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Figma may use the content you submit through its AI tools to train and improve its AI systems. If you are on a paid Professional or Organizational plan, you can opt out of this use in your account settings.
This analysis describes what Figma'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
Design files submitted to Figma's AI features may contain proprietary business information, client work, or sensitive intellectual property, and this clause authorizes Figma to use that material to improve its AI unless users take affirmative steps to opt out.
Interpretive note: The adequacy of the opt-out framing as a legal basis under GDPR, and whether free-plan users have any equivalent right, is not fully resolved by the document language and may depend on regulatory interpretation.
The updated terms now restrict how Figma may use personal information from children. Children may only use the Services through a Figma for Education Enterprise agreement with their school, and Figma explicitly prohibits using children's personal information to train or improve AI services, serve targeted advertisements, or enable third-party tracking. Parents may contact Figma if they learn a child provided personal information without consent outside of an education agreement.
View change record →For individual users on free plans, this clause means their AI-submitted content may be used for AI training without a clear opt-out mechanism. Professional and organizational plan holders have an opt-out right, but it requires active exercise to prevent this use.
How other platforms handle this
You can choose to what extent we will use your personal information to personalize your Discord experience.
California residents under the age of 18 who are registered users of online sites, services, or applications have a right under California Business and Professions Code Section 22581 to remove, or request and obtain removal of, content or information they have publicly posted.
If you choose to reveal any personal information about yourself to other users, you do so at your own risk. We strongly encourage you to use caution in disclosing any personal information online.
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"We may use Customer Data and other information we collect to train, fine-tune, and improve our AI/ML models, including our AI features. For customers on Professional or Organizational plans, we provide the ability to opt out of having your Content used to train our AI models. If you opt out, we will not use your Content for this purpose.Excerpt from Figma's Privacy Policy (Superseded URL)
REGULATORY LANDSCAPE: This provision may require evaluation under GDPR Articles 5, 6, and 13, which require that personal data be processed for specified, explicit, and legitimate purposes and that data subjects be clearly informed of processing purposes at collection. The use of content for AI training may be assessed as a secondary purpose requiring a compatibility analysis or a separate valid legal basis. The UK Information Commissioner's Office and EU data protection authorities have issued guidance on AI training data that compliance teams should consult. The FTC also has authority over unfair or deceptive data practices in the US. GOVERNANCE EXPOSURE: High. The use of customer design content for AI model training raises significant questions about whether legitimate interests or contractual necessity provide adequate GDPR legal bases, particularly where the content belongs to organizational customers who may have their own data protection obligations to their clients. Enterprise agreements that do not explicitly address AI training use may create gaps between contractual commitments and policy permissions. JURISDICTION FLAGS: EU and UK users face the highest exposure given GDPR and UK GDPR requirements for clear legal bases and purpose limitation. California users may have CCPA rights implicated if AI training constitutes a use of personal information beyond the original collection purpose. Organizations in healthcare, financial services, or legal sectors may face additional regulatory constraints on permitting third-party AI training use of client-related content. CONTRACT AND VENDOR IMPLICATIONS: Procurement teams evaluating Figma as a vendor should confirm that enterprise data processing agreements explicitly restrict AI training use of organizational content, or that the opt-out has been formally exercised and documented. The policy asserts an opt-out right for Professional and Organizational plans, but the mechanism and its operational reliability should be verified during vendor assessment. Liability for unauthorized use of third-party intellectual property submitted to AI features may also warrant review. COMPLIANCE CONSIDERATIONS: Compliance teams should document whether the AI training opt-out has been exercised for all relevant organizational accounts. Data protection impact assessments may be warranted for organizations processing sensitive or regulated content through Figma's AI features. Internal policies governing employee use of Figma AI tools should be reviewed to ensure alignment with organizational data governance obligations.
Regulatory citations, enforcement risk, and due diligence action items.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
Design files submitted to Figma's AI features may contain proprietary business information, client work, or sensitive intellectual property, and this clause authorizes Figma to use that material to improve its AI unless users take affirmative steps to opt out.
For individual users on free plans, this clause means their AI-submitted content may be used for AI training without a clear opt-out mechanism. Professional and organizational plan holders have an opt-out right, but it requires active exercise to prevent this use.
ConductAtlas has identified this type of provision across 295 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Figma.