Midjourney · Midjourney Privacy Policy · View original document ↗

Inference Data Collection and Disclosure

Medium severity Unique · 0 of 325 platforms
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Recent governance activity Midjourney recorded 5 documented changes in the last 30 days.
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Document Record

What it is

Midjourney creates inferences about you — conclusions about your preferences, behaviors, and characteristics — based on how you use the service, and shares these inferences with third parties.

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)

The clause establishes that inferred personal attributes—derived rather than directly observed—constitute permissible data categories under the privacy policy. This expands the scope of collectible data beyond transactional information to include behavioral and psychological profiling derived from user interactions.

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 →

Consumer impact (what this means for users)

Midjourney builds behavioral profiles based on your usage and shares these inferred profiles with third parties, which may affect how you are targeted online. California residents can request access to and deletion of this inference data under CCPA.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Visit https://www.midjourney.com/account, follow the instructions at the bottom of the page to submit a deletion request for your personal data including inferences Midjourney has derived about you.

How other platforms handle this

Meta Medium

We may access, preserve, and share information with regulators, law enforcement, or others if we believe it is reasonably necessary to: detect, prevent, and address fraud and other illegal activity; protect ourselves, you, and others, including as part of investigations; and prevent death or imminen...

YouTube Kids Medium

We will share individual user information with companies, organizations or individuals outside of Google if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to: meet any applicable law, regulation, legal process or enforceable govern...

Tabnine Medium

Tabnine is headquartered in the United States and operates globally. If you are located outside the United States, your personal data may be transferred to and processed in the United States or other countries that may not provide the same level of data protection as your home country. We rely on ap...

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▸ View Original Clause Language DOCUMENT RECORD
"
11 Inferences Conclusions that could be used to create a profile reflecting an individual's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, aptitude. YES. YES

— Excerpt from Midjourney's Midjourney Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

Midjourney's CCPA disclosure table confirms collection and disclosure of 'Inferences' (Category 11), which under CPRA constitutes a category of sensitive personal information subject to enhanced consumer rights. Compliance teams should assess whether inference data sharing with advertising partners constitutes a 'sale' or 'sharing' triggering opt-out requirements, and whether CPRA's 'limit use of sensitive PI' right is being honored.

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC has authority over unfair or deceptive practices related to consumer profiling and behavioral data sharing.
    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-000670
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-000670
Captured: 2026-03-20 12:17:21 UTC
SHA-256: 17818e1b0919b17f…
URL: https://conductatlas.com/platform/midjourney/midjourney-privacy-policy/inference-data-collection-and-disclosure/
Accessed: May 20, 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 Inference Data Collection and Disclosure clause do?

The clause establishes that inferred personal attributes—derived rather than directly observed—constitute permissible data categories under the privacy policy. This expands the scope of collectible data beyond transactional information to include behavioral and psychological profiling derived from user interactions.

How does this clause affect you?

Midjourney builds behavioral profiles based on your usage and shares these inferred profiles with third parties, which may affect how you are targeted online. California residents can request access to and deletion of this inference data under CCPA.

Is ConductAtlas affiliated with Midjourney?

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