Adobe Firefly vs. Midjourney: data protection per plan

not publicly documented (the page on EU data transfers offers a DPA only "If you are an Adobe business customer (with Enterprise Licensing)"; individual and team plans are not mentioned there)

not publicly documented (the page on EU data transfers offers a DPA only "If you are an Adobe business customer (with Enterprise Licensing)"; individual and team plans are not mentioned there)

not publicly documented (the page on EU data transfers offers a DPA only "If you are an Adobe business customer (with Enterprise Licensing)"; individual and team plans are not mentioned there)

yes (on request, for business customers with Enterprise Licensing; DPA portal dpa.adobe.com only after signing in with an Adobe ID)

not publicly documented (no data processing agreement (DPA) is mentioned in the Terms of Service or Privacy Policy; www.midjourney.com/dpa returns 404. Help Center "Group Plans & Corporate Billing" (q9): Midjourney does not offer, among other things, "Terms and policy negotiations" or "Participation in vendor, supplier, or security processes (such as signing organization-required forms)")

not publicly documented (no data processing agreement (DPA) is mentioned in the Terms of Service or Privacy Policy; www.midjourney.com/dpa returns 404. Help Center "Group Plans & Corporate Billing" (q9): Midjourney does not offer, among other things, "Terms and policy negotiations" or "Participation in vendor, supplier, or security processes (such as signing organization-required forms)")

not publicly documented (no data processing agreement (DPA) is mentioned in the Terms of Service or Privacy Policy; www.midjourney.com/dpa returns 404. Help Center "Group Plans & Corporate Billing" (q9): Midjourney does not offer, among other things, "Terms and policy negotiations" or "Participation in vendor, supplier, or security processes (such as signing organization-required forms)")

not publicly documented (no data processing agreement (DPA) is mentioned in the Terms of Service or Privacy Policy; www.midjourney.com/dpa returns 404. Help Center "Group Plans & Corporate Billing" (q9): Midjourney does not offer, among other things, "Terms and policy negotiations" or "Participation in vendor, supplier, or security processes (such as signing organization-required forms)")

Generative AI: 'We do not analyze your content to train generative AI models, unless you choose to submit content to the Adobe Stock marketplace.' For product improvement (content analysis, not generative models), personal accounts can switch off the analysis in the account ('turn off content analysis for product improvement'). Sub-processor list (as of 2026-09-28): 'Customer content is not used to train Adobe AI models or partner generative AI models.' Gen AI approach page: customer data and content 'are not, and will not be, used to train generative AI models'.

As for Free: no training of generative models on customer content; content analysis for product improvement can be switched off for personal accounts. FAQ: 'No, we don't train on any Creative Cloud subscribers' personal content.' Sub-processor list (as of 2026-09-28): 'Customer content is not used to train Adobe AI models or partner generative AI models.' Gen AI approach page: customer data and content 'are not, and will not be, used to train generative AI models'.

Help Center: users of a business account (team, company or school account) are 'automatically opted out of content analysis for product improvement'; no toggle visible. Generative models are not trained on customer content. Sub-processor list (as of 2026-09-28): 'Customer content is not used to train Adobe AI models or partner generative AI models.' Gen AI approach page: customer data and content 'are not, and will not be, used to train generative AI models'.

According to the Help Center, business/enterprise profiles are automatically excluded from content analysis for product improvement; no training of generative models on customer content (see above). Sub-processor list (as of 2026-09-28): 'Customer content is not used to train Adobe AI models or partner generative AI models.' Gen AI approach page: customer data and content 'are not, and will not be, used to train generative AI models'. Pricing page: company-specific subscriptions with Firefly Custom Models and IP indemnification for selected outputs.

Under 'Applicability', the Privacy Policy lists, among the data collected, "data collected through the process of training Midjourney machine learning algorithms" and "data collected from third party sources" ("public databases, commercial data sources, and the public internet"). The Terms of Service (Section 4) grant Midjourney, for inputs and assets, a "perpetual, worldwide, non-exclusive, sublicensable no-charge, royalty-free, irrevocable copyright license to reproduce, prepare derivative works of, publicly display, publicly perform, sublicense, and distribute". Public Summary of Training Content (q5, Section 2.4): for the question "Was data from user interactions with the AI model (e.g. user input and prompts) used to train the model?" "Yes" is ticked (modalities text and image); addition: "Midjourney adheres to its Privacy Policy and Terms of Service, as applicable, for user data training." The AB2013 documentation (q6) names as a training source, among others, "data our users provide through use of the Midjourney service". An opt-out is not documented in the primary sources retrieved. Visibility: by default, content is publicly viewable and remixable (ToS Section 4: "By default, Your Content is publicly viewable and remixable"); according to the plan comparison and Stealth documentation, Stealth Mode is not available in this plan.

