When you upload or create content in Figma, you give Figma a worldwide, royalty-free license to use, copy, modify, and share that content to run and improve its services. Figma can also sublicense this right to others.
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 license covers your design files, assets, and other content, and the sublicense right means Figma may share this license with third-party partners or service providers in connection with operating its platform.
The removal of the Subprocessors list link makes it less convenient for users, particularly enterprise and EU-based customers who rely on this information for data protection compliance, to verify wh…
Your uploaded design files and content can be used by Figma to operate and improve its services, and Figma can grant that right to third parties. For professional designers and businesses, this may have implications for client confidentiality or IP ownership depending on what is uploaded.
How other platforms handle this
By submitting, posting or displaying Content on or through the Services, you give Miro a worldwide, non-exclusive, royalty-free license (with the right to sublicense) to use, copy, reproduce, process, adapt, modify, publish, transmit, display and distribute such Content in any and all media or distr...
By submitting content to any TransUnion website or service, you grant TransUnion a royalty-free, worldwide, perpetual, irrevocable, non-exclusive license to use, reproduce, modify, adapt, publish, translate, create derivative works from, distribute, and display such content in any media.
You consent to our use of Your Content to provide the Service Offerings to you and any End Users. We may disclose Your Content to provide the Service Offerings to you or any End Users or to comply with any request of a governmental or regulatory body (including subpoenas or court orders).
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"By making any Content available through the Services, you hereby grant to Figma a non-exclusive, transferable, worldwide, royalty-free license, with the right to sublicense, to use, copy, modify, create derivative works based upon, distribute, publicly display, and publicly perform your Content in connection with operating and providing the Services and Content to you and to other users.— Excerpt from Figma's Figma Terms of Service
(1) REGULATORY LANDSCAPE: This provision engages GDPR (where content includes personal data of EU individuals), CCPA (where content includes personal information of California residents), and general IP law. The breadth of the sublicense right may require evaluation under enterprise data governance frameworks and client contracts. The FTC Act applies to the extent that the license scope is disclosed clearly and not deceptive to users. (2) GOVERNANCE EXPOSURE: Medium to High for enterprise and professional users. The license to 'modify' and 'create derivative works' from user content, combined with the sublicense right, is broader than a pure operational hosting license and may create tension with client IP ownership obligations or professional confidentiality duties. The license is framed as necessary to provide the service but its scope extends to 'improving' services which is operationally broader. (3) JURISDICTION FLAGS: EU/EEA users face heightened exposure where uploaded content includes personal data, as the license grant must be assessed against GDPR lawful basis requirements. Highly regulated industries (financial services, legal, healthcare) face additional exposure where client materials are uploaded. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise procurement teams should confirm whether Figma's Data Processing Addendum (DPA) limits how content data is used and whether it overrides or supplements this license grant. Client contracts that include IP assignment or confidentiality clauses should be reviewed for compatibility. The sublicense right should be specifically flagged in vendor assessments. (5) COMPLIANCE CONSIDERATIONS: Organizations should conduct a data mapping exercise to identify what categories of content are uploaded to Figma and whether any uploads include personal data or client-confidential materials. DPA execution should be confirmed. Legal teams should assess whether the license scope is compatible with client IP agreements and professional obligations.
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This license covers your design files, assets, and other content, and the sublicense right means Figma may share this license with third-party partners or service providers in connection with operating its platform.
Your uploaded design files and content can be used by Figma to operate and improve its services, and Figma can grant that right to third parties. For professional designers and businesses, this may have implications for client confidentiality or IP ownership depending on what is uploaded.
ConductAtlas has identified this type of provision across 16 platforms. See the full comparison.
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