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| 0 | Print this page Customer and Partner Agreements Terms of Service Acceptable Use Policy Service and Country Specific Requirements Data Protection Addendum (DPA) Security Overview Service Level Agreements Advisory Services Terms Professional Services Terms Twilio Marketplace Terms Twilio Segment Customer Data Platform Destination Integration and Listing Terms AI/ML Terms Customer Name Changes and Assignments Updates to Legal Terms and Conditions Country Specific Disclosures EU Data Act Disclosures and Twilio’s Commitment to Open Portability and Switching European Electronic Communications Code Disclosures Italy ALIAS Database Code of Conduct Germany - Impressum Privacy Data Privacy at Twilio Privacy Notice Binding Corporate Rules Customer Proprietary Network Information (CPNI) Sub-processors GDPR Customer Data Protection Addendum Supplier Data Protection Addendum Global Applicant Privacy Notice Mobile Application Terms Twilio Frontline End User App Terms Twilio Authy App Terms Supplier Agreements Supplier Purchase Order Terms and Conditions Country-Specific Terms Supplier Data Protection Addendum Supplier Code of Conduct Intellectual Property DMCA Policy Trademark Resources for Law Enforcement Government Requests Transparency Report Civil Requests Submit a request or subpoena Code of Conduct & Ethics Hotline Twilio Code of Conduct Ethics and Whistleblower Hotline Discord Community Code of Conduct Twilio Discord FAQ Digital Promotions General Rules Sweepstakes Rules Customer Research and User Experience Acknowledgement and Waiver Twilio Privacy Notice Last Updated : August 14, 2025 (View the prior version of our privacy notice here ) Introduction The Privacy program of Twilio Inc. and its group companies (‘Twilio’, ‘we’ or ‘our’) is built on our Binding Corporate Rules ('BCRs'), which serve as our code of conduct that governs our global processing of personal data. | 0 | Print this page Customer and Partner Agreements Terms of Service Acceptable Use Policy Service and Country Specific Requirements Data Protection Addendum (DPA) Security Overview Service Level Agreements Advisory Services Terms Professional Services Terms Twilio Marketplace Terms Twilio Segment Customer Data Platform Destination Integration and Listing Terms AI/ML Terms Customer Name Changes and Assignments Updates to Legal Terms and Conditions Country Specific Disclosures EU Data Act Disclosures and Twilio’s Commitment to Open Portability and Switching European Electronic Communications Code Disclosures Italy ALIAS Database Code of Conduct Germany - Impressum Privacy Data Privacy at Twilio Privacy Notice Binding Corporate Rules Customer Proprietary Network Information (CPNI) Sub-processors GDPR Customer Data Protection Addendum Supplier Data Protection Addendum Global Applicant Privacy Notice Mobile Application Terms Twilio Frontline End User App Terms Twilio Authy App Terms Supplier Agreements Supplier Purchase Order Terms and Conditions Country-Specific Terms Supplier Data Protection Addendum Supplier Code of Conduct Intellectual Property DMCA Policy Trademark Resources for Law Enforcement Government Requests Transparency Report Civil Requests Submit a request or subpoena Code of Conduct & Ethics Hotline Twilio Code of Conduct Ethics and Whistleblower Hotline Discord Community Code of Conduct Twilio Discord FAQ Digital Promotions General Rules Sweepstakes Rules Customer Research and User Experience Acknowledgement and Waiver Twilio Privacy Notice Last Updated : April 09, 2026 (View the prior version of our privacy notice here ) Introduction & Scope Building the Future of Engagement. |
| 1 | In order to provide products and services ('Services') to our customers and conduct our day-to-day business operations, including the operation of our websites, we collect, use and share, or otherwise process personal data about our customers, our customers’ authorized users ('end user') and their customers, our website visitors and business contacts. | 1 | Twilio powers the world’s most important communications by seamlessly unifying data and connectivity. |
| 2 | Personal data is any information that directly identifies you, such as your name and email address, or that indirectly identifies you, for example a phone number or device identifier. | 2 | We protect the personal data flowing through our platform by centering our privacy program on Binding Corporate Rules (“BCRs”). |
| 3 | The personal data we may collect and process about you varies depending on our relationship with you. | 3 | These BCRs serve as our global code of conduct, mandating how Twilio Inc. and its group companies (“Twilio”, “we”, or “our”) process personal data wherever we operate. |
| 4 | We may have a direct relationship with you because you have set up an account or consented to receive marketing communications from us, or we may have an indirect relationship with you via your relationship with one of our customers; for example you may be their employee or their customer. | 4 | Trust Through Transparency. |
| 5 | We take privacy, data protection and our legal obligations very seriously. | 5 | In a digital economy defined by speed and scale, transparency is essential to who we are and how we operate. |
| 6 | We are committed to being transparent with you about how we use personal data. | 6 | It is the foundation of the trust we build with the millions of developers and organizations who rely on Twilio. |
| 7 | This Privacy Notice ('Notice') aims to describe our privacy practices in a clear, accessible and easy to understand way and to let you know how you can exercise your rights in relation to your data. | 7 | To honor that trust, we explain our privacy practices in a clear, accessible, and easy-to-understand way, and let you know how to exercise your rights in relation to your data. |
| 8 | This Notice applies where Twilio processes personal data as a data controller , in connection with the Services we provide to our customers and the operation of our business, including our websites. | 8 | Putting Privacy Into Practice. |
| 9 | As a data controller, we determine the purpose (why) and means (how) of personal data processing and are ultimately responsible for the correct handling of your data, in accordance with applicable law. | 9 | To provide our products and services (collectively, our “Services”) and conduct our day-to-day business operations, we collect, store, use, and share personal data, which is any information that identifies you directly (such as your name) or indirectly (such as a phone number or device identifier). |
| 10 | This Notice describes our general privacy practices. | 10 | Depending on which Services are used, we process personal data for: Customers: Individuals or entities who contract with us to use our Services. |
| 11 | Depending on how you interact with us or the specific services you use, additional privacy notices may apply. | 11 | End Users: Individuals who interact with our customers via our Services (e.g., receiving a text or authenticating an identity). |
| 12 | These supplemental notices will be provided to you at or before the time we collect your personal data. | 12 | Prospective Customers & Visitors: Individuals who visit our websites, attend our events, or engage with our sales teams. |
| 13 | These supplemental notices should be read together with this Notice and are incorporated by reference. | 13 | Our personal data responsibilities depend on how you use our Services or interact with us: Twilio As Data Controller: We determine the “how” and the “why” personal data is used in relation to our Services, accounts, websites, and operations. |
| 14 | This Notice does not apply to the Personal Data we process in relation to job applicants. | 14 | In these cases, we are directly responsible for protecting the data. |
| 15 | This is covered by our Global Applicant Privacy Notice . | 15 | Twilio As Data Processor: We process personal data as directed by our customers - whether through specific instructions, our Data Protection Addendum , or their chosen Service configurations. |
| 16 | We also process personal data for most of our Services as a data processor . | 16 | In these cases, we must use and protect personal data in line with those directions. |
| 17 | As a data processor, we process personal data related to our customers' employees, end users and customers on behalf of our customers to provide Services to them in accordance with their instructions. | 17 | This Privacy Notice (“Notice”) applies when Twilio acts as a Data Controller. |
| 18 | These instructions are set out in our customer agreements, Data Protection Addendum , service specific terms or through a customer's use or configuration of a product feature. | 18 | What This Notice Doesn't Cover Supplemental Notices: Specific Services or business operations may have additional privacy terms provided at the time of collection. |
| 19 | You should contact these organizations directly for information about how they process your personal data as a data controller and to exercise your rights in relation to that data. | 19 | Job Applicants: This Notice does not apply to candidates. |
| 20 | Contents of our Privacy Notice Personal Data We Process How We Process Personal Data How We Disclose Personal Data International Data Transfers How We Secure Personal Data How Long We Retain Personal Data Your Rights and Choices About Your Data How To Exercise Your Rights and Choices How We Use Cookies and Other Tracking Technologies Children Automated Decision-Making How to Contact Us Changes to Our Privacy Notice Twilio Product Privacy Personal Data We Process The personal data we collect about you depends on your relationship with us and the purposes for which we process that personal data. | 20 | Please see our Global Applicant Privacy Notice . |
| 21 | The following describes the types of personal data that we collected and disclosed for a business purpose in the preceding 12 months. | 21 | What Personal Data We Process To deliver our Services, manage our business operations, drive research and development, secure our platform and networks, and prevent fraud, we process personal data from three sources: 1) data you share directly; 2) data we generate or collect automatically; and 3) data from third parties. |
| 22 | Personal Data You Share With Us Directly Contact Information - When you sign up for a Twilio, Sendgrid or Segment account and use any of our Services, request product information, ask for a call from our sales team, or participate in events, we ask you to provide us with your name, company name, business address, phone number, email address and other contact information. | 22 | The categories of personal data we have collected, processed and disclosed for our business purposes in the past 12 months will depend on the nature of your relationship with us or on the Services you or our customers use, and may include the following: Table 1: Data You Share Directly Personal data you provide for account setup, purchases, or support. |
| 23 | We also ask you to create a password and name your account (or accounts, if you have more than one). | 23 | Contact Data Name, company name, business address, phone number, email address, job title, industry, social media profile URLs. Customer Account Data Purchase & Payment Data Purchase history, credit/debit card details, billing address, PayPal account info. |
