Diff: Twilio Privacy Notice

Old version

March 28, 2026 06:06 UTC

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New version

April 10, 2026 06:06 UTC

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Change Summary

Twilio updated its Privacy Notice on April 10, 2026, significantly restructuring how the document is written and organized. The old notice had a straightforward explanation of data collection practices; the new version introduces new section headings and reframes the introduction with more marketing-oriented language while retaining core privacy commitments like Binding Corporate Rules. The rewrite affects how clearly privacy rights and data practices are communicated to everyday users.

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61 Sentences added

120 Sentences removed

141 Sentences modified

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	March 28, 2026 06:06 UTC			April 10, 2026 06:06 UTC
	669	An icon of a down chevron		669	An icon of a down chevron
	670	Acknowledgement and Waiver		670	Acknowledgement and Waiver
	671	Twilio Privacy Notice		671	Twilio Privacy Notice
n	672	Last Updated: August 14, 2025 (View the prior version of our privacy notice here	n	672	Last Updated: April 09, 2026 (View the prior version of our privacy notice here)
	>	)
	673	Introduction		673	Introduction & Scope
	674	The Privacy program of Twilio Inc. and its group companies (‘Twilio’, ‘we’ or ‘o		674	Building the Future of Engagement. Twilio powers the world’s most important comm
	>	ur’) is built on our Binding Corporate Rules ('BCRs'), which serve as our code o		>	unications by seamlessly unifying data and connectivity. We protect the personal
	>	f conduct that governs our global processing of personal data.		>	data flowing through our platform by centering our privacy program on Binding C
				>	orporate Rules (“BCRs”). These BCRs serve as our global code of conduct, mandati
				>	ng how Twilio Inc. and its group companies (“Twilio”, “we”, or “our”) process pe
				>	rsonal data wherever we operate.
	675	In order to provide products and services ('Services') to our customers and cond		675	Trust Through Transparency. In a digital economy defined by speed and scale, tra
	>	uct our day-to-day business operations, including the operation of our websites,		>	nsparency is essential to who we are and how we operate. It is the foundation of
	>	we collect, use and share, or otherwise process personal data about our custome		>	the trust we build with the millions of developers and organizations who rely o
	>	rs, our customers’ authorized users ('end user') and their customers, our websit		>	n Twilio. To honor that trust, we explain our privacy practices in a clear, acce
	>	e visitors and business contacts.		>	ssible, and easy-to-understand way, and let you know how to exercise your rights
				>	in relation to your data.
	676	Personal data is any information that directly identifies you, such as your name		676	Putting Privacy Into Practice. To provide our products and services (collectivel
	>	and email address, or that indirectly identifies you, for example a phone numbe		>	y, our “Services”) and conduct our day-to-day business operations, we collect, s
	>	r or device identifier.		>	tore, 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 id
				>	entifier).
	677	The personal data we may collect and process about you varies depending on our r		677	Depending on which Services are used, we process personal data for:
	>	elationship with you. We may have a direct relationship with you because you hav
	>	e 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.
	678	We take privacy, data protection and our legal obligations very seriously. We ar		678	Customers: Individuals or entities who contract with us to use our Services.
	>	e committed to being transparent with you about how we use personal data. This P
	>	rivacy Notice ('Notice') aims to describe our privacy practices in a clear, acce
	>	ssible and easy to understand way and to let you know how you can exercise your
	>	rights in relation to your data.
	679	This Notice applies where Twilio processes personal data as a data controller, i		679	End Users: Individuals who interact with our customers via our Services (e.g., r
	>	n connection with the Services we provide to our customers and the operation of		>	eceiving a text or authenticating an identity).
	>	our business, including our websites. As a data controller, we determine the pur
	>	pose (why) and means (how) of personal data processing and are ultimately respon
	>	sible for the correct handling of your data, in accordance with applicable law.
	>	This Notice describes our general privacy practices. Depending on how you intera
	>	ct with us or the specific services you use, additional privacy notices may appl
	>	y. These supplemental notices will be provided to you at or before the time we c
	>	ollect your personal data. These supplemental notices should be read together wi
	>	th this Notice and are incorporated by reference.
