Midjourney · Midjourney Privacy Policy · View original document ↗

International Data Transfer

Low severity Rare · 3 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

Your personal data may be transferred to and stored on servers in other countries, including places where data protection laws may be weaker than in your home country.

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 the operational framework for international data processing, specifying that data may be maintained across multiple jurisdictions while requiring the Company to implement security measures and maintain compliance with stated privacy standards regardless of where processing 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 →

Consumer impact (what this means for users)

By using Midjourney and agreeing to this Policy, you consent to your data being transferred internationally. For EEA and UK users, Midjourney uses Standard Contractual Clauses as a legal safeguard for these transfers.

How other platforms handle this

Windsurf Medium

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 ...

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...

OpenAI Medium

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.

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▸ 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. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

— Excerpt from Midjourney's Midjourney Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

Midjourney relies on SCCs (Standard Contractual Clauses) for EEA/UK data transfers and on user consent via policy acceptance for other jurisdictions. Post-Schrems II, SCCs alone may be insufficient without a Transfer Impact Assessment (TIA); compliance teams should request evidence of TIAs and supplementary safeguards. The blanket consent approach for non-EEA jurisdictions may not satisfy adequacy standards in countries with stricter transfer rules.

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC oversees cross-border data transfer practices and can act against companies that fail to maintain adequate privacy protections for US consumers' data sent abroad.
    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-000673
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-000673
Captured: 2026-03-20 12:17:21 UTC
SHA-256: 17818e1b0919b17f…
URL: https://conductatlas.com/platform/midjourney/midjourney-privacy-policy/international-data-transfer/
Accessed: May 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Low
Categories

Other risks in this policy

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Frequently Asked Questions

What does Midjourney's International Data Transfer clause do?

The clause establishes the operational framework for international data processing, specifying that data may be maintained across multiple jurisdictions while requiring the Company to implement security measures and maintain compliance with stated privacy standards regardless of where processing occurs.

How does this clause affect you?

By using Midjourney and agreeing to this Policy, you consent to your data being transferred internationally. For EEA and UK users, Midjourney uses Standard Contractual Clauses as a legal safeguard for these transfers.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 3 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.