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The policy states that Figma collects all content developed or uploaded by users on its platform, which may include personal information such as names embedded in design files and voice data recorded through Figma voice features.
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
This provision discloses that voice data is a category of personal information collected through Figma voice features, and that all customer-designed content, including any personal information embedded within design files, is collected and processed by Figma.
Interpretive note: Whether Figma voice feature recordings constitute biometric data under applicable state or EU definitions depends on how the data is processed, which is not specified in the policy text, creating jurisdictional uncertainty regarding applicable compliance obligations.
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 →Under this clause, any content created or uploaded by a user on Figma's platform is collected, including design files containing personal names, and voice recordings captured through Figma voice features. This data is subject to the policy's broader use and disclosure provisions, including potential use for AI training if the Content Training toggle is enabled.
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"Customer Content . We collect applications and materials that are developed by you on the Services or uploaded to the Services by you or by third parties acting on your behalf. Customer Content may include personal information such as any names you use in your designs or your voice if you use any Figma voice features.Excerpt from Figma's Privacy Policy
1. REGULATORY LANDSCAPE: Voice data collection may implicate biometric privacy laws in jurisdictions including Illinois (Biometric Information Privacy Act), Texas (Capture or Use of Biometric Identifier Act), and Washington, depending on whether voice recordings constitute biometric identifiers under applicable state definitions. GDPR Article 9 treats voice data as potentially constituting biometric data when processed for the purpose of uniquely identifying a natural person, which may require explicit consent or a specific legal basis. The FTC has general consumer protection jurisdiction over representations regarding voice data collection. 2. GOVERNANCE EXPOSURE: Medium. The collection of voice data through Figma voice features creates potential biometric privacy compliance obligations in US states with biometric privacy laws, particularly Illinois, where BIPA provides a private right of action and has generated substantial litigation. The policy does not specify whether voice data is processed for identification purposes, which affects the applicability of biometric privacy frameworks. Organizations deploying Figma for employee use in Illinois, Texas, or Washington should assess whether voice feature use creates biometric data compliance obligations. 3. JURISDICTION FLAGS: Illinois presents the highest exposure due to BIPA's private right of action and per-violation damages. Texas and Washington have statutory biometric privacy requirements without private rights of action but with Attorney General enforcement authority. EU users' voice data may constitute biometric data under GDPR Article 9 if processed for identification, requiring explicit consent. 4. CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers in Illinois or other states with biometric privacy laws should assess whether employee use of Figma voice features requires BIPA-compliant written consent, written policy disclosure, and data retention schedules. This assessment should be reflected in vendor agreements and employee privacy notices. 5. COMPLIANCE CONSIDERATIONS: Organizations should inventory which Figma features employees use, specifically whether voice features are enabled, and assess the biometric privacy implications in applicable jurisdictions. Written consent and policy documentation requirements under BIPA should be evaluated if voice features are used by Illinois-based employees. Data mapping should be updated to reflect voice data as a distinct personal information category collected through Figma.
This provision discloses that voice data is a category of personal information collected through Figma voice features, and that all customer-designed content, including any personal information embedded within design files, is collected and processed by Figma.
Under this clause, any content created or uploaded by a user on Figma's platform is collected, including design files containing personal names, and voice recordings captured through Figma voice features. This data is subject to the policy's broader use and disclosure provisions, including potential use for AI training if the Content Training toggle is enabled.
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