Midjourney · Midjourney Privacy Policy · View original document ↗

Sensory Data (Uploaded Images) Collection and Disclosure

Medium severity Unique · 0 of 325 platforms
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Recent governance activity Midjourney recorded 5 documented changes in the last 30 days.
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Document Record

What it is

Images you upload to Midjourney are classified as sensory data and are both collected and disclosed to third parties.

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)

The classification of uploaded images as sensory data establishes the legal category under which these materials are processed and governed within Midjourney's data handling procedures. This categorization determines which privacy obligations, retention policies, and disclosure rules apply to image content.

Recent Activity

This document changed recently

High Apr 21, 2026

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 →

Consumer impact (what this means for users)

Any images you upload to Midjourney's services may be shared with third-party partners. Users should be aware that uploaded images are treated as personal data and are subject to disclosure, and should avoid uploading images containing sensitive or identifiable information if they wish to limit exposure.

How other platforms handle this

Meta Medium

We may access, preserve, and share information with regulators, law enforcement, or others if we believe it is reasonably necessary to: detect, prevent, and address fraud and other illegal activity; protect ourselves, you, and others, including as part of investigations; and prevent death or imminen...

YouTube Kids Medium

We will share individual user information with companies, organizations or individuals outside of Google if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to: meet any applicable law, regulation, legal process or enforceable govern...

Tabnine Medium

Tabnine is headquartered in the United States and operates globally. If you are located outside the United States, your personal data may be transferred to and processed in the United States or other countries that may not provide the same level of data protection as your home country. We rely on ap...

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▸ View Original Clause Language DOCUMENT RECORD
"
8 Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. YES (only images you upload to our services) YES

— Excerpt from Midjourney's Midjourney Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

The CCPA disclosure table confirms sensory data (Category 8 — 'only images you upload') is both collected and disclosed. While Midjourney separately states it does not collect biometric information, uploaded images may contain biometric-adjacent content. CPRA-covered entities may need to assess whether image data constitutes sensitive personal information requiring enhanced protections. EU compliance teams should evaluate whether image uploads trigger GDPR Article 9 special category obligations.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC oversees consumer data handling practices, including the collection and sharing of user-generated content such as uploaded images.
    File a complaint →

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Midjourney Privacy Policy
Entity
Midjourney
Document last updated
May 5, 2026
Tracking information
First tracked
March 20, 2026
Last verified
March 20, 2026
Record ID
CA-P-000671
Document ID
CA-D-00094
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
17818e1b0919b17fb76e08c77136c0c847e572fa678a7ae481892a9ba9bba0cb
Analysis generated
March 20, 2026 12:17 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Midjourney
Document: Midjourney Privacy Policy
Record ID: CA-P-000671
Captured: 2026-03-20 12:17:21 UTC
SHA-256: 17818e1b0919b17f…
URL: https://conductatlas.com/platform/midjourney/midjourney-privacy-policy/sensory-data-uploaded-images-collection-and-disclosure/
Accessed: May 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Midjourney's Sensory Data (Uploaded Images) Collection and Disclosure clause do?

The classification of uploaded images as sensory data establishes the legal category under which these materials are processed and governed within Midjourney's data handling procedures. This categorization determines which privacy obligations, retention policies, and disclosure rules apply to image content.

How does this clause affect you?

Any images you upload to Midjourney's services may be shared with third-party partners. Users should be aware that uploaded images are treated as personal data and are subject to disclosure, and should avoid uploading images containing sensitive or identifiable information if they wish to limit exposure.

Is ConductAtlas affiliated with Midjourney?

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