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
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.
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 →"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
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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 …
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.
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