Midjourney · Midjourney Privacy Policy · View original document ↗

Data Transfer in Merger or Acquisition

Medium severity Rare · 2 of 343 platforms
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Document Record

What it is

If Midjourney is sold, merged, or undergoes restructuring, your personal data may be transferred to the acquiring company as part of that transaction.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision establishes that personal data constitutes a transferable asset in corporate restructuring events. The authorization applies both during negotiation periods and upon transaction completion, meaning data recipients may change without separate user consent if a qualifying business event occurs.

Recent Activity

This document changed recently

High Apr 21, 2026

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 →

Clause Stability Stable

0
Changes
3
Months Monitored
Apr 3, 2026
First Seen
Apr 17, 2026
Last Seen
This clause type exists across 1153 other provisions on other platforms.

Consumer impact (what this means for users)

In a corporate sale or acquisition, your data — including prompts, images, and behavioral history — could be inherited by a new entity whose privacy standards may differ from Midjourney's. This transfer can occur without your individual consent.

How other platforms handle this

Discord Medium

We may share your information in connection with, or during negotiations of, any merger, sale of company assets, financing, acquisition, or dissolution, transaction, or proceeding involving all or a portion of our business.

MetaMask Medium

We may share your personal information with our affiliates, meaning entities that control, are controlled by, or are under common control with Consensys. We also share information with service providers who assist in operating our services, subject to confidentiality obligations.

Ledger Medium

At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.

See all platforms with this clause type →

Monitoring

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▸ View Original Clause Language DOCUMENT RECORD
"
For business transfers: We may share or transfer Your personal 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.

— Excerpt from Midjourney's Midjourney Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

The asset-transfer clause is broadly drafted and applies to mergers, acquisitions, financing events, and bankruptcy proceedings. Under GDPR, such transfers may require a lawful basis reassessment by the acquiring entity; under CCPA, users must be notified. Legal teams conducting M&A due diligence involving Midjourney should flag this clause as a material data asset disclosure obligation.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC reviews data transfer practices in corporate transactions and can challenge transfers that violate prior privacy representations made to consumers.
    File a complaint →

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Midjourney Privacy Policy
Entity
Midjourney
Document last updated
May 5, 2026
Tracking information
First tracked
March 20, 2026
Last verified
March 20, 2026
Record ID
CA-P-000667
Document ID
CA-D-00094
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
17818e1b0919b17fb76e08c77136c0c847e572fa678a7ae481892a9ba9bba0cb
Analysis generated
March 20, 2026 12:17 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Midjourney
Document: Midjourney Privacy Policy
Record ID: CA-P-000667
Captured: 2026-03-20 12:17:21 UTC
SHA-256: 17818e1b0919b17f…
URL: https://conductatlas.com/platform/midjourney/midjourney-privacy-policy/data-transfer-in-merger-or-acquisition/
Accessed: July 4, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Midjourney's Data Transfer in Merger or Acquisition clause do?

This provision establishes that personal data constitutes a transferable asset in corporate restructuring events. The authorization applies both during negotiation periods and upon transaction completion, meaning data recipients may change without separate user consent if a qualifying business event occurs.

How does this clause affect you?

In a corporate sale or acquisition, your data — including prompts, images, and behavioral history — could be inherited by a new entity whose privacy standards may differ from Midjourney's. This transfer can occur without your individual consent.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 2 platforms. See the full comparison.

Is ConductAtlas affiliated with Midjourney?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Midjourney.