The policy establishes a Valid Request process requiring users to provide identity-verifying information and a detailed description of their request in order to exercise access, deletion, correction, or portability rights under applicable U.S. state privacy laws.
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
The Valid Request mechanism conditions the exercise of statutory privacy rights on identity verification, which is a standard requirement under U.S. state privacy laws but creates a procedural step that determines whether rights requests will be processed. The policy also reserves the right to charge a fee for excessive, repetitive, or manifestly unfounded requests.
Under this provision, users seeking to exercise access, deletion, correction, or portability rights must submit a Valid Request meeting identity verification and description criteria, with responses provided within timeframes required by applicable law. The agreement reserves the right to charge a fee for excessive or repetitive requests, with prior notice before any fee is applied.
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"To exercise the rights described in this Privacy Policy, you or your Authorized Agent (if applicable and as defined below), must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data (such as your Contact or Profile Data), and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a "Valid Request." We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete such Valid Request.— Excerpt from Figure AI's Figure AI Privacy Policy
1) REGULATORY LANDSCAPE: The Valid Request framework engages the CCPA, CPRA, and applicable U.S. state privacy laws which require that businesses respond to consumer rights requests within specified timeframes (typically 45 days with possible extension). Identity verification requirements must not be excessively burdensome under applicable law. The fee provision for excessive requests is permitted under CCPA but requires notification to the consumer before the fee is charged. 2) GOVERNANCE EXPOSURE: Low. The Valid Request framework is consistent with standard requirements under applicable U.S. state privacy laws. The fee reservation for excessive requests is explicitly permitted under CCPA and similar frameworks. The appeal process described for residents of Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, and Virginia aligns with statutory requirements. 3) JURISDICTION FLAGS: California, Colorado, Connecticut, and other covered states each impose specific response timelines and verification standard requirements. Minnesota and Oregon residents have an additional right to request a list of specific third parties to whom data has been disclosed, which the policy acknowledges. Authorized Agent provisions apply in California, Colorado, Connecticut, Delaware, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, and Texas. 4) CONTRACT AND VENDOR IMPLICATIONS: Service providers processing personal data on Figure AI's behalf should have contractual obligations to assist with rights request fulfillment within required timeframes. Data mapping documentation should be sufficient to respond to access and portability requests across all disclosed data categories. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should confirm that internal workflows for Valid Request processing meet the response timelines required under each applicable state privacy law. The appeal process described should be operationally implemented and documented. Identity verification procedures should be assessed to confirm they do not create undue barriers to rights exercise under applicable law.
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The Valid Request mechanism conditions the exercise of statutory privacy rights on identity verification, which is a standard requirement under U.S. state privacy laws but creates a procedural step that determines whether rights requests will be processed. The policy also reserves the right to charge a fee for excessive, repetitive, or manifestly unfounded requests.
Under this provision, users seeking to exercise access, deletion, correction, or portability rights must submit a Valid Request meeting identity verification and description criteria, with responses provided within timeframes required by applicable law. The agreement reserves the right to charge a fee for excessive or repetitive requests, with prior notice before any fee is applied.
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