	680	This Notice does not apply to the Personal Data we process in relation to job ap		680	Prospective Customers & Visitors: Individuals who visit our websites, attend our
	>	plicants. This is covered by our Global Applicant Privacy Notice.		>	events, or engage with our sales teams.
	681	We also process personal data for most of our Services as a data processor. As a		681	Our personal data responsibilities depend on how you use our Services or interac
	>	data processor, we process personal data related to our customers' employees, e		>	t with us:
	>	nd users and customers on behalf of our customers to provide Services to them in
	>	accordance with their instructions. These instructions are set out in our custo
	>	mer agreements, Data Protection Addendum, service specific terms or through a cu
	>	stomer's use or configuration of a product feature. You should contact these org
	>	anizations directly for information about how they process your personal data as
	>	a data controller and to exercise your rights in relation to that data.
	682	Contents of our Privacy Notice		682	Twilio As Data Controller: We determine the “how” and the “why” personal data is
				>	used in relation to our Services, accounts, websites, and operations. In these
				>	cases, we are directly responsible for protecting the data.
				683	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. In these cases, we must use and protect personal
				>	data in line with those directions.
				684	This Privacy Notice (“Notice”) applies when Twilio acts as a Data Controller.
				685	What This Notice Doesn't Cover
				686	Supplemental Notices: Specific Services or business operations may have addition
				>	al privacy terms provided at the time of collection.
				687	Job Applicants: This Notice does not apply to candidates. Please see our Global
				>	Applicant Privacy Notice.
	683	Personal Data We Process		688	What Personal Data We Process
	684	How We Process Personal Data		689	An icon of a plus symbol
	685	How We Disclose Personal Data		690	An icon of a minus symbol
	686	International Data Transfers		691	To deliver our Services, manage our business operations, drive research and deve
				>	lopment, secure our platform and networks, and prevent fraud, we process persona
				>	l data from three sources: 1) data you share directly; 2) data we generate or co
				>	llect automatically; and 3) data from third parties. 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:
	687	How We Secure Personal Data		692	Table 1: Data You Share Directly
	688	How Long We Retain Personal Data		693	Personal data you provide for account setup, purchases, or support.
	689	Your Rights and Choices About Your Data		694	Contact Data
	690	How To Exercise Your Rights and Choices		695	Name, company name, business address, phone number, email address, job title, in
				>	dustry, social media profile URLs.
	691	How We Use Cookies and Other Tracking Technologies
	692	Children
	693	Automated Decision-Making
	694	How to Contact Us
	695	Changes to Our Privacy Notice
	696	Twilio Product Privacy
	697	Personal Data We Process
	698	The personal data we collect about you depends on your relationship with us and
	>	the purposes for which we process that personal data. The following describes th
	>	e types of personal data that we collected and disclosed for a business purpose
	>	in the preceding 12 months.
	699	Personal Data You Share With Us Directly
	700	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 o
	>	ur 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. We also ask you to create a password and name your account (or acco
	>	unts, if you have more than one).
	701	Customer Account Data - We process certain personal data to manage our relations
	>	hip with you and administer you or your company’s account. This includes purchas
	>	e 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. W
	>	e 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 Cust
	>	omer or other identity verification purposes.
	702	Customer Content - We receive and store the content of communications received f
	>	rom you or our customers and other personal data uploaded to the Services or gen
	>	erated for our customers’ use as part of the Services, which we may be authorize
	>	d by you or our customer to use, where necessary for specific legitimate busines
	>	s purposes and in accordance with applicable law.
	703	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.
	704	Payment Information - In connection with Services you pay for, we ask you to pro
	>	vide our payment processor with your payment method information like a credit ca
	>	rd or your Paypal account and your billing address. Our payment processor, actin
	>	g on our behalf, gathers this so we can bill you for your use of our Services. O
	>	ur payment processor will share your billing address with Twilio for this purpos
	>	e.
	705	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.