| 24 | Customer Account Data - We process certain personal data to manage our relationship with you and administer you or your company’s account. | 24 | Service Provisioning Data Application details regarding intended use of certain Services (e.g., Short Codes) Security & Verification Data Username, password, account names, unique Account IDs, API tokens, government-issued IDs. Subscriber Records Proof of identity and physical service address and other information as required by local laws to provide specific services (e.g., phone numbers). |
| 25 | This includes purchase history, names or contact information of individuals authorized to manage the Twilio account on behalf of our customer to set up, access and manage billing. | 25 | Customer Content Communications content (e.g., email subject, email body, text body, media files), transcripts, recordings, communications logs, and other data uploaded to the Services. |
| 26 | We also collect personal data required to administer use of your account and the Services, and information to allow us to verify your identity for Know Your Customer or other identity verification purposes. | 26 | Marketing & Communications Data Privacy settings, communication preferences, event attendance info, dietary requirements, or accessibility needs for in-person events. |
| 27 | Customer Content - We receive and store the content of communications received from you or our customers and other personal data uploaded to the Services or generated for our customers’ use as part of the Services, which we may be authorized by you or our customer to use, where necessary for specific legitimate business purposes and in accordance with applicable law. | 27 | Customer Support & Feedback Data Call recordings with our support agents, transcribed conversations conducted with AI chatbots, feedback and survey responses. |
| 28 | Marketing and Contact Preferences - We use information about how you would like to be contacted and choices you have made to send you marketing communications. | 28 | Table 2: Data We Generate or Collect Automatically Personal data we automatically collect or generate in order to route communications, optimize performance, and prevent fraud, including through tracking technologies like cookies and web beacons. |
| 29 | Payment Information - In connection with Services you pay for, we ask you to provide our payment processor with your payment method information like a credit card or your Paypal account and your billing address. | 29 | Communications Usage Data Electronic Communications Metadata Sender/recipient information, routing details, timestamps, communication type, duration, message status & activity (e.g., delivered, opened, bounced, spam, clicks, or unsubscribes), error data and traffic records. |
| 30 | Our payment processor, acting on our behalf, gathers this so we can bill you for your use of our Services. | 30 | Customer Proprietary Network Information (“CPNI”) U.S. only: A subset of usage data (e.g., call destinations, locations, and configurations) that excludes names, addresses, and call content. |
| 31 | Our payment processor will share your billing address with Twilio for this purpose. | 31 | Learn more about CPNI and how to exercise your rights here . |
| 32 | Personalization Details - Some of our products, such as our short code service, may require you to complete an application form by providing details about your or your company’s intended use of the product to determine eligibility for these products. | 32 | Device Data IP address, OS type/version, browser type, screen resolution, CPU count, manufacturer/model, device IDs, time zone, IP address-based location of the device generated in the context of delivering a communication, and general location (City/Town) when you use our account portal and make requests to our APIs and activity logs. |
| 33 | Professional Information - The information we process about you with respect to your employment or profession, including company, job title, email address, phone number and online business networking profile. | 33 | Precise geolocation data is not collected. |
| 34 | Subscriber Records - For some of our communications products, we may also obtain proof of identity from you or our customer that includes a proof of address, name, physical address, or other identification information. | 34 | Online Activity Data Browsing behavior, page and feature interactions, products viewed or searched, response times, download errors. |
| 35 | For example, to use our Trust Hub or to obtain a phone number in certain countries, local law may require us to have a physical service address on file for the individual who will be using that Twilio number, whether that’s you or our customer's end user. | 35 | Table 3: Data From Other Sources Personal data we receive from third parties, trusted partners, telecommunications operators, aggregators, or carriers to provision accounts, validate identities, and enrich our Services. |
| 36 | Support and Feedback - When you interact with us on our websites including through our AI chatbots (e.g. our Help Center Assistant), over the phone or via email, we process the phone number or email address that you use, the content of your interaction and the feedback you provide about our Services. | 36 | Partner-Sourced Data Contact Data provided by event partners and co-sponsors, as well as marketing and lead generation partners. |
| 37 | You may also provide us with feedback about our Services in surveys and questionnaires. | 37 | Data may also include information you choose to share via third-party forms or advertisements, which may be auto-populated from your profile on those platforms and which may include location related data. |
| 38 | We will let you know when a call may be recorded, in accordance with applicable law. | 38 | Solution Provider-Sourced Data Contact Data and Customer Account Data shared by our solutions providers - Independent Software Vendors (“ISVs”) and Managed Service Providers (“MSP”) - to help us process orders and set up sub-accounts. |
| 39 | Personal Data We Generate or Collect Automatically Communications Usage Data - When you or our customers use Twilio communications products, we collect electronic communications metadata, such as phone numbers and routing information, the source and destination of a communication, location of the device generated in the context of delivering the communication, date, time, duration and type of communication, status of the message, error data and traffic records. | 39 | Data Enrichment Services Contact Data obtained from third-party data providers and enrichment services and data that is publicly available. |
| 40 | Device Information and IP Addresses - When you use our account portal, we collect your IP address and device information through tracking technologies like cookies, web beacons, pixels, and similar technologies. | 40 | We may combine this Contact Data with other data we have collected about you. |
| 41 | We also collect IP addresses when you make requests to our APIs and in our server logs. | 41 | Third-Party Authentication Data Contact Data and Customer Account Data shared by connected third-party services like Google and Meta when you link those accounts to your Twilio account, as permitted by your individual privacy settings on those platforms. |
| 42 | Additionally, we collect information about your device, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, unique identifiers, and general location information such as city or town when you use our account portal. | 42 | Telecommunications Data Communication-related data from operators, aggregators, and carriers - including phone type, SIM and carrier history, registration location, account type and IP address - used to validate whether personal data provided to Twilio matches operator, aggregator or carrier records. |
| 43 | We do not collect precise geolocation information. | 43 | How and Why We Use Your Data The specific reasons we process personal data depend on your relationship with us. |
| 44 | Online Activity Information - When you visit Twilio websites, including our web forms, we use tracking technologies such as cookies, web beacons, and pixels to collect the following data: your device and browser, time zone setting, web pages visited, products you view or search for, page response times, download errors, length of visits to certain pages, page interaction information, IP address. | 44 | We only process the personal data necessary to fulfill the purposes listed below, and we do so in accordance with applicable data protection laws.. |
| 45 | Security Identifiers or SIDs - When you sign up for an account with Twilio, we’ll automatically assign you and each of your accounts a unique security ID and generate an API token for each account. | 45 | In the past 12 months, we have processed personal data for the following business purposes: Table 4: Data Use Categories & Legal Basis for Processing Data Use Categories & Legal Basis for Processing Account Management Purpose: Creating and managing your Twilio account throughout your customer lifecycle. |
| 46 | We keep a record of these credentials so we know it is you making the requests when your application makes requests to our API using these credentials. | 46 | Examples: Determining service eligibility; verifying identities (KYC); billing and relationship management; and, sending essential administrative or Service updates. |
| 47 | Customer Proprietary Network Information - When you use certain US voice-based communications services, Twilio collects information associated with your service usage. | 47 | Personal Data Processed: Contact Data Customer Account Data Solution-Provider Sourced Data Third-Party Authentication Data Legal Basis for Processing: Consent Legitimate Interest Legal Obligation Business Operations Purpose: Managing essential business functions. |
| 48 | This includes information such as the number of phone calls, call destinations, call locations, type, and service configuration, and is known as Customer Proprietary Network Information ('CPNI'). | 48 | Examples: Financial management (accounting, auditing, and revenue planning); strategic growth (lead scoring and operational insights); relationship management; corporate governance; risk management; maintaining customer records; identifying potential job candidates; and, ensuring the safety of our employees, visitors, and properties. |
| 49 | CPNI does not include information such as your name, address, phone number, or the content of phone calls. | 49 | Personal Data Processed: Contact Data Customer Account Data Communications Usage Data Customer Support & Feedback Data Online Activity Data Solution-Provider Sourced Data Data Enrichment Services Third-Party Authentication Data Legal Basis for Processing: Consent Legitimate Interest Legal Obligation Platform Security & Fraud Prevention Purpose: Securing our platform and data while proactively protecting our network and our users from abuse. |
| 50 | We use CPNI to market Twilio-related Services to which you are not already subscribed unless you have exercised your right to opt out. | 50 | Examples: Safeguarding systems against unauthorized access and security threats; identifying account takeovers and signs of spam or bot attacks; training AI/ML models to recognize evolving security vulnerabilities and fraud signatures; and, utilizing signals to make real-time automated security decisions, such as approving account applications or suspending fraudulent accounts (of which you will be notified and given an opportunity to object). |
