Midjourney · Midjourney Privacy Policy · View original document ↗

Third-Party Data Sharing with Service Providers and Partners

Medium severity High confidence Explicitdocumentlanguage Rare · 7 of 325 platforms
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Document Record

What it is

Midjourney shares your personal data with outside companies that help run its services, such as payment processors and marketing firms, and also with business partners for co-branded or joint marketing purposes.

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)

Your personal data, including usage information and potentially prompts or images, may be accessible to a range of third-party companies beyond Midjourney itself, each of which operates under its own privacy practices.

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 o…

Consumer impact (what this means for users)

Personal data you provide to Midjourney may be shared with service providers and business partners, expanding the number of entities that have access to your information and creating additional data exposure beyond Midjourney's own environment.

How other platforms handle this

HubSpot Medium

We may share your personal data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. We may also share your personal data with advertising partners to display relevant advertising to y...

Ideogram Medium

We may share your personal information with third-party vendors and service providers that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.

Steam Medium

In order to provide you with services, Valve needs to share some data with the publisher or developer of the game (for example to verify your ownership of the game and register your Steam ID with the publisher), or with other third parties that Valve works with to provide services to you. Valve will...

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▸ View Original Clause Language DOCUMENT RECORD
"
We may share your information with third-party vendors and service providers that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. We may also share information with business partners with whom we offer co-branded services or engage in joint marketing activities.

— Excerpt from Midjourney's Midjourney Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: Third-party data sharing engages GDPR Articles 28 and 44 regarding data processor agreements and cross-border transfer mechanisms for EU and UK users. Under CCPA, sharing personal information with third parties for commercial purposes may constitute a sale or share requiring opt-out rights. The FTC Act applies to any deceptive or unfair disclosures about third-party sharing practices. GOVERNANCE EXPOSURE: Medium. The policy discloses third-party sharing at a category level but does not identify specific vendors or the data types shared with each category of recipient, which is standard industry practice but limits transparency for users seeking to understand the full scope of data flows. JURISDICTION FLAGS: EU and UK users are entitled under GDPR to information about the identity of data recipients or categories of recipients, and the adequacy of cross-border transfer safeguards for any transfers to US-based vendors. California residents have the right to know the categories of third parties with whom personal information is shared and may have opt-out rights if sharing constitutes a sale under CCPA. CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should assess whether Midjourney maintains Data Processing Agreements with its subprocessors as required under GDPR Article 28, and whether those agreements are available for review. The reference to business partners in joint marketing contexts raises questions about whether data shared in that context is subject to the same contractual protections as data shared with service providers. COMPLIANCE CONSIDERATIONS: Legal teams should request a list of Midjourney's subprocessors if required for their own vendor risk management programs. California-focused compliance teams should assess whether the business partner sharing constitutes a sale or share under CPRA and whether a do-not-sell mechanism is adequately provided. Data mapping should capture third-party sharing flows for all data categories collected.

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC has jurisdiction over third-party data sharing disclosures and whether they constitute unfair or deceptive practices under the FTC Act.
    File a complaint →
  • State AG
    State attorneys general in California and other states with consumer privacy laws may have jurisdiction over third-party data sharing practices that implicate state privacy statutes.
    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
May 10, 2026
Last verified
May 10, 2026
Record ID
CA-P-008438
Document ID
CA-D-00094
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
085149c3aba2fc8bdc3ab384b862f677b526cd4a63ee34e84c90983f3aaca29e
Analysis generated
May 10, 2026 06:36 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Midjourney
Document: Midjourney Privacy Policy
Record ID: CA-P-008438
Captured: 2026-05-10 06:36:35 UTC
SHA-256: 085149c3aba2fc8b…
URL: https://conductatlas.com/platform/midjourney/midjourney-privacy-policy/third-party-data-sharing-with-service-providers-and-partners/
Accessed: May 14, 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 Third-Party Data Sharing with Service Providers and Partners clause do?

Your personal data, including usage information and potentially prompts or images, may be accessible to a range of third-party companies beyond Midjourney itself, each of which operates under its own privacy practices.

How does this clause affect you?

Personal data you provide to Midjourney may be shared with service providers and business partners, expanding the number of entities that have access to your information and creating additional data exposure beyond Midjourney's own environment.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 7 platforms. See the full comparison.

Is ConductAtlas affiliated with Midjourney?

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