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Figma AI

Vannus records that this vendor routes across several model providers — not captured by one. Every finding below is quoted to the vendor’s own document, or marked not disclosed where the vendor publishes nothing. The US-control finding below is the exception: the record places the contracting entity in the United States from the document it cites, but the words that say so are not yet quoted on this page.

Determination
Contracts with Figma, Inc. (United States) — within reach of US legal process.
GLEIF records the entity's own reporting exception for its parent (NO_KNOWN_PERSON, read [2026-09-13]).
figma.com · read 2026-09-17
read from a master agreement
Contracting entity
Figma, Inc.
Jurisdiction
United States
Governing law
SSA (Organization/Enterprise), section 9.9, keyed to the customer's principal place of business: Any country in Europe (including the United Kingdom & Northern Ireland), the Middle East, or Africa — governing law England & Wales, venue courts in London, England; Any country other than those identified above — governing law "California and controlling United States federal law", venue state and United States federal courts located in San Francisco, California. ToS (Starter/Professional), section 9.10: laws of the State of California with no region split, except that the Federal Arbitration Act governs provisions relating to arbitration.
US corporate control
The contracting entity is a US entity, so US law may have legal reach over it and the data it controls. the rule

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What the vendor's own documentation says
OpenAI and our other 3rd party model providers store data temporarily, or in some cases not at all
figma.com ↗ Vendor-sourcedQuote last confirmed 7 Sep 2026; its host's terms forbid automated re-reading, so it is not re-checked
Who controls it
US corporate controlYes — a US parent or US contracting entity is on the public record · the words placing it in the US are not yet quoted here; clause last confirmed 17 Sep 2026; its host's terms forbid automated re-reading, so it is not re-checked
Contracting entityFigma, Inc. — a single US contracting entity worldwide, under BOTH the Software Services Agreement (Organization and Enterprise plans) and the Terms of Service (Starter and Professional plans). There is no Figma Ireland Limited or other non-US contracting entity in either document.
Governing lawSSA (Organization/Enterprise), section 9.9, keyed to the customer's principal place of business: Any country in Europe (including the United Kingdom & Northern Ireland), the Middle East, or Africa — governing law England & Wales, venue courts in London, England; Any country other than those identified above — governing law "California and controlling United States federal law", venue state and United States federal courts located in San Francisco, California. ToS (Starter/Professional), section 9.10: laws of the State of California with no region split, except that the Federal Arbitration Act governs provisions relating to arbitration.
Trains on your dataYes, unless you opt out — on the vendor's default plan
On a paid or enterprise planDoes not train on your data — no retention position recorded

This page gives the finding and links the document it comes from. The AI Subprocessor Jurisdiction Report ($299) quotes the clause this finding rests on, and the clause for each other vendor in your stack where the report can quote one, in one dated document you can hand to an auditor.

Applies to: Organization, Enterprise (training off). Contrast: Starter and Professional (training on by default, admin can toggle off). Figma for Education and Figma for Government also excluded.

From the AI FAQ: “By default, content training is turned off on Organization and Enterprise plans.” help.figma.com ↗

Training and retention posture varies by plan. The default-plan row above describes the vendor’s free or standard tier; the paid-plan row is quoted from the document linked beside it. A negotiated contract can override either. Check your own agreement before relying on this.

On U.S. CLOUD Act reach specifically: the statute reaches a provider subject to U.S. jurisdiction over data in its possession, custody or control. Corporate control is a strong indicator of that and it is what we can evidence from published documents — but it is not the whole test. A company founded outside the U.S. can still contract through a U.S. entity or run substantial U.S. operations. Treat this as a starting point for your own review, not a legal determination, and take advice on anything that matters.

Record history

This is the history of our record of this vendor: when we first recorded it; each time one of these changed: the determination sentence, the contracting entity, its country, the governing law, the US-control finding, what the answer depends on, the note beside the finding, or the cited document; and each time the vendor's document was read again and none of them changed. A change only in capitals, punctuation or spacing is not a line, and neither is a first document title. A line names what changed and does not repeat what those fields said before; the determination above says what they say now. Where the determination sentence itself changed, the line shows the earlier sentence too, marked as before, with why it changed. The automated re-check's latest result is not a line here; it is printed beside the clause above. A change here may be the vendor changing its document or us correcting our reading of it, and a line says which only where the record shows it; otherwise it says the cause is not established. Each line is today's reading of the record as it stood on that date. A reading we later found its citation does not carry was withdrawn, and is not repeated here. This history as data.

