Figma · Figma Privacy Policy (Superseded URL) · View original document ↗

DPF Agent Transfer Liability Retention

High severity Explicitdocumentlanguage Common · 223 of 352 platforms
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Recent governance activity Figma recorded 8 documented changes in the last 30 days.
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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

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 →

How other platforms handle this

Instacart Medium

Any access to or use of the Services or goods through your account by others, including your spouse, dependents, Recipients, and any access by AI Agents you enable or that operate on your behalf...

Twilio Medium

Indemnifying Party will not settle any Claim for which it has an obligation to indemnify under this Section 6 admitting liability or fault on behalf of Indemnified Party, nor create any obligation on behalf of Indemnified Party without Indemnified Party's prior written consent...

Whatnot Medium

A complete release for Whatnot from any liability and/or damages related to your Promotion.

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▸ View Original Clause Language DOCUMENT RECORD
"
If we have received your personal information in the U.S. and subsequently transfer that information to a third party acting as an agent, and such third party agent processes your personal information in a manner inconsistent with the DPF Principles, we will remain liable...

— Excerpt from Figma's Figma Privacy Policy (Superseded URL)

Applicable regulations

FTC Act Section 5
United States Federal

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Figma Privacy Policy (Superseded URL)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-046970
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-046970
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-046970/dpf-agent-transfer-liability-retention/
Accessed: July 12, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Figma's DPF Agent Transfer Liability Retention clause do?

The clause states: “If we have received your personal information in the U.S. and subsequently transfer that information to a third party acting as an agent, and such third party agent processes your personal information in a manner inconsistent with the DPF Principles, we will remain liable...”

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 223 platforms. See the full comparison.

Is ConductAtlas affiliated with Figma?

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