Midjourney

Data-handling profile

Trains on input

Yes, on the consumer tier (enterprise tier excluded)

Retention

May use user-submitted materials (prompts/images) to provide/improve the service and train models unless the user opts out via account settings; deletion requests are honored for future retraining but do not retroactively alter already-trained models. Chat/generation logs purged after 90 days; personal data otherwise kept as long as needed for stated purposes/legal compliance. Default operation is public (Discord-based); Stealth Mode (Pro/Mega only) hides future generations but not prior public images.

Data region

US

Certifications

none listed

DPA available

No

Breach history

none known

EU AI Act

Default-public image generation, opt-out (not opt-in) training model, and no identified SOC 2/ISO certification or formal DPA give Midjourney a comparatively weak enterprise data-governance posture under the EU AI Act; independent privacy scorecards rate it low (e.g., 'Privacy Score 38/100').

Sources

• https://docs.midjourney.com/hc/en-us/articles/32083472637453-Privacy-Policy
• https://docs.midjourney.com/hc/en-us/articles/32083055291277-Terms-of-Service
• https://docs.midjourney.com/hc/en-us/articles/32084462534541-Data-Deletion-and-Privacy-FAQ
• https://terms.law/Privacy-Watchdog/ai-services/midjourney/
• https://verifywise.ai/ai-trust-index/midjourneylink no longer resolves

Every fact above is drawn from the vendor's public documentation, reviewed by a human, and version-stamped. Monitored daily for changes. 1 of these 5 links no longer resolve. We record what we relied on rather than deleting it, so the trail stays auditable — but a struck-through source cannot be re-checked today.

Control mapping

Obligations this vendor triggers, each attributable to the fact it rests on — for your supplier register, not a compliance determination.

• EU AI Act Art. 50 — Transparency obligations for AI systemsattention

  trains_on_input = consumer_tier. Inputs may be reused for model training — users interacting with this system need to be informed accordingly.

• EU AI Act Art. 26 — Obligations of deployers of high-risk AI systemsapplies

  Applies to your organisation as deployer, independent of vendor. Assign human oversight, keep logs, and monitor operation where this tool is used in a high-risk context (Annex III duties apply from 2 Dec 2027).

• ISO/IEC 27001 A.5.19 — Information security in supplier relationshipsapplies

  Midjourney processes organisational data as a supplier. Include this vendor in the supplier register and risk assessment.

• ISO/IEC 27001 A.5.20 — Addressing information security within supplier agreementsgap

  dpa_available = false. No DPA identified — security and processing terms are not contractually established.

• ISO/IEC 27001 A.5.23 — Information security for use of cloud servicesattention

  Cloud AI service; trains_on_input = consumer_tier. Data submitted to this cloud service may be retained or reused — define acceptable-use rules for it.

• ISO/IEC 42001 A.10.3 — Suppliers of AI systems and servicesapplies

  No certifications listed. No AI-management certification identified; assurance must come from your own supplier assessment.

• GDPR Art. 44–49 — International transfers of personal dataattention

  data_region = US. Processing occurs outside the EU/EEA — a transfer mechanism (SCCs or adequacy) must be in place.

• NIS2 Art. 21(2)(d) — Supply chain securityapplies

  AI vendor forms part of your ICT supply chain. In scope for entities covered by NIS2; include in supply-chain risk measures.

• DORA Art. 28 — General principles for ICT third-party riskapplies

  AI vendor is an ICT third-party service provider. For financial entities: register of information and contractual requirements apply.

Change history

No material changes recorded since monitoring began.