Signals on file
Origin
United States

The vendor's published or catalog-recorded posture — the concrete facts this entry is built from. A full audit verifies each against the vendor's current documentation.

Who else handles your data

Figma AI publishes a list of the other companies it uses as sub-processors. It lists 48 entries, and some name the same company more than once, under different locations or for different purposes. Each is shown below with the location the vendor lists it under, in the vendor’s own words.

Agora, Inc. · United StatesAmazon Web Services, Inc. · United States (or, for Enterprise plans, the hosting location selected)Amazon Web Services, Inc. (Bedrock) · United StatesCloudflare, Ltd. · United StatesDatadog, Inc. · United StatesDigital Ocean · United StatesFunctional Software, Inc. (Sentry) · United StatesCastle Global, Inc (Hive) · United StatesModal Labs, Inc. · United StatesOpenAI, LLC · United StatesSnowflake, Inc. · United StatesTwilio, Inc. (Segment) · United StatesTwilio, Inc. · United StatesAnthropic PBC · United States*Amazon Web Services, Inc. · United States*Cerebras Systems, Inc. · United States*Fireworks.ai, Inc. · United States*Google LLC (Vertex) · United States*Jasper AI, Inc. · United States*Microsoft Corporation (Azure) · United States*OpenAI, LLC · United States*Recraft, Inc. · United States*Bria Artificial Intelligence Ltd · United StatesBytePlus Sdn. Bhd. · EU, Indonesia, MalaysiaCreate Without Limits Technologies Inc. (dba Enhancor) · EU, Indonesia, MalaysiaEleven Labs Inc. · United StatesFeatures & Labels, Inc. (FAL) · United StatesFreepik, Inc. · Belgium, Netherlands, SpainKling AI Pte. Ltd. · SingaporeLightricks Ltda AI, Inc. · EU, Israel, United Kingdom, United StatesLuma AI, Inc. · United StatesOpenAI, LLC · United StatesReplicate LLC · United StatesRunway AI, Inc. · United StatesWorld Labs Technologies, Inc. · United StatesAmazon Web Services, Inc. (Bedrock) · United StatesDecagon AI, Inc. · United StatesGainsight, Inc. · United StatesGoogle LLC (Firebase) · United StatesHex, Inc · United StatesIntercom, Inc. · United StatesIntouchCX, Inc. · Canada, The PhilippinesPostHog, Inc. · GermanyPremier Talent Partners · United StatesPylon Labs, Inc · United StatesSendGrid, Inc. · United StatesSprinklr, Inc. · United StatesZendesk, Inc. · United States

Figma AI marks some of those entries and qualifies them below the table. Its words, kept with the entries because the qualification is part of the answer:

* Where necessary to improve latency and Service reliability, requests may be routed through global data centers. When this happens, any data processed from that location is processed exclusively in volatile memory during the active request and the cache is automatically cleared within two hours.

Taken together those entries name at least Belgium, Canada, EU, Germany, Indonesia, Israel, Malaysia, Netherlands, Philippines, Singapore, Spain, United Kingdom, United States. That is what our place list could match in the vendor’s own words above, so treat it as a floor rather than the whole of it — the entries themselves are the record.

These are other companies, not Figma AI. Where a sub-processor is listed as operating is a fact about that company. It is not a statement about where Figma AI keeps your data, which Vannus publishes separately and only from a document in which the vendor says so.

The same document also lists 15 entries for Figma AI’s own corporate group, or for companies that carry its name. They are counted separately from the entries above, which are other companies.

Read from figma.com on 2026-09-17, from the page the vendor titles “Figma Sub-processors”. Every entry above is a verbatim span of that page.

This is the vendor’s own disclosure, reproduced. Vannus has not audited what any of these companies do with your data, and a list can change without notice. Treat it as a starting point for your own review, not a legal determination, and take advice on anything that matters.

Cite this record
Figma AI: “Contracts with Figma, Inc. (United States) — within reach of US legal process.”
Vannus, https://vannus.co/tool/figma-ai
figma.com · read 2026-09-17

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How this entry is set

Vannus records, from the vendor's own published documents, the legal entity a customer contracts with, the country that entity sits in, and the governing law of its terms — and whether the vendor runs its own model or resells someone else's. Each finding is quoted to its source and dated, or marked not disclosed where the vendor publishes nothing. No paid placement on a record, in the catalog or in search — affiliate status is walled off from the record, enforced by a test in the build. See the methodology →

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