CA-C-000788
Twilio — Twilio Privacy Notice
Entity
Date detected
May 1, 2026
Effective date
May 1, 2026
Severity
Medium
Direction
Negative
Affected users
all users us users business accounts
Taxonomy
Vendor disclosure shift
Changes
2 sentences modified
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What Changed

Twilio updated its privacy policy on May 1, 2026 by merging its previous standalone statement 'We do not sell your data to third parties' directly into the data disclosure section, and replacing it with a new, more specific commitment that no mobile information will be shared with or sold to third parties for marketing or promotional purposes. Previously, the no-sale commitment was a broad, standalone sentence. Now, it is narrower in scope — limited to mobile information and marketing/promotional purposes — which means other categories of personal data are no longer covered by an explicit no-sale pledge. This matters because consumers who relied on the broader original promise may have weaker protections for non-mobile data.

Consumer Impact (what this means for users)

Twilio has removed its broad, unqualified commitment not to sell personal data to third parties and replaced it with a narrower promise that only covers mobile information and only for marketing or promotional purposes. This means personal data that is not classified as 'mobile information' — such as account data, usage data, or communications data — no longer carries an explicit no-sale guarantee under the policy. You can review Twilio's updated privacy notice directly and, if you are a California resident, exercise your right to opt out of the sale or sharing of personal information under CCPA by submitting a request through Twilio's privacy rights portal.

Obligation Changes (what shifted)

1
Protection removed
Consumers Removed

Twilio no longer explicitly promises not to sell all types of your personal data — only your mobile information is protected from being sold for marketing.

Data controllers Shifted

If your company told your own customers that Twilio doesn't sell their data, you may need to update that statement because Twilio's promise is now narrower.

Applicable regulations

CCPA/CPRA
California, USA
CFAA
United States Federal
CAN-SPAM
United States Federal
GDPR
European Union

Why It Matters (compliance & risk perspective)

Twilio's prior blanket no-sale promise gave all users clear assurance that none of their personal data would be sold; the new policy only protects mobile information from marketing-related sales, leaving other data categories without an explicit no-sale guarantee. This matters because consumers and downstream businesses may have made decisions — or written their own disclosures — based on the broader original commitment.

📈 Historical Context

This is the 2nd significant Vendor Disclosure Shift change Twilio has made since ConductAtlas began monitoring.

ConductAtlas has recorded 2 material changes to this document (since April 2026). An additional minor or cosmetic changes were excluded.

Across all monitored documents, Twilio has made 3 significant changes.

2 of Twilio's significant changes have been classified as negative for consumers.

Key Clauses Affected

No-Sale Commitment

Twilio removed its broad, unconditional pledge not to sell any personal data to third parties and replaced it with a narrower commitment limited to mobile information for marketing or promotional purposes only.

How We Disclose Personal Data

The disclosure section was amended to incorporate the narrowed no-sale language inline, while the original standalone no-sale sentence was removed and replaced with a mobile-specific carve-out.

Full clause-by-clause analysis available with Watcher.

Evidence Verification

✓ Verified
Previous Version
e2e78bf619187463f1bae7f4a9c97eb9b62a9bbaa427dd0c6ea2ea5b8a0384b3
May 1, 2026 06:21 UTC
✓ Verified
Current Version
8aa34d875deca43dc028e30e5b310acd78aaa2c08ec1ee04ae93e035e3836716
May 1, 2026 16:28 UTC
✓ Verified
Change Detected
May 1, 2026 16:28 UTC
✓ Verified
Source Document
https://www.twilio.com/en-us/legal/privacy
How to Cite
ConductAtlas Policy Archive
Entity: Twilio | Document: Twilio Privacy Notice | Record: CA-C-000788
Captured: 2026-05-01 16:28:21 UTC
URL: https://conductatlas.com/change/2026-05-01-twilio-twilio-privacy-notice-788/
Accessed: May 2, 2026

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Institutional Analysis (Compliance & legal intelligence)

Assessment

Twilio removed a blanket 'we do not sell your data to third parties' statement and replaced it with a scope-limited commitment covering only mobile information for marketing/promotional purposes. This change touches CCPA/CPRA disclosure obligations (Cal. Civ. Code §1798.100 et seq.) and GDPR Art. 13/14 transparency requirements. The narrowing of the no-sale pledge creates a potential disclosure gap for non-mobile personal data categories. Compliance officers whose organizations rely on Twilio's privacy representations as part of their own vendor due diligence or DPA language should reassess whether their downstream disclosures to end users remain accurate. Action is required if your organization's own privacy notice or DPA references Twilio's no-sale commitment broadly.

Regulatory Exposure

1. CCPA/CPRACal. Civ. Code §1798.100, §1798.110, §1798.115, §1798.120, §1798.135: The removal of a blanket no-sale commitment and its replacement with a category-specific (mobile information only) and purpose-specific (marketing/promotional) commitment may affect CCPA 'Do Not Sell or Share' disclosures. Businesses relying on Twilio as a service provider must re-evaluate whether Twilio's updated commitments still support their own CCPA notices and opt-out mechanisms. California AG and CPPA enforcement guidance on privacy notice accuracy is directly relevant.

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ConductAtlas provides verified policy intelligence sourced directly from platform documents. All analysis is intended to support, not replace, legal and compliance review. Record CA-C-000788.

Full Changes

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Document Context

Document
Twilio Privacy Notice
Entity
Twilio
Captured
May 1, 2026
Source URL
https://www.twilio.com/en-us/legal/privacy
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