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
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.
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 →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
If you are a resident in the EEA, Switzerland or the UK, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We may transfer Personal Information from the EEA, Switzerland or the UK to the U.S. and other third countries ...
We may share or transfer 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 by another company.
In the event that we are involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your personal information may be sold or transferred as part of that transaction. This Privacy Policy will apply to your personal information as transferred to the new entity, although the new ...
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"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
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.
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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.
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.
ConductAtlas has identified this type of provision across 2 platforms. See the full comparison.
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