| 51 | For information about your CPNI choices, see the section “ Your Rights and Choices About Your Data ” below. | 51 | Personal Data Processed: Contact Data Customer Account Data Customer Content Communications Usage Data Customer Support & Feedback Data Solution-Provider Sourced Data Third-Party Authentication Data Telecommunications Data Legal Basis for Processing: Consent Legitimate Interest Legal Obligation Service Support & Improvement Purpose: Operating, maintaining, and evolving our communications and engagement platforms. |
| 52 | Personal Data Collected From Other Sources Add-On Service Data - In the event you purchase our Services through one of our Add-On Partners , they may share your personal data with us to fulfill their contractual obligations. | 52 | Examples: Providing global connectivity and routing communications; troubleshooting technical issues; training AI/ML models with performance metrics to optimize network reliability; providing dedicated customer support; and, refining our Service suite through usage insights. |
| 53 | Add-On Partners may share your personal data in the form of leads when you download Twilio content on the Add-On Partner’s website or you participate in events and webinars of which Twilio is a sponsor. | 53 | Personal Data Processed: Contact Data Customer Account Data Customer Content Communications Usage Data Customer Support & Feedback Data Solution-Provider Sourced Data Third-Party Authentication Data Telecommunications Data Legal Basis for Processing: Consent Legitimate Interest Legal Obligation Research & Innovation Purpose: Expanding platform capabilities and developing the next generation of communications, engagement, and identity solutions. |
| 54 | Professional Data - We collect certain personal data such as employment or professional information from sources other than you. | 54 | Examples: Developing new features or products to continuously improve our Services. |
| 55 | We may combine this data with other personal data that you share with us. | 55 | Personal Data Processed: Customer Account Data Customer Content Communications Usage Data Customer Support & Feedback Data Online Activity Data Solution-Provider Sourced Data Third-Party Authentication Data Telecommunications Data Legal Basis for Processing: Consent Legitimate Interest Legal Obligation Customer Engagement Purpose: Personalizing your experience and managing our ongoing relationship with you. |
| 56 | Publicly-Available Sources - We may also use publicly-available information about you that we have gathered through services like LinkedIn, or we may obtain information about you or your company from third party providers, such as your industry, the size of your company, and your company’s website URL. | 56 | Examples: Delivering essential Service notifications and account support; sending relevant Service updates and news based on your preferences; facilitating event participation and access to resources like whitepapers; and, conducting surveys to gather insights for Service improvements. |
| 57 | Social Media Data - Social media service providers such as Google, LinkedIn, and Meta may provide us with information about you, in accordance with your privacy settings on those sites. | 57 | Personal Data Processed: Contact Data Customer Account Data Marketing & Communications Data Communications Usage Data (Device Data) Online Activity Data Partner-Sourced Data Solution-Provider Sourced Data Data Enrichment Services Third-Party Authentication Data Legal Basis for Processing: Consent Legitimate Interest Personalization & Optimization Purpose: To analyze site and platform interactions in order to improve your digital experience, refine our interfaces, and optimize our marketing ecosystem through a unified understanding of the customer journey. |
| 58 | Telecommunication Data - We receive communication-related data from telecommunications operators, aggregators and carriers that may include phone type, carrier history, SIM status and history, city and/or country where phone was first registered, contract and account type, IP address city and/or country and a validation result of personal data provided by our customer and whether it matches data held by the carrier. | 58 | Examples: Analyzing website and platform navigation to improve functionality and experience; utilizing identity resolution to create unified profiles that ensure a consistent experience across different devices and touchpoints; measuring and optimizing the performance of our advertising activities; and deploying online tracking technologies in accordance with your preferences. |
| 59 | How We Process Personal Data The purposes for which we process personal depends on your relationship with us. | 59 | Personal Data Processed: Contact Data Customer Account Data Marketing & Communications Data Communications Usage Data (Device Data) Online Activity Data Partner-Sourced Data Solution-Provider Sourced Data Third-Party Authentication Data Legal Basis for Processing: Consent Legitimate Interest Legal Compliance Purpose: Fulfilling our global legal obligations and protecting the public interest. |
| 60 | We only use personal data that is necessary to fulfill the specified purposes listed below as applicable to you and in accordance with applicable data protection law. | 60 | Examples: Adhering to international telecommunications and data protection laws, along with carrier requirements and industry codes of practice; responding to valid legal requests (such as court orders or subpoenas); and safeguarding the fundamental rights and freedoms of individuals. |
| 61 | Purpose Personal Data Processed Legal Basis for Processing Creating and managing accounts, including verification of the identity of our customer’s end user for Know-Your-Customer (KYC) or identity verification purposes. | 61 | Personal Data Processed: Customer Account Data Customer Content Communications Usage Data Solution=Provider Sourced Data Third-Party Authentication Data Legal Basis for Processing: Legitimate Interest Legal Obligation How We Disclose Personal Data We only share your data when it is necessary to provide our Services, run our business, or comply with the law. |
| 62 | Add-On Service Data Contact Information Customer Account Data Online Activity Information Payment Information Professional Information Subscriber Records Security Identifier Legitimate Interest Legal Obligation Carrying out Twilio’s core business operations, such as account administration, accounting, auditing and compliance, business analytics, filing taxes, finance, forecasting, consolidated management and reporting, product strategy and revenue planning. | 62 | We do not sell your data to third parties. |
| 63 | Add-On Service Data Professional Information Customer Account Data Support and Feedback Customer Content Communications Usage Data Payment Information Publicly Available Sources Social Media Data Legitimate Interest Billing and relationship management. | 63 | In the past 12 months, we may have shared personal data with the following categories of recipients: Table 5: Data Recipient Categories Data Recipient Categories Telecommunications Service Providers Recipient Details: Global network of operators, aggregators, and carriers who act as conduits for Customer Content. |
| 64 | Add-On Service Data Contact Information Communications Usage Data Payment Information Legitimate Interest Providing, optimizing and maintaining our Services and, platform, including debugging and troubleshooting. | 64 | These providers function as independent data controllers when processing metadata for billing, fraud prevention, or legal compliance. |
| 65 | Add-On Service Data Subscriber Records Online Activity Information Communications Usage Data Customer Content Device Information and IP Addresses Security Identifier Legitimate Interest Preventing, detecting and investigating security incidents and managing the security of Twilio’s platform, services, websites and accounts. | 65 | Important Note: Where required by local law, we share Subscriber Records with local carriers or authorities solely to provide connectivity, maintaining the highest confidentiality for these records. |
| 66 | Add-On Service Data Communications Usage Data Customer Content Device Information and IP Addresses Online Activity Information Payment Information Subscriber Records Telecommunication Data Contact Information Customer Account Data Security Identifier Legitimate Interest Legal Obligation Preventing, detecting, or investigating abuse or misuse of Twilio’s platform or Services , including spam, fraud, illegal activities, or violations of the Twilio Acceptable Use Policy , or assisting telecommunications service providers, regulators, or law enforcement agencies with combating spam, fraud, or illegal activities. | 66 | Reason for Sharing: To route and connect communications across the publicly switched telephone network (“PSTN”). |
| 67 | Communications Usage Data Customer Content Customer Account Data Contact Information Device Information and IP Addresses Telecommunications Data Security Identifier Legitimate Interest Legal Obligation Determining eligibility for certain Services. | 67 | Other Communications Service Providers Recipient Details: Over-the-Top (“OTT”) providers (such as WhatsApp) that function as independent data controllers. |
| 68 | Add-On Service Data Contact Information Payment Information Personalization Details Subscriber Records Legitimate Interest For routing and connectivity purposes to send messages on behalf of our customers, including transmitting, distributing and exchanging communications using phone numbers, either through the public switched telephone network or other communications networks. | 68 | Reason for Sharing: To route and connect communications across the publicly switched telephone network (“PSTN”). |
| 69 | Add-On Service Data Communications Usage Data Legitimate Interest Providing customer support, including responding to your requests and communicating with you about your account and use of the services, including suspicious activity or security alerts. | 69 | Third Party Service Providers Recipient Details: Third-party vendors and service providers engaged by Twilio to process personal data on our behalf. |
| 70 | Contact Information Customer Account Data Customer Content Communications Usage Data Professional Information Support and Feedback Security Identifier Other personal data provided by requestor Legitimate interest Sending important notifications about our Services. | 70 | Reason for Sharing: To perform specific operational functions, with access strictly limited to providing services to Twilio under robust security and confidentiality safeguards. |
| 71 | Add-On Service Data Contact Information Customer Account Data Legitimate Interest Complying with legal and regulatory obligations, telecommunication service provider requirements and communications industry codes of practice. | 71 | Partners & Integrated Service Providers Recipient Details: Third party partners who provide 'add-ons' or integrations to our Services through the Twilio Marketplace or other Twilio provided catalogue (such as Segment Connections). |
| 72 | Subscriber Records Customer Content Communications Usage Data Customer Account Data Legitimate Interest Sending marketing communications in accordance with your marketing preferences. | 72 | Reason for Sharing: To facilitate seamless interoperability between Twilio and third-party services. |
| 73 | Add-On Service Data Contact Information Marketing and Contact Preferences Professional Data Publicly Available Sources Social Media Data Legitimate Interest Consent Analyzing your interest in our Services and delivering marketing campaigns that are relevant to you. | 73 | This includes disclosing Contact Data and Customer Account Data to those partners to enable the chosen functionality. |
