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

Machine Learning Training Data Collection

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Document Record

What it is

The policy states that personal data collected during the process of training Midjourney's machine learning algorithms is within the scope of this privacy policy, in addition to data collected through the platform services and websites.

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 establishes that machine learning training data collection is an explicitly disclosed data processing activity governed by this policy. The policy does not separately articulate purpose limitations, retention terms, or opt-out mechanisms specific to the use of user data in ML training, which may require evaluation under applicable data minimization and purpose limitation principles in GDPR-governed jurisdictions.

Interpretive note: The policy discloses ML training data collection within its scope but does not separately specify the lawful basis, retention terms, or opt-out mechanism for this processing activity, creating interpretive ambiguity about whether existing general bases are sufficient under applicable law.

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)

The agreement establishes that data collected during Midjourney's machine learning algorithm training is subject to this policy, indicating that user-submitted content including prompts and images may be within scope of this training data category. The policy does not provide a separate opt-out mechanism specifically for the use of personal data in machine learning training.

Cross-platform context

See how other platforms handle Machine Learning Training Data Collection and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
Applicability: This Policy applies to personal data that Midjourney collects, uses, and discloses and which may include: (i) data collected through the Services, (ii) data collected through the process of training Midjourney machine learning algorithms, (iii) data collected through Midjourney websites, and (iv) data collected from third party sources.

Excerpt from Midjourney's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1.

Insight

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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-013919
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-013919
Captured: 2026-05-12 04:55:54 UTC
SHA-256: 31a78fe46275c58b…
URL: https://conductatlas.com/platform/midjourney/midjourney-privacy-policy/provision/CA-P-013919/machine-learning-training-data-collection/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Midjourney's Machine Learning Training Data Collection clause do?

This provision establishes that machine learning training data collection is an explicitly disclosed data processing activity governed by this policy. The policy does not separately articulate purpose limitations, retention terms, or opt-out mechanisms specific to the use of user data in ML training, which may require evaluation under applicable data minimization and purpose limitation principles in GDPR-governed jurisdictions.

How does this clause affect you?

The agreement establishes that data collected during Midjourney's machine learning algorithm training is subject to this policy, indicating that user-submitted content including prompts and images may be within scope of this training data category. The policy does not provide a separate opt-out mechanism specifically for the use of personal data in machine learning training.

Is ConductAtlas affiliated with Midjourney?

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