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The policy categorizes user-submitted prompts, including text, images, spoken-input summaries, photos, videos, documents, and messages, as personally identifiable information subject to collection and the policy's described uses.
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 establishes that prompts and all user-submitted content are treated as personal data, meaning they are subject to the policy's data sharing, retention, and ML training data collection disclosures. The inclusion of spoken-input summaries indicates that voice-derived content processed into text is also within scope.
The agreement establishes that all content submitted to Midjourney's services, including text prompts, images, videos, documents, spoken-input summaries, and messages, is collected as personally identifiable information and is subject to the policy's data use, sharing, and retention terms.
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"Personally identifiable information may include, but is not limited to: Your user name for the Services Prompts that you provide (including text, images, and those generated from spoken input and summarized into text), and other content such as photos, videos, documents, and messages that you input into the ServicesExcerpt from Midjourney's Privacy Policy
1. REGULATORY LANDSCAPE: The collection of prompts and user-generated content as personal data implicates GDPR data minimization and purpose limitation principles for EEA and UK users, enforced by relevant supervisory authorities. Under the CCPA, this content falls within the identifiers and sensory data categories disclosed in the policy's data table. The FTC Act is relevant at the federal level regarding adequacy of disclosure. 2. GOVERNANCE EXPOSURE: Medium. The broad scope of content classified as personally identifiable information, including all prompt types and spoken-input summaries, means that any content submitted to the platform is subject to data sharing and ML training disclosures. Organizations using Midjourney for business purposes should assess whether submitted content contains confidential or sensitive information. 3. JURISDICTION FLAGS: EEA and UK users have the strongest protections regarding purpose limitation for personal data collected in this category. California users have CCPA access and deletion rights that extend to this content. Organizations in jurisdictions with sector-specific privacy requirements (healthcare, financial services, legal) should evaluate whether sensitive content submitted as prompts is adequately protected. 4. CONTRACT AND VENDOR IMPLICATIONS: Business users and enterprise accounts should assess the risk of submitting proprietary, confidential, or regulated content as prompts given that this content is classified as personal data subject to sharing with service providers and analytics partners. Vendor agreements should address the treatment of prompt content and whether it is excluded from ML training data. 5. COMPLIANCE CONSIDERATIONS: Compliance teams deploying Midjourney in enterprise contexts should implement policies restricting the submission of personal, confidential, or regulated information as prompts. Data mapping should include prompt content as a personal data category with Midjourney identified as a data controller or processor. For GDPR-governed deployments, a data protection impact assessment may be warranted given the breadth of content categories classified as personal data.
Regulatory citations, enforcement risk, and due diligence action items.
Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
This provision establishes that prompts and all user-submitted content are treated as personal data, meaning they are subject to the policy's data sharing, retention, and ML training data collection disclosures. The inclusion of spoken-input summaries indicates that voice-derived content processed into text is also within scope.
The agreement establishes that all content submitted to Midjourney's services, including text prompts, images, videos, documents, spoken-input summaries, and messages, is collected as personally identifiable information and is subject to the policy's data use, sharing, and retention terms.
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