| 74 | Add-On Service Data Contact Information Marketing and Contact Preferences Professional Data Publicly Available Sources Social Media Data Security Identifier Legitimate Interest Consent Deploying cookies and other tracking technologies in accordance with your online settings. | 74 | Twilio Group Companies Recipient Details: Twilio group companies (subsidiaries and affiliates) as listed in our Binding Corporate Rules. |
| 75 | Add-On Service Data Contact Information Marketing and Contact Preferences Professional Data Social Media Data Legitimate Interest Consent Understanding how visitors navigate our websites, and tracking and optimizing the performance of our advertising activities. | 75 | Reason for Sharing: To facilitate global operations and Service delivery, with all members contractually bound to use your information strictly as described in this Notice. |
| 76 | Device Information Online Activity Information Publicly Available Sources Social Media Data Legitimate Interest Understanding how customers are using our platform and improving the website navigation experience. | 76 | Legal, Regulatory, & Judicial Parties Recipient Details: Law enforcement, government agencies, emergency services, private parties involved in legal proceedings (such as opposing counsel or court-appointed officers) or a third party. |
| 77 | Add-On Service Data Contact Information Marketing and Contact Preferences Online Activity Information Professional Data Legitimate Interest Consent Conducting questionnaires and surveys to improve our Services and provide training to our employees. | 77 | Important Note: We notify users of legal requests whenever permitted and where Twilio determines the disclosure will not interfere with an on-going investigation. |
| 78 | Add-On Service Data Contact Information Customer Account Data Marketing and Contact Preferences Personalization Details Professional Data Support and Feedback Legitimate Interest Consent Managing your participation in our events and webinars and granting you access to whitepapers and on-demand resources. | 78 | We object to any requests that are not properly issued. |
| 79 | Add-On Service Data Contact Information Customer Account Data Marketing and Contact Preferences Professional Data Support and Feedback Legitimate Interest Consent Collecting sales insights and performing lead scoring. | 79 | Reason for Sharing: To comply with legal obligations, respond to court orders or subpoenas in civil or criminal cases, enforce our agreements and policies, prevent fraud, and protect the safety and integrity of the platform or the public. |
| 80 | Contact Information Professional Data Publicly Available Sources Social Media Data Legitimate Interest Developing our business by updating, expanding, and analyzing our customer relationship records. | 80 | Corporate Transaction Parties Recipient Details: Prospective or actual buyers, merger partners, and their professional advisors (such as legal and financial consultants). |
| 81 | Contact Information Marketing and Contact Preferences Payment Information Professional Data Publicly Available Sources Social Media Data Legitimate Interest Consent Identifying potential job candidates. | 81 | Important Note: We will notify you in advance if required by law and provide information on any choices you have regarding the transfer of your data to a new entity. |
| 82 | Publicly Available Sources Social Media Data Legitimate Interest Developing or improving our Services, including anonymizing, de-identifying, pseudonymizing and aggregating personal data for this purpose. | 82 | Reason for Sharing: To conduct due diligence or complete a transfer of assets during a merger, sale, reorganization, or dissolution, ensuring business continuity. |
| 83 | Communications Usage Data Customer Content Customer Account Data Personalization Details Support and Feedback Legitimate Interest As otherwise authorized by you or our customer in Service specific terms or through your or our customer’s use and configuration of features in a product. | 83 | Aggregated, Anonymized & De-Identified Data We may derive aggregated, anonymized, or de-identified data from your personal data. |
| 84 | Data used will vary based on customer authorization Legitimate Interest Protecting the health and safety of our employees, visitors and our properties. | 84 | Because this data does not identify you, it is not considered personal data under the law. |
| 85 | Contact Information Customer Account Data Legal Obligation Protecting the rights and freedoms of individuals, meeting legal or regulatory obligations, including complying with valid court orders, disclosure requests, subpoenas, and other appropriate legal mechanisms. | 85 | We may use this data for any purpose. |
| 86 | Add-On Service Data Communications Usage Data Customer Content Device Information and IP Addresses Online Activity Information Marketing and Contact Preferences Payment Information Subscriber Records Telecommunication Data Security Identifier Legal Obligation Legitimate Interest How We Disclose Personal Data We disclose personal data to third parties in limited circumstances in order to provide the Services and to otherwise run our business. | 86 | We commit to never attempting to re-identify this information, and we will only share it with third parties who are legally or technically bound to keep it de-identified. |
| 87 | Below are the different scenarios under which we may disclose your data to third parties. | 87 | U.S. Supplemental Disclosure If you are a US resident interested in what personal data we have disclosed lately for our business purposes, here’s a list: Identifiers Commercial information Financial information Internet or other electronic activity information Geolocation information Professional or employment information By “our business purposes,” we mean that we only disclose personal data as described in this section. |
| 88 | Telecommunications Service Providers Twilio’s communications products provide an easier way for developers to build applications that make use of the publicly switched telephone network ('PSTN') to send communications. | 88 | International Transfers As a global platform, we move data across borders to ensure seamless connectivity, Service provision and business operations. |
| 89 | Therefore, we engage with a global network of telecommunications operators, aggregators, carriers and other communication service providers (collectively, “telecommunications service providers”) as necessary to route and connect those communications from the sender to the intended recipient. | 89 | While our primary processing facilities are in the U.S., we use regulator-approved frameworks to ensure personal data receives the same high level of protection everywhere it travels. |
| 90 | How telecommunications service providers handle this data is generally determined by their own policies and local regulations. | 90 | Whether we are transferring data internally within the Twilio group or externally to trusted third parties, we rely on the following legal safeguards: Data Privacy Frameworks (or “DPF”): Primary mechanism for transfers from the EU, UK and Switzerland to the U.S. Binding Corporate Rules (or “BCRs”): EU-approved rules covering transfers to Twilio group companies globally. |
| 91 | Where telecommunications service providers transmit the content of a communication, they function neither as data controllers nor data processors, instead they act simply as a conduit to transmit communication content. | 91 | EU, UK Standard Contractual Clauses (or “SCCs”): Transfer mechanisms used for EU and UK transfers where the DPF or BCR’s do not apply. |
| 92 | In the event telecommunications services providers process any personal data for their own purposes such as communications metadata required to transmit the message, or for billing or fraud prevention purposes, they also act as data controllers. | 92 | Brazil Standard Contractual Clauses (or “Brazil SCCs”): Primary mechanism for transfers from Brazil. |
| 93 | We may have to share Subscriber Records with local government authorities or local telecommunications carriers that provide connectivity services. | 93 | Global CBPR and PRP Systems (or “CBPR and PRP”): Twilio’s privacy practices (as described in this Notice) comply with the Global Cross Border Privacy Rules and Privacy Recognition for Processors, frameworks for organisations to ensure the protection of data transferred among participating economies. |
| 94 | However, we don’t share subscriber records for purposes other than this, and we treat these records with our highest confidentiality. | 94 | More on these programs can be found here . |
| 95 | Other Communications Service Providers For proper routing and connectivity, Twilio also enables sending or receiving communications through communications service providers that do not use the PSTN, these are referred to as Over-the-Top ('OTT') communications service providers. | 95 | For our customers, all international data transfers are governed by our Data Protection Addendum (“DPA”), which provides detailed information on our contractual safeguards. |
| 96 | If you or our customer chooses to use Twilio to send or receive communications by way of these providers, Twilio will disclose communications content and other data to these providers as necessary to route and connect those communications from the sender to the intended recipient. | 96 | Data Security & Retention Twilio protects personal data through a risk-based security framework and data lifecycle management processes. |
| 97 | How those OTT communications service providers, as data controllers, handle this data is determined by their own policies and local regulations. | 97 | Security Measures To protect against loss, unauthorized use, access, or disclosure, Twilio uses reasonable and appropriate security measures designed to protect personal data both online and offline. |
| 98 | Third Party Service Providers Twilio engages third-party vendors and service providers to carry out certain personal data processing functions on our behalf. | 98 | Risk-Based Protections: These measures vary based on the sensitivity of the personal data we collect, process, and store, as well as the current state of technology. |
| 99 | These providers are limited to only accessing or using personal data to provide services to us and must provide reasonable assurances they will appropriately safeguard the data. | 99 | Global Standards: All systems are governed by policies built on industry best practices, including ISO 27001 and NIST standards. |
| 100 | Add-On Partners Add-ons are additional features, functionality or services offered by Twilio’s Add-on partners (who are third parties not affiliated with Twilio). | — | Removed |
| 101 | Twilio may make Add-ons available through the Twilio Marketplace. | — | Removed |
| 102 | Some Add-ons may need to access or collect some of your information, including personal data. | — | Removed |
| 103 | If you choose to use an Add-on, Twilio will disclose your information to the Add-on partner so you can use the Add-on. | — | Removed |
| 104 | Twilio does not control Add-on partners’ use of your information and their use of your information will be in accordance with their own policies. | — | Removed |
| 105 | If you do not want your information to be disclosed to an Add-on partner, then you should not use the Add-on. | — | Removed |
| 106 | Twilio Group Members We may disclose your personal data among Twilio Group Members. | — | Removed |
| 107 | Twilio Group Members will only use the information as described in this Notice. | — | Removed |
