Figma · Figma Privacy Policy (Superseded URL) · View original document ↗

AI Content Training via Administrator Toggle

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Document Record

What it is

The policy states that Customer Content may be used to train Figma's AI models when the 'Content Training' setting is enabled by an administrator, with de-identification and aggregation steps applied to the data used for training.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision establishes that the use of Customer Content for AI model training is governed by an administrative setting, meaning the decision rests with organizational administrators rather than individual end users in enterprise contexts. The policy does not disclose the default state of this toggle in its text, which is a material operational detail for compliance teams assessing data processing scope.

Interpretive note: The policy does not disclose the default state of the Content Training toggle, and the scope of de-identification measures applied to training data is not specified in the policy text.

Recent Activity

This document changed recently

Medium May 28, 2026

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 →

Consumer impact (what this means for users)

Under this provision, Customer Content including design materials and any voice data captured through Figma voice features may be used for AI training when the Content Training setting is active. Individual end users in organizational accounts may not control this setting directly, as it is described as an administrative user setting.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Opt Out of Arbitration
    Log into your Figma account, navigate to administrative user settings, and locate the 'Content Training' toggle. Disable the toggle to prevent Customer Content from being used for AI model training.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
Improving our Services through artificial intelligence. This includes: if "Content Training" is toggled on within your administrative user settings, Customer Content and where we act as a controller (e.g. when processing Usage Data). We take steps to de-identify and aggregate data to protect your privacy for data we use to train AI models.

Excerpt from Figma's Privacy Policy (Superseded URL)

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1. REGULATORY LANDSCAPE: This provision implicates GDPR Article 6 legitimate interests as the stated legal basis, and engages CCPA provisions regarding the use of personal information for purposes beyond the primary service delivery context. The EU AI Act may also be relevant to the extent Figma's AI models are classified under its risk categories, though the policy does not address this. The FTC holds enforcement jurisdiction over unfair or deceptive practices related to AI data use for U.S. users. 2. GOVERNANCE EXPOSURE: Medium. The provision asserts legitimate interests as the legal basis for AI training on Customer Content, but under GDPR, legitimate interests requires a documented balancing test weighing Figma's interests against data subjects' rights. The policy asserts this basis without disclosing the balancing outcome. Additionally, the policy does not specify the default state of the Content Training toggle, leaving enterprise compliance teams unable to determine their current processing exposure from the policy text alone. 3. JURISDICTION FLAGS: EU and UK users have heightened exposure given GDPR and UK GDPR requirements around legitimate interests documentation and data subject rights regarding automated processing. California users may have CCPA rights to opt out of uses of personal information beyond the original service context. Enterprise customers subject to their own GDPR or CCPA obligations should assess whether their use of Figma constitutes a processor or controller relationship with respect to this AI training data use. 4. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers reviewing their Figma agreements should confirm whether the Data Processing Addendum addresses the AI training data use and what processor versus controller designations apply. Procurement teams should verify the default state of the Content Training toggle through direct product testing or written confirmation from Figma, as the policy text does not disclose this. Contracts with clients whose data is processed in Figma may need to be reviewed to ensure AI training disclosure obligations are satisfied. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should audit the current Content Training toggle state for all organizational accounts and document the configuration decision. Data mapping exercises should capture whether Customer Content qualifies as personal data under applicable law and whether it flows into AI training pipelines. If the toggle is or was enabled, data subject rights requests related to AI training data use may require specific process design to address.

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Applicable agencies

  • FTC
    The FTC holds enforcement jurisdiction over Figma's DPF compliance and unfair or deceptive practices related to AI data use for U.S. users
    File a complaint →

Provision details

Document information
Document
Figma Privacy Policy (Superseded URL)
Entity
Figma
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-015821
Document ID
CA-D-00544
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
f7f03821eec4a58f9dc0198f7828ff49a980d5d548d3fa82093da85a7a1559da
Analysis generated
July 9, 2026 08:53 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Figma
Document: Figma Privacy Policy (Superseded URL)
Record ID: CA-P-015821
Captured: 2026-07-09 08:53:35 UTC
SHA-256: f7f03821eec4a58f…
URL: https://conductatlas.com/platform/figma/figma-privacy-policy-superseded-url/provision/CA-P-015821/ai-content-training-via-administrator-toggle/
Accessed: July 24, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

Governance intelligence across arbitration, AI governance, data rights, indemnification, and retention
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Frequently Asked Questions

What does Figma's AI Content Training via Administrator Toggle clause do?

This provision establishes that the use of Customer Content for AI model training is governed by an administrative setting, meaning the decision rests with organizational administrators rather than individual end users in enterprise contexts. The policy does not disclose the default state of this toggle in its text, which is a material operational detail for compliance teams assessing data processing …

How does this clause affect you?

Under this provision, Customer Content including design materials and any voice data captured through Figma voice features may be used for AI training when the Content Training setting is active. Individual end users in organizational accounts may not control this setting directly, as it is described as an administrative user setting.

Is ConductAtlas affiliated with Figma?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Figma.