Midjourney keeps your personal data for as long as it needs to for the purposes described in the policy, which could mean retaining it for an extended period for legal compliance or dispute resolution.
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 provision defines the operational scope and duration of data retention practices, establishing that retention extends beyond the primary service delivery purpose to encompass legal compliance, dispute resolution, and contractual enforcement obligations. This framework creates a multi-purpose retention basis that extends the standard service-related retention period.
Interpretive note: The policy does not specify retention periods for individual data categories, creating ambiguity about how long specific types of data such as prompts and generated images are retained in practice.
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 →Midjourney does not commit to a specific maximum retention period for personal data, meaning your account information, prompts, and generated images may be retained for an extended and indeterminate period, especially if linked to legal compliance or dispute resolution needs.
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We retain personal data for as long as needed to provide our services, comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will vary depending on the type of data and the purposes for which we use it.
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"We retain your personal information for as long as necessary to fulfill the purposes outlined in this privacy policy, unless a longer retention period is required or permitted by law. We may also retain and use your information to comply with our legal obligations, resolve disputes, and enforce our agreements.— Excerpt from Midjourney's Midjourney Privacy Policy
REGULATORY LANDSCAPE: Data retention practices engage GDPR's storage limitation principle, which requires that personal data be kept no longer than necessary for the specified purpose. Vague retention language stating data is kept 'as long as necessary' without defined periods may create tension with GDPR storage limitation requirements enforced by EU and UK supervisory authorities. Under CCPA, users have the right to request deletion, which interacts with retention practices. GOVERNANCE EXPOSURE: Medium. The absence of specific retention schedules is common in consumer-facing privacy policies but creates operational risk if EU or UK supervisory authorities require documentation of retention periods as part of accountability obligations under GDPR Article 5. JURISDICTION FLAGS: EU and UK users face heightened exposure because GDPR requires data controllers to define and document retention periods or criteria for determining them, and vague language may not satisfy this requirement. California users may exercise CCPA deletion rights to effectively override open-ended retention for non-legally-required data. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers should request clarification on Midjourney's data retention schedules for specific data categories, particularly for prompts and generated images, as part of their vendor risk assessment. The reference to retention for dispute resolution and legal compliance creates an indefinite carve-out that limits the practical scope of deletion requests. COMPLIANCE CONSIDERATIONS: Legal teams should assess whether Midjourney's retention practices meet the documentation requirements of GDPR Article 30 records of processing activities. Compliance teams advising EU clients should consider whether the absence of specific retention periods warrants a formal inquiry to Midjourney or adjustment of the organization's acceptable use policy.
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The provision defines the operational scope and duration of data retention practices, establishing that retention extends beyond the primary service delivery purpose to encompass legal compliance, dispute resolution, and contractual enforcement obligations. This framework creates a multi-purpose retention basis that extends the standard service-related retention period.
Midjourney does not commit to a specific maximum retention period for personal data, meaning your account information, prompts, and generated images may be retained for an extended and indeterminate period, especially if linked to legal compliance or dispute resolution needs.
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