The policy restricts collection of personal data from users under 18 years of age and provides a contact mechanism for reporting potential collection from minors.
This analysis describes what Figure AI'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
Figure AI's policy sets the minimum age at 18, which is more restrictive than COPPA's threshold of 13, but relies on a knowledge-based standard rather than affirmative age verification. The absence of an active age verification mechanism means the restriction depends on self-reporting or third-party notification.
The agreement prohibits knowing collection of personal data from users under 18, with a reporting mechanism available at privacy@figure.ai for suspected collection from minors. The policy does not describe an active age verification mechanism.
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"We do not knowingly collect or solicit Personal Data from children under 18 years of age; if you are a child under the age of 18, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If you believe that a child under 18 years of age may have provided Personal Data to us, please contact us at privacy@figure.ai.— Excerpt from Figure AI's Figure AI Privacy Policy
1) REGULATORY LANDSCAPE: COPPA (Children's Online Privacy Protection Act) applies to online collection of personal information from children under 13, enforced by the FTC. Figure AI's policy sets a higher threshold of 18, which exceeds COPPA requirements but relies on a knowledge-based rather than verified standard. State laws in California and other states impose additional restrictions on collection of data from minors under 16. 2) GOVERNANCE EXPOSURE: Low to Medium. The knowledge-based standard without active age verification creates a gap between the stated restriction and operational enforcement. If the services are accessible to minors despite the stated restriction, COPPA or state minor privacy law obligations may apply regardless of the policy statement. 3) JURISDICTION FLAGS: California's AADC (Age Appropriate Design Code considerations) and similar state-level frameworks for minor user protections may apply depending on whether the services are likely to be accessed by users under 18. Federal COPPA enforcement remains active for services that knowingly collect data from users under 13. 4) CONTRACT AND VENDOR IMPLICATIONS: Service providers should be instructed to flag and not process personal data identified as belonging to users under 18. Data processing agreements should include provisions addressing the handling of minor user data if inadvertently collected. 5) COMPLIANCE CONSIDERATIONS: A technical and operational assessment should evaluate whether age verification or screening mechanisms are feasible and legally required given the nature of Figure AI's services. Incident response procedures for identified collection from minors should be documented, including deletion workflows and regulatory notification protocols where required.
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Figure AI's policy sets the minimum age at 18, which is more restrictive than COPPA's threshold of 13, but relies on a knowledge-based standard rather than affirmative age verification. The absence of an active age verification mechanism means the restriction depends on self-reporting or third-party notification.
The agreement prohibits knowing collection of personal data from users under 18, with a reporting mechanism available at privacy@figure.ai for suspected collection from minors. The policy does not describe an active age verification mechanism.
ConductAtlas has identified this type of provision across 7 platforms. See the full comparison.
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