	706	Professional Information - The information we process about you with respect to
	>	your employment or profession, including company, job title, email address, phon
	>	e number and online business networking profile.
	707	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, na
	>	me, physical address, or other identification information. For example, to use o
	>	ur Trust Hub or to obtain a phone number in certain countries, local law may req
	>	uire us to have a physical service address on file for the individual who will b
	>	e using that Twilio number, whether that’s you or our customer's end user.
	708	Support and Feedback - When you interact with us on our websites including throu
	>	gh 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. You may also provi
	>	de us with feedback about our Services in surveys and questionnaires. We will le
	>	t you know when a call may be recorded, in accordance with applicable law.
	709	Personal Data We Generate or Collect Automatically
	710	Communications Usage Data - When you or our customers use Twilio communications
	>	products, we collect electronic communications metadata, such as phone numbers a
	>	nd routing information, the source and destination of a communication, location
	>	of the device generated in the context of delivering the communication, date, ti
	>	me, duration and type of communication, status of the message, error data and tr
	>	affic records.
	711	Device Information and IP Addresses - When you use our account portal, we collec
	>	t your IP address and device information through tracking technologies like cook
	>	ies, web beacons, pixels, and similar technologies. We also collect IP addresses
	>	when you make requests to our APIs and in our server logs. Additionally, we col
	>	lect information about your device, such as your computer or mobile device opera
	>	ting system type and version number, manufacturer and model, browser type, scree
	>	n resolution, unique identifiers, and general location information such as city
	>	or town when you use our account portal. We do not collect precise geolocation i
	>	nformation.
	712	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 page
	>	s visited, products you view or search for, page response times, download errors
	>	, length of visits to certain pages, page interaction information, IP address.
	713	Security Identifiers or SIDs - When you sign up for an account with Twilio, we’l
	>	l automatically assign you and each of your accounts a unique security ID and ge
	>	nerate an API token for each account. We keep a record of these credentials so w
	>	e know it is you making the requests when your application makes requests to our
	>	API using these credentials.
	714	Customer Proprietary Network Information - When you use certain US voice-based c
	>	ommunications services, Twilio collects information associated with your service
	>	usage. This includes information such as the number of phone calls, call destin
	>	ations, call locations, type, and service configuration, and is known as Custome
	>	r Proprietary Network Information ('CPNI'). CPNI does not include information su
	>	ch as your name, address, phone number, or the content of phone calls. We use CP
	>	NI to market Twilio-related Services to which you are not already subscribed unl
	>	ess you have exercised your right to opt out. For information about your CPNI ch
	>	oices, see the section “Your Rights and Choices About Your Data” below.
	715	Personal Data Collected From Other Sources
	716	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 cont
	>	ractual obligations. 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 p
	>	articipate in events and webinars of which Twilio is a sponsor.
	717	Professional Data - We collect certain personal data such as employment or profe
	>	ssional information from sources other than you. We may combine this data with o
	>	ther personal data that you share with us.
	718	Publicly-Available Sources - We may also use publicly-available information abou
	>	t you that we have gathered through services like LinkedIn, or we may obtain inf
	>	ormation about you or your company from third party providers, such as your indu
	>	stry, the size of your company, and your company’s website URL.
	719	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.
	720	Telecommunication Data - We receive communication-related data from telecommunic
	>	ations operators, aggregators and carriers that may include phone type, carrier
	>	history, SIM status and history, city and/or country where phone was first regis
	>	tered, contract and account type, IP address city and/or country and a validatio
	>	n result of personal data provided by our customer and whether it matches data h
	>	eld by the carrier.
	721	How We Process Personal Data
	722	The purposes for which we process personal depends on your relationship with us.
	>	We only use personal data that is necessary to fulfill the specified purposes l
	>	isted below as applicable to you and in accordance with applicable data protecti
	>	on law.
	723	Purpose
	724	Personal Data Processed
	725	Legal Basis for Processing
	726	Creating and managing accounts, including verification of the identity of our cu
	>	stomer’s end user for Know-Your-Customer (KYC) or identity verification purposes
	>	.
