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
The clause establishes the operational scope of data disclosure beyond Midjourney's direct control, specifying categories of recipients and their functional purposes. This authorization defines how user information flows through the service delivery infrastructure and third-party business relationships.
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 →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
We may share your personal information with third parties in the following circumstances: With service providers who perform services on our behalf, such as data analytics, marketing, customer service, and technology services. With financial partners, including banks, brokerage firms, and payment pr...
We may share your information with third parties 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 your information with business partners who offer products or services that...
We may also share your personal information with third parties that assist us in providing our services, or where we are under an obligation to report to. But rest assured: we will only ever share your personal information in the limited circumstances described in this Policy.
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"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
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.
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The clause establishes the operational scope of data disclosure beyond Midjourney's direct control, specifying categories of recipients and their functional purposes. This authorization defines how user information flows through the service delivery infrastructure and third-party business relationships.
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.
ConductAtlas has identified this type of provision across 7 platforms. See the full comparison.
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