| 108 | Twilio Group Members are listed in Appendix 1 in our Binding Corporate Rules . | — | Removed |
| 109 | Compliance with Legal Obligations We may disclose your personal data to a third party if: If we reasonably believe that disclosure is compelled by applicable law, regulation, legal process, or a government request (including to meet national security, emergency services, or law enforcement requirements); to enforce our agreements and policies; to protect the security or integrity of our Services; to protect ourselves, our other customers, or the public from harm or illegal activities, including security threats, spam and fraud; or to respond to an emergency which we believe in good faith requires us to disclose data to assist in preventing a death or serious bodily injury. | — | Removed |
| 110 | For more details, please see the procedure laid out in our Binding Corporate Rules . | — | Removed |
| 111 | If Twilio is required by law to disclose any personal data about you, we will notify you or our customers of the disclosure requirement to the extent legally permitted and where Twilio determines such disclosure will not interfere with an ongoing investigation. | — | Removed |
| 112 | Further, we object to information requests we do not believe were issued properly. | — | Removed |
| 113 | Business Transfers In connection with a corporate sale, merger, reorganization, dissolution or similar event, personal data about you may be part of the assets transferred or disclosed in connection with the due diligence for any such transaction. | — | Removed |
| 114 | If required by law, we will notify you prior to such a transfer and provide you with information about any choices you may have with respect to your personal data. | — | Removed |
| 115 | Aggregated, Anonymized or De-identified Data Aggregated, anonymized and de-identified data may be derived by Twilio from your personal data but is generally not considered personal data under data protection law as this data does not directly or indirectly reveal your identity. | — | Removed |
| 116 | We may use and disclose de-identified, anonymized or aggregated data to third parties. | — | Removed |
| 117 | We do not disaggregate or reidentify de-identified data. | — | Removed |
| 118 | International Data Transfers and Jurisdiction-Specific Provisions As a global organization, we may need to transfer your personal data to Twilio affiliates, contractors, service providers and third parties in various countries and jurisdictions around the world. | — | Removed |
| 119 | When we transfer your personal data, we take care to use appropriate safeguards to ensure your personal data remains protected. | — | Removed |
| 120 | Data Transfers to the United States and Elsewhere When you use our account portal, or our other Services, your personal data may be transferred to the United States, where our primary processing facilities are located, and possibly to other countries where we or our service providers operate. | — | Removed |
| 121 | Safeguards for Data Transfers Twilio employs appropriate safeguards for cross-border transfers of personal data, as required by applicable local law. | — | Removed |
| 122 | EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF and Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF“) As set forth by the U.S. Department of Commerce Twilio is officially certified under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and Swiss-U.S. DPF and relies on these certifications as its primary transfer mechanisms for transfers of personal data from the EU, UK and Switzerland to the U.S. Twilio adheres to the DPF principles for onward transfers of personal data to third parties and remains liable for damages caused by third parties under the DPF unless Twilio did not cause the event giving rise to damage. | — | Removed |
| 123 | The U.S. Federal Trade Commission has jurisdiction over Twilio’s compliance with the DPF. | — | Removed |
| 124 | To learn more about the DPF Program, and to view our certifications, please visit the DPF website . | — | Removed |
| 125 | Brazilian Standard Contractual Clauses Twilio uses the Brazilian Standard Contractual Clauses as the legal mechanism for transferring personal data from Brazil. | — | Removed |
| 126 | Twilio’s incorporation of the Brazilian SCCs, as well as a link to the Brazilian SCCs, is available at https://www.twilio.com/en-us/legal/data-protection-addendum . | — | Removed |
| 127 | If you are a Brazilian data subject, you have rights afforded to you by the Lei Geral de Proteção de Dados Pessoais (“LGPD”), specifically those outlined in Article 18. | — | Removed |
| 128 | Twilio has appointed a DPO who provides oversight of Twilio's compliance with applicable data protection laws and regulations. | — | Removed |
| 129 | You may exercise your rights by contacting our DPO at privacy@twilio.com . | — | Removed |
| 130 | Twilio’s Binding Corporate Rules Twilio has established and implemented a set of Binding Corporate Rules for internal transfers of personal data between Twilio Group Members in the European Union and Twilio Group Members elsewhere as a data controller. | — | Removed |
| 131 | Twilio’s BCRs have been approved by European Union Data Protection Authorities and are a commitment by Twilio to adequately protect personal data that Twilio processes regardless of where the information resides. | — | Removed |
| 132 | You can access Twilio’s BCR-Controller Policy here . | — | Removed |
| 133 | Where neither the EU-U.S. DPF, the UK extension to the EU-U.S. DPF, Swiss-EU DPF nor Twilio's BCRs apply, we rely instead on other data transfer mechanisms to transfer personal data outside the EEA, the UK, and Switzerland, such as Standard Contractual Clauses and the UK’s International Data Transfer Agreement. | — | Removed |
| 134 | Global CBPR & Global PRP Participation Twilio’s privacy practices, described in this Notice, comply with the Global Cross Border Privacy Rules (“CBPR”) and Global Privacy Recognition for Processors (“PRP”) Systems. | — | Removed |
| 135 | The global, CBPR and PRP systems provide a framework for organizations to ensure protection of personal data transferred among participating economies. | — | Removed |
| 136 | More information about this global framework can be found here . | — | Removed |
| 137 | How We Secure Personal Data To protect personal data from loss, or unauthorized use, access or disclosure, Twilio uses reasonable and appropriate security measures designed to protect the security of your personal data both online and offline. | — | Removed |
| 138 | These measures vary based on the sensitivity of the personal data we collect, process and store and the current state of technology. | — | Removed |
| 139 | All systems used to support our business are governed by Twilio’s Information Security Policy and Standards which are built on industry standards and best practices such as the ISO 27001 and NIST standards. | — | Removed |
| 141 | How Long We Retain Personal Data We endeavor not to retain personal data in a form which permits identification of individuals for longer than is necessary for the purposes for which that data is processed. | 101 | Retention Policy We endeavor not to retain personal data in a form which permits identification of individuals for longer than is necessary for the purposes for which that data is processed. |
| 142 | We retain personal data in accordance with Twilio's record retention policies and guidelines as revised and updated from time to time. | 102 | We retain personal data in accordance with Twilio’s record retention policies and guidelines. |
| 143 | Twilio will store your Customer Account Data as long as needed to provide you or our customer with the Services and to operate our business. | 103 | Customer Account Data is stored as long as needed to provide Services and operate our business. |
| 144 | If you ask Twilio to delete specific personal data from your Customer Account Data (see ‘ Your Rights and Choices About Your Data ’ below), we will honor this request, unless deleting that information prevents us from carrying out necessary business functions, such as billing for our services, calculating taxes, or conducting required audits. | 104 | Please note that requests to delete Customer Account Data are subject to the Limitations set forth in the Privacy Rights & Choices section of this Notice. |
| 145 | Your Rights and Choices About Your Data Depending on the data protection laws applicable to you, you may have the following rights in relation to your personal data that we process as a data controller: that we provide details about the categories of personal data that we collect about you, including how we collect and share it; that we provide you access to, and a copy of, the personal data we collect about you; that we update or correct any inaccurate personal data we have about you; that we delete the personal data we have about you; that we restrict processing of personal data about you; that we provide you with your personal data in a structured, commonly used format and to transmit that information to another controller, and where feasible, transmit the information directly; that we provide you with the right to object to the processing of personal data, including profiling; that we provide you with a free, easy mechanism to object to use of your personal information for direct marketing purposes; that you not be subject to a decision based solely on automated processing, including profiling, that produces legal effects or similarly affects your individual rights; to withdraw your consent; and to complain to a competent supervisory authority and/or to commence proceedings in a court of competent jurisdiction. | 105 | Managing Your Data We provide the tools you need to store, access, delete, and exercise control over your data. |
| 146 | Twilio will honor your rights subject to limitations in certain situations, such as where Twilio can demonstrate that it has a legal requirement or legitimate interest to process your data or can legitimately apply an exemption to the exercise of a right under applicable law. | 106 | The specific choices available to you depend entirely on which Service you use and how you have configured it. |
| 147 | More information about these rights can be found in our Binding Corporate Rules Controller Policy Rule 10 and Appendix 3 . | 107 | The Twilio Docs repository is a centralized hub that includes product-specific instructions for managing your data, plus step-by-step guides on our retention and deletion practices. |
| 148 | If you are a US resident interested in what personal data we have disclosed lately for our business purposes, here’s a list: Identifiers Commercial information Financial information Internet or other electronic activity information Geolocation information Professional or employment information By “our business purposes,” we mean that we only disclose personal data as we describe in the section " How We Disclose Personal Data " above. | 108 | Privacy Rights & Choices Depending on the applicable data protection laws, you may have the following rights in relation to the personal data that we process as a data controller: Table 6: Privacy Rights & Choices Privacy Rights & Choices Transparency & Control Rights Be Informed: Request clear details on data categories, sources, purposes, and third-party sharing. |
| 149 | Also, as described in the “How We Use Cookies & Other Tracking technologies” section below, we process personal data to deliver ads targeted to your interests on other companies’ websites and mobile apps. | 109 | Access: View or request a copy of your data. |
