You are responsible for everything that happens under your Figma account, whether or not you personally took the action. Keeping your password secure is your obligation.
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
If someone else gains access to your account and violates Figma's terms or causes harm, you may bear responsibility under these terms, even if you were not personally involved.
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 →This new provision places full liability on users for all account activity regardless of whether they actually authorized it, limiting Figma's responsibility for unauthorized access.
View full change record →If your Figma account is compromised and used to violate the terms of service, you remain responsible for those actions under these terms. Strong password hygiene and account security measures are important for all Figma users.
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"You are responsible for maintaining the confidentiality of your account and password, including but not limited to the restriction of access to your computer and/or account. You agree to accept responsibility for all activities or actions that occur under your account and/or password, whether or not the password is in use by you.— Excerpt from Figma's Figma Terms of Service
(1) REGULATORY LANDSCAPE: Account responsibility clauses are standard in SaaS agreements and are generally enforceable under US and UK contract law. Where account compromise involves unauthorized access to personal data, GDPR breach notification obligations may be triggered. CCPA similarly requires notification of data breaches involving California residents' personal information. (2) GOVERNANCE EXPOSURE: Low. This is a standard provision in SaaS agreements. However, for enterprise deployments with multiple employee users, account security governance and access control policies become important operational considerations. (3) JURISDICTION FLAGS: No heightened jurisdiction-specific exposure beyond standard data breach notification obligations under GDPR and CCPA in the event of account compromise. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise administrators should ensure multi-factor authentication and access control policies are in place and documented. Vendor assessments should confirm what account security controls Figma provides at the organizational level. (5) COMPLIANCE CONSIDERATIONS: Organizations should implement and enforce strong password and MFA policies for all Figma accounts, conduct access reviews, and ensure offboarding procedures revoke access promptly.
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If someone else gains access to your account and violates Figma's terms or causes harm, you may bear responsibility under these terms, even if you were not personally involved.
If your Figma account is compromised and used to violate the terms of service, you remain responsible for those actions under these terms. Strong password hygiene and account security measures are important for all Figma users.
ConductAtlas has identified this type of provision across 1 platforms. See the full comparison.
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