Figma · Figma Privacy Policy · View original document ↗

GDPR Legal Bases and Data Subject Rights

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Document Record

What it is

If you are in the EU, UK, or Switzerland, Figma processes your data under GDPR and provides you with rights to access, correct, delete, or export your personal data.

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)

EU, UK, and Swiss users have meaningful legal rights over their personal data under GDPR, including the ability to request deletion or a copy of their data, and Figma is required to respond to such requests within regulatory timeframes.

Consumer impact (what this means for users)

EU, UK, and Swiss users can exercise GDPR rights including data access, correction, deletion, and portability by contacting Figma's Data Protection Officer or using the in-product privacy tools. These rights are legally enforceable and Figma is obligated to respond.

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.
  • Delete Your Data
    EU, UK, and Swiss users can submit data access, correction, deletion, or portability requests by emailing privacy@figma.com or contacting Figma's Data Protection Officer at the address listed in the Privacy Policy. Describe your request clearly and include account verification details.

How other platforms handle this

Runway Medium

In addition to the above rights, your local laws (including those in the EU, UK, Japan, California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Virginia, or Utah) may afford you f...

Waze Medium

If you are located in the European Economic Area or the United Kingdom, you have certain rights under applicable data protection laws, including the right to access, correct, or delete your personal data, the right to object to or restrict processing, and the right to data portability. You may also ...

Smartsheet Medium

If you are located in the EEA or UK, you may have the following rights under applicable data protection law: the right to access your personal data; the right to rectify inaccurate personal data; the right to erasure of your personal data; the right to restrict processing of your personal data; the ...

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▸ View Original Clause Language DOCUMENT RECORD
"
If you are located in the European Economic Area, the United Kingdom, or Switzerland, we collect and process your personal information on the following legal bases: Performance of a contract, Legitimate interests, Compliance with legal obligations, and Consent. You have certain rights with respect to your personal information, including the right to access, correct, delete, restrict processing, data portability, and to object to processing.

— Excerpt from Figma's Figma Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: This provision directly engages GDPR and UK GDPR, with enforcement authority resting with EU member state data protection authorities and the UK Information Commissioner's Office. The reliance on legitimate interests as a legal basis for certain processing activities, including potentially AI training and marketing, may be subject to challenge if the balancing test required under GDPR is not adequately documented. Data subject rights requests must be fulfilled within one month under GDPR, extendable by two additional months in complex cases. GOVERNANCE EXPOSURE: Medium. The policy asserts GDPR compliance and lists applicable legal bases but does not provide a granular mapping of each processing activity to its specific legal basis in the public-facing document. Regulators and auditors may expect more detailed documentation, particularly for AI-related processing. JURISDICTION FLAGS: EU and EEA users, UK users, and Swiss users are explicitly covered. The policy's assertion that Standard Contractual Clauses govern data transfers to the US should be verified against current regulatory guidance, as post-Schrems II transfer impact assessments may be required. Swiss Federal Act on Data Protection requirements may diverge from GDPR in specific respects and should be independently evaluated. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers acting as data controllers when using Figma as a data processor should ensure that a Data Processing Agreement is in place that reflects the legal bases and sub-processor arrangements described in this policy. The DPO contact information provided in the policy should be recorded in vendor management systems for rights request escalation. COMPLIANCE CONSIDERATIONS: Organizations should verify that Figma's data subject rights request process is operationally functional and test response timelines. Internal procedures for forwarding data subject requests received by the organization to Figma as a processor should be documented. Transfer impact assessments for US-based processing should be reviewed and updated as regulatory guidance evolves.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • State AG
    EU and UK data protection authorities (equivalent to State AG enforcement in those jurisdictions) have authority to investigate GDPR compliance failures by Figma with respect to EU and UK user data.
    File a complaint →

Applicable regulations

EU AI Act
European Union
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Figma Privacy Policy
Entity
Figma
Document last updated
May 5, 2026
Tracking information
First tracked
May 8, 2026
Last verified
May 11, 2026
Record ID
CA-P-010180
Document ID
CA-D-00544
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
315fb012bac613a0c2ab4c786331faed0efcf8a6a9a30d7fb56cce37350ff08d
Analysis generated
May 8, 2026 13:38 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Figma
Document: Figma Privacy Policy
Record ID: CA-P-010180
Captured: 2026-05-08 13:38:05 UTC
SHA-256: 315fb012bac613a0…
URL: https://conductatlas.com/platform/figma/figma-privacy-policy/gdpr-legal-bases-and-data-subject-rights/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Figma's GDPR Legal Bases and Data Subject Rights clause do?

EU, UK, and Swiss users have meaningful legal rights over their personal data under GDPR, including the ability to request deletion or a copy of their data, and Figma is required to respond to such requests within regulatory timeframes.

How does this clause affect you?

EU, UK, and Swiss users can exercise GDPR rights including data access, correction, deletion, and portability by contacting Figma's Data Protection Officer or using the in-product privacy tools. These rights are legally enforceable and Figma is obligated to respond.

Is ConductAtlas affiliated with Figma?

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