Midjourney states its service is not directed at children under 13 and that it will delete personal data collected from children under 13 if it becomes aware of such collection without parental consent.
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 the entity's operational compliance framework with the Children's Online Privacy Protection Act (COPPA). It defines the entity's age restriction policy and establishes procedures for data removal when underage data collection occurs, which structures the entity's legal obligations regarding children's personal data under federal regulation.
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 →Parents or guardians who believe a child under 13 has submitted personal data to Midjourney should contact the company directly to request removal; the policy states Midjourney will take steps to delete such data upon becoming aware of it.
How other platforms handle this
Our Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13 without parental consent. If we become aware that a child under 13 has provided us with personal information without parental consent, we will take steps to remo...
Our websites and mobile applications are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13 without parental consent. If we learn that we have collected personal information from a child under 13 without parental consent, we will...
The Services are intended for users who are 13 years of age or older. If you are under 13 years of age, you are not permitted to use the Services. By using the Services, you represent and warrant that you are 13 years of age or older. If you are between 13 and 18 years of age, you may only use the S...
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"Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.— Excerpt from Midjourney's Midjourney Privacy Policy
1) REGULATORY LANDSCAPE: This provision engages the Children's Online Privacy Protection Act (COPPA), which applies to operators of online services directed to children under 13 or that have actual knowledge of collecting personal information from children under 13. The FTC is the primary COPPA enforcement authority. For EEA users, GDPR Article 8 sets the consent age at 16 (with member state discretion to lower to 13), which is not addressed in this provision. 2) GOVERNANCE EXPOSURE: Low for COPPA purposes given the policy's statement that the service is not directed at children under 13. However, if the service is accessible without age verification mechanisms and minors do access it, actual knowledge standards under COPPA may engage additional obligations. The policy does not describe any age verification or gate mechanism. 3) JURISDICTION FLAGS: EEA users between 13 and 15 may be subject to GDPR Article 8 requirements in member states that have set the consent age above 13, which this policy does not address. UK users face a similar gap given the UK Children's Code. 4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise deployments in educational contexts should assess whether Midjourney's age policy is compatible with their own COPPA and FERPA obligations and whether additional contractual protections are required. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether the service's design includes any age screening or verification mechanism, whether the policy's COPPA commitment is operationally supported by a documented process for receiving and responding to parental contact requests, and whether GDPR Article 8 and UK Children's Code obligations are addressed for European users under the applicable consent age threshold.
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This provision establishes the entity's operational compliance framework with the Children's Online Privacy Protection Act (COPPA). It defines the entity's age restriction policy and establishes procedures for data removal when underage data collection occurs, which structures the entity's legal obligations regarding children's personal data under federal regulation.
Parents or guardians who believe a child under 13 has submitted personal data to Midjourney should contact the company directly to request removal; the policy states Midjourney will take steps to delete such data upon becoming aware of it.
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