Under 'Applicability', the Privacy Policy lists, among the data collected, "data collected through the process of training Midjourney machine learning algorithms" and "data collected from third party sources" ("public databases, commercial data sources, and the public internet"). The Terms of Service (Section 4) grant Midjourney, for inputs and assets, a "perpetual, worldwide, non-exclusive, sublicensable no-charge, royalty-free, irrevocable copyright license to reproduce, prepare derivative works of, publicly display, publicly perform, sublicense, and distribute". Public Summary of Training Content (q5, Section 2.4): for the question "Was data from user interactions with the AI model (e.g. user input and prompts) used to train the model?" "Yes" is ticked (modalities text and image); addition: "Midjourney adheres to its Privacy Policy and Terms of Service, as applicable, for user data training." The AB2013 documentation (q6) names as a training source, among others, "data our users provide through use of the Midjourney service". An opt-out is not documented in the primary sources retrieved. Visibility: by default, content is publicly viewable and remixable (ToS Section 4: "By default, Your Content is publicly viewable and remixable"); according to the plan comparison and Stealth documentation, Stealth Mode is not available in this plan.

Under 'Applicability', the Privacy Policy lists, among the data collected, "data collected through the process of training Midjourney machine learning algorithms" and "data collected from third party sources" ("public databases, commercial data sources, and the public internet"). The Terms of Service (Section 4) grant Midjourney, for inputs and assets, a "perpetual, worldwide, non-exclusive, sublicensable no-charge, royalty-free, irrevocable copyright license to reproduce, prepare derivative works of, publicly display, publicly perform, sublicense, and distribute". Public Summary of Training Content (q5, Section 2.4): for the question "Was data from user interactions with the AI model (e.g. user input and prompts) used to train the model?" "Yes" is ticked (modalities text and image); addition: "Midjourney adheres to its Privacy Policy and Terms of Service, as applicable, for user data training." The AB2013 documentation (q6) names as a training source, among others, "data our users provide through use of the Midjourney service". An opt-out is not documented in the primary sources retrieved. Visibility: public by default (ToS Section 4); according to the plan comparison and Stealth documentation, Stealth Mode is available in this plan. ToS: Midjourney commits to "best efforts" not to publish assets created with Stealth; content created in public Discord channels remains visible to others.

Under 'Applicability', the Privacy Policy lists, among the data collected, "data collected through the process of training Midjourney machine learning algorithms" and "data collected from third party sources" ("public databases, commercial data sources, and the public internet"). The Terms of Service (Section 4) grant Midjourney, for inputs and assets, a "perpetual, worldwide, non-exclusive, sublicensable no-charge, royalty-free, irrevocable copyright license to reproduce, prepare derivative works of, publicly display, publicly perform, sublicense, and distribute". Public Summary of Training Content (q5, Section 2.4): for the question "Was data from user interactions with the AI model (e.g. user input and prompts) used to train the model?" "Yes" is ticked (modalities text and image); addition: "Midjourney adheres to its Privacy Policy and Terms of Service, as applicable, for user data training." The AB2013 documentation (q6) names as a training source, among others, "data our users provide through use of the Midjourney service". An opt-out is not documented in the primary sources retrieved. Visibility: public by default (ToS Section 4); according to the plan comparison and Stealth documentation, Stealth Mode is available in this plan. ToS: Midjourney commits to "best efforts" not to publish assets created with Stealth; content created in public Discord channels remains visible to others.

Privacy policy: 'The main locations where we process your personal information are the US and India.' Page on EU data transfers (2026-10-18): "The primary locations where Adobe handles and oversees your personal data are the US, Ireland, and India"; it does not describe an EU storage option, and the Gen AI approach page does not state any processing locations. Sub-processor list (as of 2026-09-28): hosting via AWS (US, EU, Australia, Singapore, Japan, India) and Microsoft Azure (US, EU, UK, Canada, India, Australia). Firefly partner models run in the US, the EU, the UK, Germany, Singapore, Malaysia, Indonesia and Saudi Arabia. A selectable EU data residency for Firefly is not documented.

See Firefly Free.

See Firefly Free.

See Firefly Free.

Data Deletion and Privacy FAQ (q7, as of 2026-09-03): "The personal information you provide is stored on Midjourney servers in the US." For data stored on Discord, the FAQ refers to Discord ("Discord is in control of all data you store on Discord"). Privacy Policy 2.5: processing also "at the Midjourney's operating offices and in any other places where the parties involved in the processing are located". A choice of region is not documented.

