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
Relying on user acceptance of a privacy policy as 'consent' for cross-border data transfers does not meet GDPR's standard for valid transfer mechanisms, creating potential legal exposure for EEA users.
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…
The policy states that Midjourney collects user-submitted prompts, uploaded images, IP addresses, usage data, cookies, and behavioral inferences, and may share these with service providers, advertising partners, and analytics companies. Personal data including prompts and uploaded content may also be used in connection with machine learning model training, as noted in the policy's description of applicable data collection contexts. You can request access to, deletion of, or portability of your personal data by visiting www.midjourney.com/account and following the instructions at the bottom of the page.
How other platforms handle this
We process and store information in the U.S. and other countries. By using our Services and Software, you authorize Adobe to transfer your personal information across national borders and to other countries where Adobe and its partners operate.
When we transfer personal data from the European Economic Area, the United Kingdom, or Switzerland to the United States or other countries that do not provide the same level of data protection, we implement appropriate safeguards, such as Standard Contractual Clauses approved by the European Commiss...
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Monitoring
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"Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in Your jurisdiction. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.— Excerpt from Midjourney's Midjourney Privacy Policy
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Relying on user acceptance of a privacy policy as 'consent' for cross-border data transfers does not meet GDPR's standard for valid transfer mechanisms, creating potential legal exposure for EEA users.
ConductAtlas has identified this type of provision across 2 platforms. See the full comparison.
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