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The policy states that personal data held about service users may be transferred as an asset in the context of a merger, acquisition, sale of assets, bankruptcy, or similar corporate transaction.
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 user personal data is treated as a transferable asset in corporate transactions. The policy does not specify whether users will be notified prior to or following such a transfer, or whether the successor entity's privacy practices will be required to conform to this policy.
Under these terms, personal data may be transferred to a successor company in connection with a merger, acquisition, bankruptcy, or asset sale. The policy does not describe a specific notification mechanism or opt-out right in connection with business transfer data sharing.
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"For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.Excerpt from Midjourney's Privacy Policy
1. REGULATORY LANDSCAPE: Business transfer data sharing implicates GDPR requirements for lawful basis and notice in the event of a controller change for EEA and UK users. The FTC has addressed business transfer data practices in prior enforcement actions regarding privacy policy continuity. The CCPA requires disclosure of business transfers as a data sharing category, which this provision satisfies. 2. GOVERNANCE EXPOSURE: Low to Medium. The provision is standard commercial boilerplate but creates operational exposure if a successor entity adopts materially different privacy practices without adequate user notice. GDPR may require a new lawful basis assessment and notification to data subjects in the event of a controller change. 3. JURISDICTION FLAGS: EEA and UK users have the strongest protections against unnoticed changes in data controller identity under GDPR. California users have CCPA rights that would apply against any successor entity to the extent personal data is included in the transfer. 4. CONTRACT AND VENDOR IMPLICATIONS: Business users and enterprise accounts should assess whether their vendor agreements with Midjourney address privacy policy continuity obligations in the event of a business transfer. Data processing agreements should specify obligations that transfer to any successor entity. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should monitor for corporate transaction announcements involving Midjourney that may trigger data controller change notification obligations under GDPR. Data subject rights processes should be reviewed to confirm they will remain operable through any transition period.
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This provision establishes that user personal data is treated as a transferable asset in corporate transactions. The policy does not specify whether users will be notified prior to or following such a transfer, or whether the successor entity's privacy practices will be required to conform to this policy.
Under these terms, personal data may be transferred to a successor company in connection with a merger, acquisition, bankruptcy, or asset sale. The policy does not describe a specific notification mechanism or opt-out right in connection with business transfer data sharing.
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