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
The policy establishes age 13 as the minimum age threshold and commits to deleting data collected from underage users without parental consent, consistent with COPPA requirements in the United States.
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.
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The Service is intended for general audiences and is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe that your child under the age of 13 has provided us with personal information without your cons...
To access and use the Services, you must be at least the age of majority in the state, province, or territory where you live or at least 18 years of age. If you are under the age of 13, you may not use the Services and you should not be visiting the Sites or using the Services.
enableGpcSdk: true, gpcSetting: { privacyPolicyLink: '/Privacy-Security-Policy-a-282.html' }
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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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The policy establishes age 13 as the minimum age threshold and commits to deleting data collected from underage users without parental consent, consistent with COPPA requirements in the United States.
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.
ConductAtlas has identified this type of provision across 10 platforms. See the full comparison.
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