| 150 | Some of these activities may be considered “sharing” or “targeted advertising” under certain laws. | 110 | Correct: Update inaccurate or outdated information. |
| 151 | You have the right to opt out of the processing of your personal data for targeted advertising, and can do so by adjusting your preferences using our Cookie Preferences Tool located on the bottom right of the Twilio website you are visiting. | 111 | Delete: Request data destruction when no legal or legitimate business reason for retention exists. |
| 112 | Portability: Receive data in a structured, machine-readable format for transfer. | ||
| 113 | Object or Restrict: Oppose or limit data processing, including automated decision making and related profiling. | ||
| 114 | Withdraw Consent: Rescind your consent for processing at any time. | ||
| 115 | Important Note: Account closure or deletion is permanent and results in immediate loss of access to some or all data. | ||
| 116 | Requests are subject to limitations set forth below. | ||
| 117 | How to Exercise Rights: Self-service via Twilio console. | ||
| 118 | Customer Support for requests outside of self-service tools. | ||
| 119 | Marketing Communications & Targeted Advertising Rights Opt out of marketing communications; update your communications preferences; update cookie preferences; opt out of targeted advertising. | ||
| 120 | Important Note: Marketing opt-outs may take up to three days to process. | ||
| 121 | Essential service communications— such as billing or password resets—will continue unless your account is deactivated. | ||
| 122 | How to Exercise Rights: Click “unsubscribe” at the bottom of any Twilio marketing email. | ||
| 123 | Update your communications preferences . | ||
| 124 | For targeted advertising, see Cookies & Tracking Technologies section of this Notice. | ||
| 125 | Contact Customer Support . | ||
| 126 | Automated-Decision Making Rights Object to and request a human review of decisions Twilio makes about you based solely on automated processing, which currently includes account approvals and account suspensions related to abusive or fraudulent activity, or other decisions that significantly affect you. | ||
| 127 | How to Exercise Rights: Contact privacy@twilio.com . | ||
| 128 | Contact Customer Support . | ||
| 129 | Complaint Rights Submit a complaint to Twilio; file an official complaint with a government data protection regulator; take legal action through the relevant court system. | ||
| 130 | How to Exercise Rights: See Resolving Complaints section in this Notice. | ||
| 131 | Additional Rights Depending on your jurisdiction, you may exercise specific controls over your data: Sensitive Data: Restrict the use of sensitive personal data to what is strictly necessary for Service delivery. | ||
| 132 | Twilio currently limits processing to the specific purposes in this Notice or as permitted by law. | ||
| 133 | EU Rights: If you believe data transfers from Europe to our U.S. headquarters or other non-US companies breach our BCRs, you may lodge a complaint with the transferring Twilio company or its local supervisory authority, or bring a court action against the company. | ||
| 134 | U.S. CPNI: U.S. account holders can opt-out of the use of Customer Proprietary Network Information (e.g., call quantity, type, and destination) for marketing new services without affecting current services. | ||
| 135 | Brazil: Brazilian data subjects may exercise Article 18 rights by contacting our Data Protection Officer at privacy@twilio.com . | ||
| 136 | Security & Verification To protect your account, we must verify your identity before processing certain requests (e.g. deletion). | ||
| 137 | Verification Process: We typically ask for proof of your recent interactions with us or login verification. | ||
| 138 | Authorized Agents: If you use an authorized agent to make a request, we may require proof in the form of a power of attorney or written authority to act on your behalf. | ||
| 139 | Limitations In certain cases, these rights may be limited or an exemption may be applicable, such as where Twilio can demonstrate that it has a legal requirement or legitimate interest to process your data. | ||
| 140 | More information about these rights can be found in our Binding Corporate Rules Controller Policy Rule 10 and Appendix 3. | ||
| 141 | We will not discriminate against you or change the price of our Services if you exercise your rights, but if you ask us to delete your data, it may affect your ability to use our Services. | ||
| 142 | Important Note: If Twilio processes your data as a data processor on behalf of a customer, we will direct you to contact our customer to exercise your rights. | ||
| 143 | Children’s Privacy Our Services are not directed to or intended to be used by children (under the age of 13 in the U.S. and UK, or 16 in the EEA). | ||
| 144 | If we discover that a child has created an account, we will deactivate it and delete the data as quickly as possible. | ||
| 145 | If you believe we have inadvertently collected data from a child, please contact us at privacy@twilio.com with the subject line “Children”. | ||
| 146 | Cookies & Tracking Technologies We use cookies, pixels, web beacons, and similar tools to secure our website, analyze performance, and deliver relevant ads. | ||
| 147 | These tools help us recognize your device to make your experience more secure, efficient and tailored to your interests. | ||
| 148 | Under some U.S. state laws, this is considered "sharing" or "targeted advertising." Cookies Cookies are small files stored on your device that help us recognize you, making your experience more efficient and personalized. | ||
| 149 | We use both session cookies (which expire when you close your browser) and persistent cookies (which remain on your device for a set period). | ||
| 150 | Our cookies fall into three categories: Required: Essential for the website to function (e.g., secure log-in or remembering where you are at in the order process. | ||
| 151 | You cannot opt-out of required cookies. | ||
| 152 | Functional: Used to remember your choices (e.g, language or region) and analyze site usage to improve customer experience and site performance. | ||
| 153 | You can opt-out of functional cookies, however some site features may not work properly. | ||
| 154 | Advertising: Used to show you content and ads that are relevant to your interests. | ||
| 155 | You can opt-out of advertising cookies at any time. | ||
| 156 | Web Beacons (Pixels) Web beacons (or pixels) are 1x1 transparent images that can be embedded into our marketing emails and allow us to see if you opened an email or clicked a link, which helps us measure the effectiveness of our communications. | ||
| 157 | Your Controls: How to Manage Tracking Technologies We provide multiple ways for you to manage tracking technologies: Twilio Cookie Preferences Tool: The easiest way to manage your settings is by clicking the “Cookie Preferences” icon located in the footer of any Twilio website. | ||
| 154 | You also have the right to request the restriction of processing of your sensitive personal information. | 160 | Browser Settings: You can use your browser settings to opt out of Functional Cookies and Advertising Cookies. |
| 155 | Where applicable, the respective sensitive personal information will be marked accordingly and may only be processed by us for certain purposes. | — | Removed |
| 156 | At the current time, however, we do not use or disclose sensitive personal information for purposes other than those expressed in this Privacy Notice or otherwise permitted by applicable law, and these uses cannot be limited under California law. | — | Removed |
| 157 | You may have additional rights under our Binding Corporate Rules in the EU. | — | Removed |
| 158 | For example, where you believe your personal data has been transferred by an EU-based Twilio company to our US headquarters and processed by the US company in breach of the Binding Corporate Rules, you may have a right to: Lodge a complaint with the Twilio company that transferred your data outside Europe; Lodge a complaint with the supervisory authority in the same country as the Twilio company that transferred your data outside Europe; and Bring a court action against the Twilio company that transferred your data outside Europe. | — | Removed |
| 159 | If Twilio processes your personal data as a data processor on behalf of a customer, we will either direct you to contact our customer to exercise your rights. | — | Removed |
| 160 | How To Exercise Your Rights and Choices The following sections provide information about how to exercise certain rights in relation to your personal data. | — | Removed |
| 161 | To exercise any other rights, please contact us at privacy@twilio.com . | — | Removed |
| 162 | Accessing and Controlling Account Data As part of our Services, we provide you with a number of self-service features at no additional cost within the Twilio console itself, including the ability to access your data, update any incorrect data, download a copy of your data, delete your data, or restrict the use of your data. | — | Removed |
| 163 | You can make various choices about your Customer Account Data through the account portal when you log into your Twilio account or through the marketing preferences center. | — | Removed |
| 164 | Any other requests about your data you cannot make through these self-service tools, you can request by contacting Customer Support . | — | Removed |
| 165 | Closing Your Account and Deletion To request closure or deletion of your Twilio account, you can contact Customer Support . | — | Removed |
| 166 | Please be aware that closure or deletion of your Twilio account will result in you permanently losing access to your account and the data in the account. | — | Removed |
| 167 | After closure of your account, certain information associated with your account may remain on Twilio’s servers in an aggregated form that does not identify you. | — | Removed |
| 168 | Similarly, after you close your account, we will retain data — including personal data — associated with your account that we are required to maintain for legal purposes or for necessary business operations (see “ How Long We Retain Personal Data ” section above) until it’s no longer needed. | — | Removed |
| 169 | Identity Verification In some instances, we will need to verify your identity before honoring your request. | — | Removed |
| 170 | We will generally verify your identity by asking you to provide personal data related to your recent interactions with us. | — | Removed |
| 171 | Thereafter, we will process your request and inform you of any decisions we have made about your request. | — | Removed |
| 172 | Additionally, you may exercise your privacy rights through an authorized agent. | — | Removed |
| 173 | If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. | — | Removed |
| 174 | If you are an authorized agent seeking to make a request, please contact us at privacy@twilio.com . | — | Removed |
| 175 | We won’t discriminate against you or change the price of our services if you make a request, but if you ask us to delete your data, it may affect your ability to use our Services. | — | Removed |
| 176 | Customer Proprietary Network Information (CPNI) As an individual Twilio account holder or as an authorized representative of a Twilio customer in the US, you have the right to restrict Twilio’s use of CPNI . | — | Removed |