	727	Add-On Service Data
	728	Contact Information
	729	Customer Account Data		696	Customer Account Data
n	730	Online Activity Information	n	697	Purchase & Payment Data
	731	Payment Information		698	Purchase history, credit/debit card details, billing address, PayPal account inf
				>	o.
	732	Professional Information		699	Service Provisioning Data
				700	Application details regarding intended use of certain Services (e.g., Short Code
				>	s)
				701	Security & Verification Data
				702	Username, password, account names, unique Account IDs, API tokens, government-is
				>	sued IDs.
	733	Subscriber Records		703	Subscriber Records
n	734	Security Identifier	n	704	Proof of identity and physical service address and other information as required
				>	by local laws to provide specific services (e.g., phone numbers).
				705	Customer Content
				706	Communications content (e.g., email subject, email body, text body, media files)
				>	, transcripts, recordings, communications logs, and other data uploaded to the S
				>	ervices.
				707	Marketing & Communications Data
				708	Privacy settings, communication preferences, event attendance info, dietary requ
				>	irements, or accessibility needs for in-person events.
				709	Customer Support & Feedback Data
				710	Call recordings with our support agents, transcribed conversations conducted wit
				>	h AI chatbots, feedback and survey responses.
				711	Table 2: Data We Generate or Collect Automatically
				712	Personal data we automatically collect or generate in order to route communicati
				>	ons, optimize performance, and prevent fraud, including through tracking technol
				>	ogies like cookies and web beacons.
				713	Communications Usage Data
				714	Electronic Communications Metadata
				715	Sender/recipient information, routing details, timestamps, communication type, d
				>	uration, message status & activity (e.g., delivered, opened, bounced, spam, clic
				>	ks, or unsubscribes), error data and traffic records.
				716	Customer Proprietary Network Information (“CPNI”)
				717	U.S. only: A subset of usage data (e.g., call destinations, locations, and confi
				>	gurations) that excludes names, addresses, and call content. Learn more about CP
				>	NI and how to exercise your rights here.
				718	Device Data
				719	IP address, OS type/version, browser type, screen resolution, CPU count, manufac
				>	turer/model, device IDs, time zone, IP address-based location of the device gene
				>	rated in the context of delivering a communication, and general location (City/T
				>	own) when you use our account portal and make requests to our APIs and activity
				>	logs. Precise geolocation data is not collected.
				720	Online Activity Data
				721	Browsing behavior, page and feature interactions, products viewed or searched, r
				>	esponse times, download errors.
				722	Table 3: Data From Other Sources
				723	Personal data we receive from third parties, trusted partners, telecommunication
				>	s operators, aggregators, or carriers to provision accounts, validate identities
				>	, and enrich our Services.
				724	Partner-Sourced Data
				725	Contact Data provided by event partners and co-sponsors, as well as marketing an
				>	d lead generation partners. Data may also include information you choose to shar
				>	e via third-party forms or advertisements, which may be auto-populated from your
				>	profile on those platforms and which may include location related data.
				726	Solution Provider-Sourced Data
				727	Contact Data and Customer Account Data shared by our solutions providers - Indep
				>	endent Software Vendors (“ISVs”) and Managed Service Providers (“MSP”) - to help
				>	us process orders and set up sub-accounts.
				728	Data Enrichment Services
				729	Contact Data obtained from third-party data providers and enrichment services an
				>	d data that is publicly available. We may combine this Contact Data with other d
				>	ata we have collected about you.
				730	Third-Party Authentication Data
				731	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 per
				>	mitted by your individual privacy settings on those platforms.
				732	Telecommunications Data
				733	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 ope
				>	rator, aggregator or carrier records.
				734	How and Why We Use Your Data
				735	An icon of a plus symbol
				736	An icon of a minus symbol
				737	The specific reasons we process personal data depend on your relationship with u
				>	s. We only process the personal data necessary to fulfill the purposes listed be
				>	low, and we do so in accordance with applicable data protection laws..
