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
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.
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no Materials will be accessed from, downloaded in, released in, carried to, transferred to, transshipped through, exported to, or re-exported...to any territory...to which such Materials could not be transferred directly from the United States
You also will not provide access to or allow the use of our Services by any government, entity or individual: (a) located in any Prohibited Jurisdiction; or (b) identified on the U.S. Treasury Department's list of Specially Designated Nationals...
the Services may not be exported or re-exported (a) into any U.S. embargoed countries or any country that has been designated by the U.S. Government as a "terrorist supporting" country, or (b) to anyone listed on any U.S. Government list of prohibited or restricted parties
"Customer will not access or use the Figma Platform, export, re-export, distribute, assign, or otherwise engage in any transaction relating to the Figma Platform or any Customer Content in violation of Export Controls.Excerpt from Figma's Terms of Service
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The clause states: “Customer will not access or use the Figma Platform, export, re-export, distribute, assign, or otherwise engage in any transaction relating to the Figma Platform or any Customer Content in violation of Export Controls.”
ConductAtlas has identified this type of provision across 183 platforms. See the full comparison.
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