| 177 | To opt-out of the use of CPNI data related to your Twilio account to market other Twilio Services based on your usage of our Services, click here . | — | Removed |
| 178 | Please note that, if you have subscribed for the services on behalf of an organization, the CPNI relates to the service usage by that organization and not you individually. | — | Removed |
| 179 | Opting-out of the use of CPNI for marketing will not unsubscribe you from other types of marketing contacts from Twilio and will not affect the status of the services you currently have with us. | — | Removed |
| 180 | Your approval or opt-out of the use of your CPNI outside of the services to which you are already subscribed is valid until you affirmatively revoke or limit such approval. | — | Removed |
| 181 | Communication Preferences You can opt out of receiving marketing communications from us at any time through your marketing preferences page by clicking the “unsubscribe” link at the bottom of any marketing email you receive from Twilio. | — | Removed |
| 182 | You can also update your communication preferences using our online form or contact our Customer Support Team to communicate your choice to opt out. | — | Removed |
| 183 | Please note that it may take up to three days to remove your contact information from our marketing communications lists, so you may receive correspondence from us for a short time after you make your request. | — | Removed |
| 184 | You will not be able to opt out of service emails from us, such as password reset emails, billing emails, or notifications of updates to our terms, unless you deactivate your account. | — | Removed |
| 185 | How We Use Cookies and Other Tracking Technologies Twilio uses common information gathering tools such as cookies, web beacons, pixels and other similar tracking technologies to automatically collect information as you navigate our websites, your account or when you interact with emails we send to you. | — | Removed |
| 186 | Cookies A cookie is a small text file that is stored in your browser or elsewhere on your hard drive. | — | Removed |
| 187 | Cookies allow Twilio to identify your device as you navigate our websites or your account. | — | Removed |
| 188 | This makes navigating and interacting with our websites or your account more efficient, easy and meaningful for you. | — | Removed |
| 189 | Twilio uses both session and persistent cookies. | — | Removed |
| 190 | Session cookies are cookies that disappear from your computer or browser when you turn off your computer. | — | Removed |
| 191 | Persistent cookies stay on your computer even after you’ve turned it off. | — | Removed |
| 192 | The cookies on our websites fall into three categories: (1) Required Cookies, (2) Functional Cookies, and (3) Advertising Cookies. | — | Removed |
| 193 | To learn more about each category of cookie, you can visit our cookie consent tool by clicking on the “Cookie Preferences” link on the bottom right of the Twilio website you are visiting. | — | Removed |
| 194 | Manage Your Cookie Preferences Twilio uses a cookie consent tool, which you can utilize to customize your cookie preferences. | — | Removed |
| 195 | When you visit our website for the first time, a cookie consent banner will pop up and ask you to customize your cookie preferences. | — | Removed |
| 196 | If you decide to change your preferences at a later date, you can easily do so by clicking on the “Cookie Preferences” link on the bottom right of the Twilio website you are visiting. | — | Removed |
| 197 | Please note that Required Cookies cannot be disabled and if you decide to opt-out of Functional Cookies, certain functionality of our websites or your account may be impacted. | — | Removed |
| 198 | Any choices concerning cookies are browser and/or device specific. | — | Removed |
| 199 | If you clear your cookies from your browser on any of your devices, your choices will need to be reset. | — | Removed |
| 200 | Manage Cookies Using Your Browser In addition to using our Cookie Consent tool, you can use your browser settings to opt out of Functional Cookies and Advertising Cookies. | — | Removed |
| 203 | Universal Opt-Out Mechanisms Global Privacy Control (GPC) and Do Not Track (DNT) are tools that you can use to inform websites of your privacy preferences in regard to ad trackers. | 163 | Universal Opt-Outs: Global Privacy Control (“GPC”) and Do Not Track (“DNT”) are tools that you can use to inform websites of your privacy preferences in regard to ad trackers. |
| 207 | Opt Out of Advertising Cookies To learn more about how to opt out of targeting and advertising cookies, you can go to the Your Online Choices page, the Network Advertising Initiative page, and the Digital Advertising Alliance’s Consumer Choice page. | 167 | Ad Industry Tools: To learn more about how to opt out of targeting and advertising cookies, you can visit Your Online Choices , the Network Advertising Initiative , and the Digital Advertising Alliance . |
| 208 | These opt-out tools are provided by third parties, not Twilio. | 168 | Service Specific Privacy Notices If you utilize any of the following Services, we are required to provide additional details as to how we use the specified data categories and the purpose. |
| 209 | We do not control or operate these tools or the choices that advertisers and others provide through these tools. | 169 | Additional information regarding the products can be found at the links below or in the Twilio Docs . |
| 210 | Web Beacons Twilio also uses web beacons to gather data about your use of our websites, your account, and how you interact with emails we have sent to you. | 170 | Authy The Authy service is our standalone two-factor authentication (“2FA”) service for desktop and mobile. |
| 211 | Web beacons are clear electronic images that can recognize certain types of data on your computer, like when you view a particular website tied to the web beacon, and a description of a website tied to the web beacon. | 171 | The Authy apps generate one time passwords and push notifications to provide an additional layer of security for your Authy-compatible accounts. |
| 212 | Additionally, we may put web beacons in marketing emails that notify us when you click on a link in the email that directs you to a Twilio website. | 172 | Authy’s 2FA can be used independently or with applications that integrate directly with Authy 2FA API. |
| 213 | Children Our Services are not directed to or intended to be used by children (under the age of 13 in the US and UK, or 16 in the EEA). | 173 | Due to the nature of the Authy service, Twilio collects the following additional personal data elements to our other Services: Identifiers To create an Authy account, we require a phone number. |
| 214 | We do not knowingly permit children to sign up for a Twilio account. | 174 | We send a verification code to that phone number to be sure that the person creating the Authy account has control over the device. |
| 215 | If we become aware that a child has signed up for an account, we will take reasonable steps to deactivate the account and remove their personal data from our records as quickly as possible. | 175 | This phone number serves as your “primary device and the unique identifier for your Authy account. |
| 216 | If you believe an underage person has signed up for a Twilio account, please contact us at privacy@twilio.com with the subject line “Children”. | 176 | We use that phone number to identify you, provide 2FA services, and maintain security and anti-fraud logs. |
| 217 | Automated Decision Making Automated decision-making occurs when an electronic system uses personal data to make a decision about you, without human involvement. | 177 | We also collect your email address for identity verification and account recovery purposes. |
| 218 | Twilio uses automated decision-making leveraging a variety of signals derived from records we collect or obtain from third party vendors, to help monitor, identify, and suspend accounts sending spam or engaging in other abusive or fraudulent activity. | 178 | Device Information When you download and open the Authy desktop or mobile app, we automatically collect your device type and unique device identifier. |
| 219 | We may also use this information to evaluate your account application and make decisions about whether to approve or decline. | 179 | This ensures we deliver the correct version of the app, as well as the appropriate technical support. |
| 220 | If your account is suspended or not approved under these circumstances you will be notified and given an opportunity to request human review of the decision. | 180 | We also use your device information to ensure proper delivery, maintenance, and security of the Authy app. |
| 221 | We may rely on other automated decision-making where: We have notified you of the decision and provided you with the opportunity to request a human review of the decision It is necessary to perform a contract with you and appropriate measures are in place to safeguard your rights We have your consent and we have put in place appropriate measures to safeguard your rights How to Contact Us If you have any questions, concerns or complaints about this Notice or our data protection practices, please do not hesitate to contact our Data Protection Officer by emailing us at privacy@twilio.com or by writing to us at any of the following addresses: Worldwide Headquarters Twilio Inc. 101 Spear Street, 5th Floor San Francisco CA 94105 EEA Headquarters Twilio Ireland Limited 70 Sir John Rogerson's Quay Dublin 2 D02 R296, Ireland Complaints We will endeavor to resolve questions, concerns or complaints you raise with us in accordance with our Complaints Handling Procedure . | 181 | Login History and Authy Account History When you use an Authy token to log into an account, whether generated within the app or sent to your phone, we collect information associated with that activity. |
| 222 | In the unlikely event that we are unable to resolve your concern, you can find information about your options to seek assistance through independent dispute resolution mechanisms or complaints to your local data protection authority here . | 182 | This includes your IP address, the application you accessed, and the timestamp of the login. |
| 223 | In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Twilio commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States, the European Union, the United Kingdom, and/or Switzerland. | 183 | We also maintain a log of any changes made to the phone number or email address associated with your account. |
| 224 | If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. | 184 | We collect this information to monitor for suspicious activity and to verify your identity if we suspect your account may be compromised. |
| 225 | The services of JAMS are provided at no cost to you. | 185 | Geolocation information If you have location services enabled, we collect your location based on your IP address. |
| 226 | You have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding DPF compliance that are not resolved by any of the other DPF mechanisms. | 186 | We use this information for anti-fraud purposes, to detect suspicious activity, and as an additional data point to verify your identity in the event of a suspected account compromise. |
| 227 | You can find more information in the DPF ANNEX-I-introduction. | 187 | Frontline Services To use the Frontline services, you must log in to the Frontline app using a third party account through your Single Sign-On provider. |
