure that Midjourney does not sell data but may share it for advertising purposes is consistent with the CPRA distinction between sale and sharing. 2) GOVERNANCE EXPOSURE: Medium. The operational implementation of the do-not-share mechanism, including Global Privacy Control signal recognition, is required under CPRA regulations. The truncated document text prevents confirmation of the full opt-out mechanism described in the policy, creating uncertainty about whether the implementation details satisfy CPRA requirements. 3) JURISDICTION FLAGS: This provision applies specifically to California residents and individuals whose personal information was collected in California. Other states with comprehensive privacy laws (Virginia, Colorado, Connecticut, Texas) may have analogous opt-out rights that are not addressed in this policy section. 4) CONTRACT AND VENDOR IMPLICATIONS: Advertising and analytics partners receiving data through cookie-based sharing must be assessed to confirm they qualify as service providers or contractors under CPRA rather than third parties to whom a sale or sharing has occurred, as this classification affects the opt-out mechanism required. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should confirm that the GPC signal is technically recognized and operationally implemented across Midjourney's web properties, that the opt-out mechanism is accessible and functional, and that advertising partners receiving data through cookies have executed appropriate service provider agreements. Teams should also assess whether the policy's opt-out disclosure covers all sharing that may qualify under CPRA's cross-context behavioral advertising definition.
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The policy distinguishes between selling and sharing personal data under CCPA, acknowledging that advertising cookie sharing may qualify as sharing under CPRA, and provides California residents with a specific opt-out right.
California residents have the right under CCPA and CPRA to opt out of Midjourney's sharing of personal information with advertising partners through cookies; the policy states Midjourney does not sell personal information but confirms sharing for advertising purposes may occur.
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