CA-C-000204
Figma — Figma Terms of Service
Entity
Date detected
March 31, 2026
Effective date
March 31, 2026
Severity
Low
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What Changed

Figma updated their Terms of Service on March 31, 2026 by reorganizing some navigation links in their document footer or menu. Specifically, they removed the 'Candidate Privacy Notice' link and moved some privacy-related links (like 'Privacy Policy,' 'Data Processing Addendum,' and 'Figma Subprocessors') out of the visible navigation, replacing them with trademark and intellectual property links. This is primarily a structural reorganization of how Figma presents supplementary resources rather than a change to any substantive rights or obligations.

Why It Matters

Business users and compliance teams that relied on Figma's Terms of Service to quickly navigate to the Data Processing Addendum and Subprocessors list can no longer do so, which may complicate vendor management documentation. The underlying documents are likely still available but must now be located independently.

Consumer Impact

Figma reorganized navigation links within its Terms of Service, removing quick-access links to its Privacy Policy, Data Processing Addendum, Subprocessors list, and Candidate Privacy Notice, while adding links to trademark and intellectual property resources. For most everyday users, this has no practical effect on their rights or data. Business users who relied on these links to quickly locate Figma's privacy documentation should search Figma's Privacy & Trust Center directly to find those resources.

Institutional Analysis (Compliance & legal intelligence)

Assessment

Figma removed footer/navigation links within its Terms of Service to the Privacy Policy, Data Processing Addendum, and Subprocessors list, replacing them with IP/trademark links. This does not alter any substantive contractual obligation but may affect how quickly compliance teams can locate key vendor documents. Organizations using Figma as a data processor under GDPR Art. 28 should verify that DPA and Subprocessors documentation remains accessible via Figma's Trust Center. No immediate escalation required, but update any internal vendor documentation links.

Regulatory Exposure

Watcher tier. 1) GDPR Art. 28(3) requires controllers to maintain a current DPA with processors; the removal of the DPA link does not void the DPA but may complicate access documentation. Art. 28(3)(c) GDPR requires subprocessor lists to be accessible — removal of the Figma Subprocessors link warrants confirmation that the list remains accessible elsewhere. 2) Cal. Civ. Code §1798.135 (CCPA/CPRA) requires privacy notices to be reasonably accessible; removal of the Privacy Policy link from ToS navigation should be verified against accessibility requirements. 3) UK GDPR Art. 28 mirrors EU obligations for UK-based controllers. 4) EDPB Guidelines 05/2020 on consent and transparency may be tangentially relevant if users can no longer easily navigate to the Privacy Policy from the ToS. No active enforcement action identified as directly applicable.

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ConductAtlas provides verified policy intelligence sourced directly from platform documents. All analysis is intended to support, not replace, legal and compliance review. Record CA-C-000204.

Evidence Verification

✓ Verified
Previous Version
bb36744c1a7d9f810f32e27ad2c4a1bf6daaeba748418fce1bd23d32a358a5d4
March 19, 2026 14:56 UTC
✓ Verified
Current Version
3c5c3a542a3cdfa8e6517354a826be1ba0c6a72197d040578504ec3db92cbd20
March 31, 2026 06:04 UTC
✓ Verified
Change Detected
March 31, 2026 06:04 UTC
✓ Verified
Source Document
https://www.figma.com/legal/tos/
How to Cite
ConductAtlas Policy Archive
Entity: Figma | Document: Figma Terms of Service | Record: CA-C-000204
Captured: 2026-03-31 06:04:03 UTC
URL: https://conductatlas.com/change/2026-03-31-figma-figma-terms-of-service-204/
Accessed: April 4, 2026

Full Changes

-2 sentences removed 2 sentences modified
View complete diff →

Document Context

Document
Figma Terms of Service
Entity
Figma
Captured
March 31, 2026
Source URL
https://www.figma.com/legal/tos/
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