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 establishes Figma's operational compliance framework for age-restricted services under children's privacy regulations. It creates both a contractual representation requirement for users and an administrative procedure for data deletion upon discovery of underage access.
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 →Users represent and warrant they are at least 16 years old as a condition of service use. If a user is under 16, Figma reserves the right to delete associated personal information upon discovery, and third parties may initiate deletion by contacting the designated privacy email address.
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"The Services are not directed to children under the age of 16. By using the Services, you are representing that you are at least 16 years old. If we learn that a child under 16 has provided us with personal information, we will take steps to delete such information. If you believe that a child under 16 has provided personal information to us, please contact us at privacy@figma.com.— Excerpt from Figma's Figma Terms of Service
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This provision establishes Figma's operational compliance framework for age-restricted services under children's privacy regulations. It creates both a contractual representation requirement for users and an administrative procedure for data deletion upon discovery of underage access.
Users represent and warrant they are at least 16 years old as a condition of service use. If a user is under 16, Figma reserves the right to delete associated personal information upon discovery, and third parties may initiate deletion by contacting the designated privacy email address.
ConductAtlas has identified this type of provision across 7 platforms. See the full comparison.
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