				738	In the past 12 months, we have processed personal data for the following busines
				>	s purposes:
				739	Table 4: Data Use Categories & Legal Basis for Processing
				740	Data Use Categories & Legal Basis for Processing
				741	Account Management
				742	Purpose:
				743	Creating and managing your Twilio account throughout your customer lifecycle.
				744	Examples:
				745	Determining service eligibility; verifying identities (KYC); billing and relatio
				>	nship management; and, sending essential administrative or Service updates.
				746	Personal Data Processed:
				747	Contact Data
				748	Customer Account Data
				749	Solution-Provider Sourced Data
				750	Third-Party Authentication Data
				751	Legal Basis for Processing:
				752	Consent
	735	Legitimate Interest		753	Legitimate Interest
	736	Legal Obligation		754	Legal Obligation
n	737	Carrying out Twilio’s core business operations, such as account administration,	n	755	Business Operations
	>	accounting, auditing and compliance, business analytics, filing taxes, finance,
	>	forecasting, consolidated management and reporting, product strategy and revenue
	>	planning.
	738	Add-On Service Data		756	Purpose:
	739	Professional Information		757	Managing essential business functions.
				758	Examples:
				759	Financial management (accounting, auditing, and revenue planning); strategic gro
				>	wth (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 proper
				>	ties.
				760	Personal Data Processed:
				761	Contact Data
	740	Customer Account Data		762	Customer Account Data
n	741	Support and Feedback	n
	742	Customer Content
	743	Communications Usage Data		763	Communications Usage Data
n	744	Payment Information	n	764	Customer Support & Feedback Data
	745	Publicly Available Sources
	746	Social Media Data
	747	Legitimate Interest
	748	Billing and relationship management.
	749	Add-On Service Data
	750	Contact Information
	751	Communications Usage Data
	752	Payment Information
	753	Legitimate Interest
	754	Providing, optimizing and maintaining our Services and, platform, including debu
	>	gging and troubleshooting.
	755	Add-On Service Data
	756	Subscriber Records
	757	Online Activity Information		765	Online Activity Data
	758	Communications Usage Data		766	Solution-Provider Sourced Data
	759	Customer Content		767	Data Enrichment Services
	760	Device Information and IP		768	Third-Party Authentication Data
	761	Addresses		769	Legal Basis for Processing:
	762	Security Identifier		770	Consent
	763	Legitimate Interest
	764	Preventing, detecting and investigating security incidents and managing the secu
	>	rity of Twilio’s platform, services, websites and accounts.
	765	Add-On Service Data
	766	Communications Usage Data
	767	Customer Content
	768	Device Information and IP
	769	Addresses
	770	Online Activity Information
	771	Payment Information
	772	Subscriber Records
	773	Telecommunication Data
	774	Contact Information
	775	Customer Account Data
	776	Security Identifier
	777	Legitimate Interest		771	Legitimate Interest
	778	Legal Obligation		772	Legal Obligation
n	779	Preventing, detecting, or investigating abuse or misuse of Twilio’s platform or	n	773	Platform Security & Fraud Prevention
	>	Services , including spam, fraud, illegal activities, or violations of the Twili
	>	o Acceptable Use Policy, or assisting telecommunications service providers, regu
	>	lators, or law enforcement agencies with combating spam, fraud, or illegal activ
	>	ities.
	780	Communications Usage Data		774	Purpose:
	781	Customer Content		775	Securing our platform and data while proactively protecting our network and our
				>	users from abuse.
	782	Customer Account Data		776	Examples:
	783	Contact Information		777	Safeguarding systems against unauthorized access and security threats; identifyi
				>	ng 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 accou
				>	nt applications or suspending fraudulent accounts (of which you will be notified
				>	and given an opportunity to object).
	784	Device Information and IP		778	Personal Data Processed:
	785	Addresses		779	Contact Data
	786	Telecommunications Data
	787	Security Identifier
	788	Legitimate Interest
	789	Legal Obligation
	790	Determining eligibility for certain Services.
	791	Add-On Service Data
	792	Contact Information
	793	Payment Information
	794	Personalization Details
	795	Subscriber Records
	796	Legitimate Interest
	797	For routing and connectivity purposes to send messages on behalf of our customer
	>	s, including transmitting, distributing and exchanging communications using phon
	>	e numbers, either through the public switched telephone network or other communi
	>	cations networks.
