Figma transfers EU, UK, and Swiss user data to the US and other countries using Standard Contractual Clauses, which are a legally recognized mechanism for protecting personal data during international transfers.
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
EU and UK users' personal data is processed by Figma in the US, and the adequacy of the transfer mechanism used is subject to ongoing regulatory scrutiny, meaning users should understand that their data crosses borders and the legal protections that apply.
Interpretive note: The document does not specify which SCC module is used or whether transfer impact assessments have been conducted, creating some uncertainty about the completeness of the transfer compliance framework.
If you are in the EU or UK, your personal data is transferred to the US under Standard Contractual Clauses, which provide a baseline legal framework for data protection but are subject to regulatory review and may not eliminate all risks associated with US government access to data.
How other platforms handle this
When we transfer personal data outside the European Economic Area, United Kingdom, or Switzerland, we use appropriate safeguards, including Standard Contractual Clauses approved by the European Commission, to ensure your data is protected.
Canva is headquartered in Australia and has operations and service providers in a number of countries. When we transfer personal information outside of the country in which it was collected, we take steps to ensure that appropriate safeguards are in place to protect your information, including the u...
Personal data collected by Unity may be transferred to and processed in countries outside of the European Economic Area, including the United States, where data protection laws may differ from those in your country. Where we transfer personal data from the EEA or the UK, we rely on appropriate safeg...
Monitoring
Figma has changed this document before.
Receive same-day alerts, structured change summaries, and monitoring for up to 10 platforms.
"When we transfer personal information from the European Economic Area, United Kingdom, or Switzerland to countries that have not been found to provide an adequate level of protection under applicable law, we take steps to provide appropriate safeguards, including through the use of Standard Contractual Clauses approved by the European Commission.— Excerpt from Figma's Figma Privacy Policy
REGULATORY LANDSCAPE: Cross-border data transfers from the EU engage GDPR Chapter V, which requires adequate safeguards when transferring personal data to third countries without an EU adequacy decision. Standard Contractual Clauses adopted by the European Commission are a recognized mechanism under GDPR. UK transfers are governed by UK GDPR and the UK International Data Transfer Agreement. The EU-US Data Privacy Framework provides an alternative transfer mechanism for US companies that self-certify, but it is not clear from the document whether Figma relies on this framework or solely on SCCs. GOVERNANCE EXPOSURE: Medium. SCCs are a recognized and commonly used transfer mechanism, but they require that the data exporter conduct a transfer impact assessment to evaluate whether the legal framework in the destination country provides equivalent protection. If Figma has not conducted adequate transfer impact assessments, this could create exposure with EU and UK regulators. JURISDICTION FLAGS: EU member state data protection authorities and the UK ICO have authority to assess the adequacy of transfer mechanisms. Following the Schrems II ruling, US national security law remains a relevant factor in transfer impact assessments for US-based recipients. Swiss transfers are governed by the Swiss Federal Act on Data Protection, which has its own transfer requirements. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers with EU or UK personal data processed through Figma should confirm that the Data Processing Agreement incorporates current SCC module versions and that Figma maintains documentation of its transfer impact assessment. Changes to the EU-US Data Privacy Framework or SCC requirements may necessitate contract amendments. COMPLIANCE CONSIDERATIONS: Legal teams should verify which SCC module version Figma uses and whether transfer impact assessments have been conducted for key processing locations. If the organization's own data protection policies require specific transfer mechanism standards, these should be aligned with Figma's DPA provisions. Changes in the regulatory landscape for international transfers should be monitored.
Full compliance analysis
Regulatory citations, enforcement risk, and due diligence action items.
Free: track 1 platform + weekly digest. Watcher: 10 platforms + same-day alerts. No credit card required.
ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.
Your genetic data may be transferred to a new owner as a business asset. Here is what the Terms of Service actually say and what you can do right now.
Professional Governance Intelligence
Need to monitor specific governance provisions?
Professional includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.
Built from archived source documents, structured governance mappings, and historical version tracking.
EU and UK users' personal data is processed by Figma in the US, and the adequacy of the transfer mechanism used is subject to ongoing regulatory scrutiny, meaning users should understand that their data crosses borders and the legal protections that apply.
If you are in the EU or UK, your personal data is transferred to the US under Standard Contractual Clauses, which provide a baseline legal framework for data protection but are subject to regulatory review and may not eliminate all risks associated with US government access to data.
ConductAtlas has identified this type of provision across 2 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Figma.