Provision record
Figma · Figma Privacy Policy · View original document ↗

International Data Transfers and Standard Contractual Clauses

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Document Record

What it is

The policy states that personal information is transferred to and stored in the United States and other countries where Figma's affiliates and sub-processors operate, with transfers from the EEA, Switzerland, and UK relying on Standard Contractual Clauses (Module 2, June 2021) and the UK Addendum as transfer mechanisms.

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 the legal transfer mechanisms Figma relies on for cross-border personal data flows from the EU, UK, and Switzerland to the US and other jurisdictions, and discloses that transferred data may be subject to government access requests in destination jurisdictions.

Recent Activity

This document changed recently

Medium May 28, 2026

The updated terms establish specific restrictions on how Figma may use personal information collected from minors. Children under 13 in the US, under 16 in California and the EU, and under 18 in Japan may now use the Services only through agreements with educational institutions. Figma states it will not use children's personal information to train, fine-tune, or improve AI services, nor will it permit service providers to do so. The policy also prohibits using children's data for marketing purposes, targeted advertising, or enabling third-party tracking. If a parent learns their child provided personal information without consent outside an educational agreement, they may contact Figma to report the issue.

View change record →

Clause Stability Stable

0
Changes
5
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under this clause, personal information collected from EU, UK, and Swiss users is transferred to and stored in the United States, with Standard Contractual Clauses serving as the primary legal transfer mechanism for non-adequacy-decision jurisdictions. The policy acknowledges that destination jurisdictions may have data protection laws that are less protective than the laws in the user's home country, and that data may be subject to government access requests in those jurisdictions.

Cross-platform context

See how other platforms handle International Data Transfers and Standard Contractual Clauses and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
Where we transfer your personal information to countries and territories outside of the European Economic Area ("EEA"), Switzerland and the UK which have been formally recognized as providing an adequate level of protection for personal information, we rely on the relevant "adequacy decisions" and "adequacy regulations" from the European Commission, Swiss and UK authorities. Where the transfer is not subject to an adequacy decision or derogation under the applicable law, we take appropriate safeguards to ensure that your personal information will remain protected in accordance with this Privacy Policy and applicable laws. These safeguards include implementing the Module 2 of European Commission's Standard Contractual Clauses as issued on 4 June 2021 under Article 46(2) GDPR for transfers originating in the EEA, Switzerland (with amendments required under the applicable Swiss law) and the UK Addendum permitted under Article 46(2) of the UK GDPR for the transfer of data originating in the UK.

Excerpt from Figma's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1.

Insight

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Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Provision details

Document information
Document
Figma Privacy Policy
Entity
Figma
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-014688
Document ID
CA-D-00206
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
f7f03821eec4a58f9dc0198f7828ff49a980d5d548d3fa82093da85a7a1559da
Analysis generated
July 9, 2026 06:11 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Figma
Document: Figma Privacy Policy
Record ID: CA-P-014688
Captured: 2026-07-09 06:11:55 UTC
SHA-256: f7f03821eec4a58f…
URL: https://conductatlas.com/platform/figma/figma-privacy-policy/provision/CA-P-014688/international-data-transfers-and-standard-contractual-clauses/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Figma's International Data Transfers and Standard Contractual Clauses clause do?

This provision establishes the legal transfer mechanisms Figma relies on for cross-border personal data flows from the EU, UK, and Switzerland to the US and other jurisdictions, and discloses that transferred data may be subject to government access requests in destination jurisdictions.

How does this clause affect you?

Under this clause, personal information collected from EU, UK, and Swiss users is transferred to and stored in the United States, with Standard Contractual Clauses serving as the primary legal transfer mechanism for non-adequacy-decision jurisdictions. The policy acknowledges that destination jurisdictions may have data protection laws that are less protective than the laws in the user's home country, and that …

Is ConductAtlas affiliated with Figma?

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