	798	Add-On Service Data
	799	Communications Usage Data
	800	Legitimate Interest
	801	Providing customer support, including responding to your requests and communicat
	>	ing with you about your account and use of the services, including suspicious ac
	>	tivity or security alerts.
	802	Contact Information
	803	Customer Account Data		780	Customer Account Data
	804	Customer Content		781	Customer Content
	805	Communications Usage Data		782	Communications Usage Data
n	806	Professional Information	n	783	Customer Support & Feedback Data
	807	Support and Feedback		784	Solution-Provider Sourced Data
	808	Security Identifier		785	Third-Party Authentication Data
	809	Other personal data provided by requestor		786	Telecommunications Data
				787	Legal Basis for Processing:
				788	Consent
	810	Legitimate interest		789	Legitimate Interest
	811	Sending important notifications about our Services.		790	Legal Obligation
	812	Add-On Service Data		791	Service Support & Improvement
	813	Contact Information		792	Purpose:
				793	Operating, maintaining, and evolving our communications and engagement platforms
				>	.
				794	Examples:
				795	Providing global connectivity and routing communications; troubleshooting techni
				>	cal issues; training AI/ML models with performance metrics to optimize network r
				>	eliability; providing dedicated customer support; and, refining our Service suit
				>	e through usage insights.
				796	Personal Data Processed:
				797	Contact Data
	814	Customer Account Data		798	Customer Account Data
n	815	Legitimate Interest	n
	816	Complying with legal and regulatory obligations, telecommunication service provi
	>	der requirements and communications industry codes of practice.
	817	Subscriber Records
	818	Customer Content		799	Customer Content
	819	Communications Usage Data		800	Communications Usage Data
n			n	801	Customer Support & Feedback Data
				802	Solution-Provider Sourced Data
				803	Third-Party Authentication Data
				804	Telecommunications Data
				805	Legal Basis for Processing:
				806	Consent
				807	Legitimate Interest
				808	Legal Obligation
				809	Research & Innovation
				810	Purpose:
				811	Expanding platform capabilities and developing the next generation of communicat
				>	ions, engagement, and identity solutions.
				812	Examples:
				813	Developing new features or products to continuously improve our Services.
				814	Personal Data Processed:
	820	Customer Account Data		815	Customer Account Data
n			n	816	Customer Content
				817	Communications Usage Data
				818	Customer Support & Feedback Data
				819	Online Activity Data
				820	Solution-Provider Sourced Data
				821	Third-Party Authentication Data
				822	Telecommunications Data
				823	Legal Basis for Processing:
				824	Consent
	821	Legitimate Interest		825	Legitimate Interest
n	822	Sending marketing communications in accordance with your marketing preferences.	n	826	Legal Obligation
	823	Add-On Service Data		827	Customer Engagement
	824	Contact Information		828	Purpose:
	825	Marketing and Contact Preferences		829	Personalizing your experience and managing our ongoing relationship with you.
	826	Professional Data		830	Examples:
	827	Publicly Available Sources		831	Delivering essential Service notifications and account support; sending relevant
				>	Service updates and news based on your preferences; facilitating event particip
				>	ation and access to resources like whitepapers; and, conducting surveys to gathe
				>	r insights for Service improvements.
	828	Social Media Data		832	Personal Data Processed:
				833	Contact Data
				834	Customer Account Data
				835	Marketing & Communications Data
				836	Communications Usage Data (Device Data)
				837	Online Activity Data
				838	Partner-Sourced Data
				839	Solution-Provider Sourced Data
				840	Data Enrichment Services
				841	Third-Party Authentication Data
				842	Legal Basis for Processing:
				843	Consent
	829	Legitimate Interest		844	Legitimate Interest
n			n	845	Personalization & Optimization
				846	Purpose:
				847	To analyze site and platform interactions in order to improve your digital exper
				>	ience, refine our interfaces, and optimize our marketing ecosystem through a uni
				>	fied understanding of the customer journey.
