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 which third parties Figma engages to process their data. While the subprocessor information may still exist on Figma's website, removing the direct link from the Terms of Service reduces accessibility and transparency. Enterprise customers and those subject to GDPR may need to contact Figma directly to access current subprocessor information.
View change record →Severity reduced from 'high' to 'medium' and provision name changed from 'Broad Content License Including AI/ML Use' to 'Broad Content License Grant'; explicit AI/ML language was removed from the named provision.
View full change record →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 posting or submitting content on or through the Services, you grant Upwork a worldwide, non-exclusive, royalty-free, fully paid, sublicensable, and transferable license to use, copy, modify, create derivative works based on, distribute, publicly display, publicly perform, and otherwise exploit in...
"Content" means anything you or your Customers create or make available through the Service in connection with your Account, including your intellectual property (e.g. trademarks, trade names, service marks, and copyrighted works); the products or services you offer (e.g., courses, coaching, members...
By posting, uploading, inputting, providing or submitting your Content you grant Kit, its affiliated companies and necessary sublicensees permission to use your Content in connection with the operation of their Internet businesses including, without limitation, the rights to: copy, distribute, trans...
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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.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Figma.