| 228 | If your question or complaint relates to personal data we process as a data processor on behalf of a customer, we will direct you to contact our customer to address your question or complaint. | 188 | Authentication is managed by that third party, and we only collect the information you expressly authorize when you link your account with the Frontline app. |
| 229 | Changes to Our Privacy Notice We will periodically review this Notice and may change it to address legal, technical or business development requirements or make clarifications. | 189 | We only access the information you or our customers provide, and we use it solely for the purposes for which it was shared. |
| 230 | When we change this Notice, the most current version will be available at https://www.twilio.com/legal/privacy with the date indicating when it was last updated. | — | Removed |
| 231 | If we make material changes that affect your rights, we will provide you with advance notice, such as by posting a message in the Twilio console or sending an email to the address we have on file for you. | — | Removed |
| 232 | We will comply with applicable law with respect to any changes we make to this Notice. | — | Removed |
| 233 | We will also seek your consent to material changes, where required by applicable law. | — | Removed |
| 234 | Twilio Product Privacy Twilio offers a range of industry-leading communications and customer data platform services to our customers. | — | Removed |
| 235 | Depending on the Service, Twilio may be a data controller and data processor of personal data used to provide the Services. | — | Removed |
| 236 | Twilio processes personal data (Communications Usage Data and Customer Content) for most of our Services as a data processor acting on the instruction of our customer and in accordance with the terms of our agreement with a customer, our Data Protection Addendum , and service specific terms. | — | Removed |
| 237 | Our Services provide customers with ways to control, access and secure their data. | — | Removed |
| 238 | We also offer customers the ability to store, delete, access, or exercise other choices about their personal data. | — | Removed |
| 239 | The ability to make these choices depends on the Service being used and how it is being used by a customer. | — | Removed |
| 240 | Customers are referred to our API docs for each of our Services, along with SendGrid’s documentation and Segment’s documentation to find more detailed information about managing personal data collected and stored in connection with their use of our Services. | — | Removed |
| 241 | We also provide an overview of our retention and deletion practices, including how to delete data you control in our support documentation . | — | Removed |
| 242 | We provide information about the security measures we use to protect our customer’s data in our Security Overview , and if you are located in a country that requires you to obtain information about our supplemental measures, you may read more about those measures here . | — | Removed |
| 243 | For some of the Services we also act as a data controller where disclosed and agreed to by our customer in the agreement, Data Protection Addendum, product specific terms or via the customers’ use and configuration of a product or feature.As a data controller, Twilio is responsible for the processing of the personal data. | — | Removed |
| 244 | For more detail on our Services, please find information below or by visiting our products page . | — | Removed |
| 245 | Authy The Authy service is our standalone two-factor authentication (2FA) service for desktop and mobile. | — | Removed |
| 246 | The Authy apps generate one time passwords and push notifications that can be used as a part of a two-step verification process with your Authy-compatible accounts to add another layer of security. | — | Removed |
| 247 | Authy’s 2FA can be used on its own or with applications that directly integrate with Authy’s 2-factor authentication API. | — | Removed |
| 248 | Due to the nature of the Authy service, Twilio collects the following additional personal data elements to our other Services: Identifiers Once you open the Authy app, we ask you to provide us with a phone number to create your Authy account. | — | Removed |
| 249 | We send a verification code to that phone number to be sure that the person creating the Authy account also has control over the phone number entered. | — | Removed |
| 250 | This phone number is considered your “primary device,” and will be the identifier for your Authy account. | — | Removed |
| 251 | We use that phone number to identify you, to provide you 2FA services, and to maintain logs for security and anti-fraud purposes. | — | Removed |
| 252 | We also collect your email address, and we use it for identity verification and account recovery purposes. | — | Removed |
| 253 | Device Information When you download and open the Authy desktop or mobile app, we automatically collect information about the type of device you have downloaded the app on and your device identifier. | — | Removed |
| 254 | We collect this to ensure we deliver the right version of the app for your device and so that we can provide appropriate follow up support as necessary. | — | Removed |
| 255 | We also use your device information to ensure proper delivery of our service and to provide and deliver support and maintenance of the Authy app. | — | Removed |
| 256 | Login History and Authy Account History When you use an Authy token to log into an account, whether the token was generated on the app or one sent to you via your phone number, we collect and keep information associated with your login activity including information like your IP address, what application you logged in to, that you logged in, and when. | — | Removed |
| 257 | If you change your phone number or email associated with your Authy account, we will also keep a log of that. | — | Removed |
| 258 | We collect this information to monitor for suspicious activity and also as another piece of information that could be used to verify your identity if we suspect your account may be compromised. | — | Removed |
| 259 | Geolocation information If you have location services turned on, we collect your location based on your IP address. | — | Removed |
| 260 | We use this information for anti-fraud purposes, to check for suspicious activity and as another piece of information we can use to verify your identity if we suspect your account may be compromised. | — | Removed |
| 261 | Frontline Services To use the Frontline services, you must log in to the Frontline app using a third party account (through your Single Sign-On provider). | — | Removed |
| 262 | The authentication of your login details is handled by that third party and we only collect the information you expressly agree to share with us at the time you give permission to link the Frontline app with the third party account. | — | Removed |
| 263 | We only gather the information you and our customers give us access to, and we only use it for the purposes for which you and our customers have provided it to us. | — | Removed |
| 265 | SendGrid Services The SendGrid services also collect additional data in the form of web beacons placed in the body of emails delivered using the SendGrid platform. | 191 | SendGrid Services The SendGrid Services also collect additional data through web beacons placed in the body of emails delivered via our platform. |
| 266 | This allows us to keep track of whether or not an email has been delivered, opened, clicked on, whether it bounced or was treated as spam. | 192 | This allows us to track email engagement, including whether a message was delivered, opened, or clicked, bounced, or marked as spam. |
| 267 | You can learn more about web beacons in the section titled “ How We Use Cookies and Other Tracking Technologies ” above. | 193 | You can learn more about our use of web beacons in the section titled “ Cookies and Tracking Technologies ” above. |
| 268 | Voice Intelligence Voice Intelligence incorporates artificial intelligence and machine learning to transcribe and analyze voice calls into a structured format that allows our customers to drive their business processes. | 194 | Conversational Intelligence Conversational Intelligence incorporates artificial intelligence and machine learning to transcribe and analyze voice calls into a structured format that allows our customers to drive their business processes. |
| 269 | To translate voice calls into structured content, Twilio processes certain data as a controller, including personal data contained in voice calls disclosed to us by our customer through their use of the service. | 195 | To translate voice calls into structured content, Twilio processes certain data, including personal data within voice calls, as an independent controller. |
| 196 | This includes information provided to us by our customers through their use of the Conversational Intelligence Service. | ||
| 197 | How to Contact Us If you have questions about this Notice or our privacy practices, please contact our Data Protection Officer (“DPO”) at privacy@twilio.com. | ||
| 198 | You can also write to us at our global headquarters: Worldwide Headquarters Twilio Inc. 101 Spear Street, 5th Floor San Francisco CA 94105 EEA Headquarters Twilio Ireland Limited 78 Sir John Rogerson’s Quay, Dublin 2 D02 R296, Ireland Resolving Complaints We aim to resolve any questions or concerns in accordance with our Complaints Handling Procedure . | ||
| 199 | If you have a question or wish to lodge a complaint (whether related to our privacy practices or otherwise), please contact the Twilio Privacy Team at privacy@twilio.com or by mail at the physical addresses referenced under “How to Contact Us.” We encourage you to use these direct channels to ensure a prompt response, however, we will address complaints received through any other means. | ||
| 200 | If we are unable to resolve your concern to your satisfaction, you may pursue further resolution through the following channels: Data Protection Frameworks (“DPF”): For practices covered by our DPF certification, contact our U.S.-based third party dispute resolution provider (free of charge) at https://www.jamsadr.com/DPF-Dispute-Resolution . | ||
| 201 | Under certain circumstances, you may also invoke binding arbitration. | ||
| 202 | For details, see Annex I of the EU-U.S. Data Privacy Framework Principles . | ||
| 203 | Global CBPR and PRP Systems: For unresolved concerns related to our CBPR or PRP certifications, contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request . | ||
| 204 | Data Protection Authorities: You may have the right to lodge a complaint with a local data protection authority or commence court proceedings under your local laws. | ||
| 205 | EEA Residents: You have the right to lodge a complaint with the Data Protection Commissioner in Ireland, where our EEA headquarters are located. | ||
| 206 | If your complaint relates to a company using our Services (e.g., you want to stop receiving emails from a specific brand), please contact that company directly. | ||
| 207 | As a data processor, we cannot resolve complaints about our customers' data practices. | ||
| 208 | Changes to Our Privacy Notice We periodically review and update this Notice to make clarifications or to reflect legal, technical, or business changes. | ||
| 209 | The latest version will always be posted at twilio.com/legal/privacy with the “Last Updated” date at the top. | ||
| 210 | If we make significant changes that affect your rights, we will provide advance notice via the Twilio console or by email and obtain your consent where legally required. | ||
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