Provision record
Midjourney · Midjourney Privacy Policy · View original document ↗

International Data Transfer via Policy Consent

Medium severity Medium confidence Explicit document language Unique · 0 of 352 platforms
Stay ahead of the changes
Track Midjourney and get the diff the day its terms change.
Share 𝕏 Share in Share 🔒 PDF
Document Record

What it is

The policy states that personal data may be transferred to and processed in jurisdictions outside the user's country, and that consent to this policy combined with submission of information constitutes agreement to such transfers.

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 asserts that consent to the privacy policy itself, combined with data submission, serves as the legal mechanism authorizing international data transfers. For EEA and UK users, the policy separately references standard contractual clauses as the transfer mechanism, which is the operative legal basis under GDPR; reliance on policy consent alone as a transfer mechanism may warrant evaluation against applicable transfer adequacy requirements.

Interpretive note: The policy's reliance on consent to the privacy policy as the legal basis for international transfers may not satisfy GDPR's transfer mechanism requirements; the EEA supplemental section references standard contractual clauses as the operative mechanism, creating potential ambiguity about which basis applies to which users.

Clause Stability Stable

0
Changes
5
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under these terms, personal data may be transferred to and processed in jurisdictions with different data protection laws. For EEA and UK users, the policy separately states that standard contractual clauses are used to safeguard such transfers, providing an additional legal mechanism beyond general policy consent.

Cross-platform context

See how other platforms handle International Data Transfer via Policy Consent and similar clauses.

Compare across platforms →
▸ View Original Clause Language DOCUMENT RECORD
"
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.

Excerpt from Midjourney's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Provision details

Document information
Document
Midjourney Privacy Policy
Entity
Midjourney
Document last updated
May 5, 2026
Tracking information
First tracked
May 12, 2026
Last verified
July 9, 2026
Record ID
CA-P-013922
Document ID
CA-D-00094
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
31a78fe46275c58bc78432dcb6f1164a07d9bb61c0ea0f36d50b715fa5c4ffc7
Analysis generated
May 12, 2026 04:55 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Midjourney
Document: Midjourney Privacy Policy
Record ID: CA-P-013922
Captured: 2026-05-12 04:55:54 UTC
SHA-256: 31a78fe46275c58b…
URL: https://conductatlas.com/platform/midjourney/midjourney-privacy-policy/provision/CA-P-013922/international-data-transfer-via-policy-consent/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

Get the research letter

Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.

Frequently Asked Questions

What does Midjourney's International Data Transfer via Policy Consent clause do?

This provision asserts that consent to the privacy policy itself, combined with data submission, serves as the legal mechanism authorizing international data transfers. For EEA and UK users, the policy separately references standard contractual clauses as the transfer mechanism, which is the operative legal basis under GDPR; reliance on policy consent alone as a transfer mechanism may warrant evaluation against …

How does this clause affect you?

Under these terms, personal data may be transferred to and processed in jurisdictions with different data protection laws. For EEA and UK users, the policy separately states that standard contractual clauses are used to safeguard such transfers, providing an additional legal mechanism beyond general policy consent.

Is ConductAtlas affiliated with Midjourney?

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