If Midjourney is sold, merges with another company, or undergoes a major business transaction, your personal data may be transferred to the new owner as part of that deal.
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
A future acquisition or merger could result in your data being controlled by an entirely different company with different privacy practices, and you may have limited ability to prevent this transfer.
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 o…
In the event of a sale or acquisition of Midjourney, your prompts, images, account information, and other personal data may be transferred to the acquiring entity, which may operate under different privacy standards.
How other platforms handle this
Where required by law, we provide adequate protection for the transfer of personal data in accordance with applicable law, such as by obtaining your consent, relying on the European Commission's adequacy decisions, or executing Standard Contractual Clauses. Where relevant, you may request a copy of ...
In connection with any reorganization, restructuring, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with our Privacy Policy.
We may share or transfer your 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 to another company.
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"We may share or transfer your 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.— Excerpt from Midjourney's Midjourney Privacy Policy
REGULATORY LANDSCAPE: Corporate transaction data transfers engage GDPR requirements regarding the lawful basis for transfer and the obligation to notify data subjects of changes in data controller identity under Articles 13 and 14. Under CCPA, a merger or acquisition may trigger disclosure obligations to California residents if the transaction results in a material change to how their personal information is used. The FTC has reviewed data transfers in corporate transactions as part of merger review processes. GOVERNANCE EXPOSURE: Low to Medium. This clause is standard in US-based service provider privacy policies and reflects common commercial practice, but its implications are material for users who have shared significant personal or creative data with the service. JURISDICTION FLAGS: EU and UK users may have stronger protections if the acquiring entity is located in a country without an adequacy decision, as the transfer would need to satisfy GDPR cross-border transfer requirements. California residents may have rights to request deletion before a transfer is completed if they object to the new entity's practices. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers should note that their data could be transferred to a competitor or an entity with different security and privacy standards in a corporate transaction scenario. Procurement teams may wish to include contractual protections requiring notification in the event of a change of control affecting data processing. COMPLIANCE CONSIDERATIONS: Compliance teams should monitor Midjourney for public announcements of corporate transactions that could trigger this clause. Legal teams advising EU clients should assess whether a change of controller would require fresh consent or notification obligations under GDPR.
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A future acquisition or merger could result in your data being controlled by an entirely different company with different privacy practices, and you may have limited ability to prevent this transfer.
In the event of a sale or acquisition of Midjourney, your prompts, images, account information, and other personal data may be transferred to the acquiring entity, which may operate under different privacy standards.
ConductAtlas has identified this type of provision across 18 platforms. See the full comparison.
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