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
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.
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 →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
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.
Your personal information may be transferred to, processed and stored in countries other than the country in which you are resident, including the United States, Australia, Canada, the European Union and the UK. We take appropriate safeguards to protect your personal information in accordance with t...
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.
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"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
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.
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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.
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.
ConductAtlas has identified this type of provision across 3 platforms. See the full comparison.
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