Data Deletion and Privacy FAQ (q7, as of 2026-09-03): "The personal information you provide is stored on Midjourney servers in the US." For data stored on Discord, the FAQ refers to Discord ("Discord is in control of all data you store on Discord"). Privacy Policy 2.5: processing also "at the Midjourney's operating offices and in any other places where the parties involved in the processing are located". A choice of region is not documented.

Data Deletion and Privacy FAQ (q7, as of 2026-09-03): "The personal information you provide is stored on Midjourney servers in the US." For data stored on Discord, the FAQ refers to Discord ("Discord is in control of all data you store on Discord"). Privacy Policy 2.5: processing also "at the Midjourney's operating offices and in any other places where the parties involved in the processing are located". A choice of region is not documented.

Data Deletion and Privacy FAQ (q7, as of 2026-09-03): "The personal information you provide is stored on Midjourney servers in the US." For data stored on Discord, the FAQ refers to Discord ("Discord is in control of all data you store on Discord"). Privacy Policy 2.5: processing also "at the Midjourney's operating offices and in any other places where the parties involved in the processing are located". A choice of region is not documented.

• Amazon Web Services (hosting; US, EU, AU, SG, JP, IN)
• Microsoft Azure (hosting; US, EU, UK, CA, IN, AU)
• Akamai, Cloudflare, Fastly (CDN)
• Firefly model partners: OpenAI (US, EU), Google (Gemini/Veo; US), Black Forest Labs (Flux; DE, US), Luma AI (US), Runway (US), ElevenLabs (UK, US), Topaz Labs (US), Kuaishou (Kling; Singapore), Features and Labels/fal.ai (SG, US, MY), BytePlus (Seedance; SG, MY, ID), Humain (Saudi Arabia)
• others as per the list (Okta, Splunk, CrowdStrike, New Relic, among others)

• see Firefly Free

• see Firefly Free

• see Firefly Free

• No list published. Privacy Policy 2.3 names categories: "Service Providers, Third Party Vendors, Consultants, and other Business Partners", payment service providers and analytics and advertising partners (cookies).

• No list published. Privacy Policy 2.3 names categories: "Service Providers, Third Party Vendors, Consultants, and other Business Partners", payment service providers and analytics and advertising partners (cookies).

• No list published. Privacy Policy 2.3 names categories: "Service Providers, Third Party Vendors, Consultants, and other Business Partners", payment service providers and analytics and advertising partners (cookies).

• No list published. Privacy Policy 2.3 names categories: "Service Providers, Third Party Vendors, Consultants, and other Business Partners", payment service providers and analytics and advertising partners (cookies).

Firefly Free: free of charge; daily generations (image, video, audio) with limits that reset daily; no number stated (pricing page DE, as of 2026-10-14)

Pricing page DE (monthly subscription, incl. VAT): Standard 10.98 EUR/month (2,000 credits), Pro 21.99 EUR (4,000), Pro Plus 54.99 EUR regular price (10,000; promotion 38.47 EUR in the first year if subscribed by 21 October, year not stated), Premium 219.98 EUR regular price (50,000; promotion 153.90 EUR). Unlimited standard image generation on paid plans. As of 2026-10-14.

Pricing page DE (excl. VAT, per licence, annual subscription paid monthly): Pro for Teams 18.48 EUR/month (4,000 credits), Pro Plus for Teams 46.21 EUR (10,000), Premium for Teams 184.86 EUR (50,000). According to the Help Center (as of 2026-10-07), credits are not shared between users (shared credits only for certain ETLA customers). As of 2026-10-14.

not publicly documented (pricing page DE, as of 2026-10-18: no Enterprise price; for enterprise-specific subscriptions only a reference to Firefly Custom Models and IP indemnification)

10 USD/month or 96 USD/year (8 USD/month with annual payment), as of 2026-10-14

30 USD/month or 288 USD/year (24 USD/month with annual payment), as of 2026-10-14

60 USD/month or 576 USD/year (48 USD/month with annual payment), as of 2026-10-14

120 USD/month or 1,152 USD/year (96 USD/month with annual payment), as of 2026-10-14

yes

yes

yes

yes

yes (Image and video generation; features per plan according to the plan comparison)

yes (Image and video generation; features per plan according to the plan comparison)

yes (Image and video generation; features per plan according to the plan comparison)

yes (Image and video generation; features per plan according to the plan comparison)