				848	Examples:
				849	Analyzing website and platform navigation to improve functionality and experienc
				>	e; utilizing identity resolution to create unified profiles that ensure a consis
				>	tent experience across different devices and touchpoints; measuring and optimizi
				>	ng the performance of our advertising activities; and deploying online tracking
				>	technologies in accordance with your preferences.
				850	Personal Data Processed:
				851	Contact Data
				852	Customer Account Data
				853	Marketing & Communications Data
				854	Communications Usage Data (Device Data)
				855	Online Activity Data
				856	Partner-Sourced Data
				857	Solution-Provider Sourced Data
				858	Third-Party Authentication Data
				859	Legal Basis for Processing:
	830	Consent		860	Consent
n	831	Analyzing your interest in our Services and delivering marketing campaigns that	n
	>	are relevant to you.
	832	Add-On Service Data
	833	Contact Information
	834	Marketing and Contact Preferences
	835	Professional Data
	836	Publicly Available Sources
	837	Social Media Data
	838	Security Identifier
	839	Legitimate Interest		861	Legitimate Interest
n	840	Consent	n	862	Legal Compliance
	841	Deploying cookies and other tracking technologies in accordance with your online		863	Purpose:
	>	settings.
	842	Add-On Service Data		864	Fulfilling our global legal obligations and protecting the public interest.
	843	Contact Information		865	Examples:
	844	Marketing and Contact Preferences		866	Adhering to international telecommunications and data protection laws, along wit
				>	h 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.
	845	Professional Data		867	Personal Data Processed:
	846	Social Media Data		868	Customer Account Data
				869	Customer Content
				870	Communications Usage Data
				871	Solution=Provider Sourced Data
				872	Third-Party Authentication Data
				873	Legal Basis for Processing:
	847	Legitimate Interest		874	Legitimate Interest
n	848	Consent	n
	849	Understanding how visitors navigate our websites, and tracking and optimizing th
	>	e performance of our advertising activities.
	850	Device Information
	851	Online Activity Information
	852	Publicly Available Sources
	853	Social Media Data
	854	Legitimate Interest
	855	Understanding how customers are using our platform and improving the website nav
	>	igation experience.
	856	Add-On Service Data
	857	Contact Information
	858	Marketing and Contact Preferences
	859	Online Activity Information
	860	Professional Data
	861	Legitimate Interest
	862	Consent
	863	Conducting questionnaires and surveys to improve our Services and provide traini
	>	ng to our employees.
	864	Add-On Service Data
	865	Contact Information
	866	Customer Account Data
	867	Marketing and Contact Preferences
	868	Personalization Details
	869	Professional Data
	870	Support and Feedback
	871	Legitimate Interest
	872	Consent
	873	Managing your participation in our events and webinars and granting you access t
	>	o whitepapers and on-demand resources.
	874	Add-On Service Data
	875	Contact Information
	876	Customer Account Data
	877	Marketing and Contact Preferences
	878	Professional Data
	879	Support and Feedback
	880	Legitimate Interest
	881	Consent
	882	Collecting sales insights and performing lead scoring.
	883	Contact Information
	884	Professional Data
	885	Publicly Available Sources
	886	Social Media Data
	887	Legitimate Interest
	888	Developing our business by updating, expanding, and analyzing our customer relat
	>	ionship records.
	889	Contact Information
	890	Marketing and Contact Preferences
	891	Payment Information
	892	Professional Data
	893	Publicly Available Sources
	894	Social Media Data
	895	Legitimate Interest
	896	Consent
	897	Identifying potential job candidates.
	898	Publicly Available Sources
	899	Social Media Data
	900	Legitimate Interest
	901	Developing or improving our Services, including anonymizing, de-identifying, pse
	>	udonymizing and aggregating personal data for this purpose.
	902	Communications Usage Data
	903	Customer Content
	904	Customer Account Data
	905	Personalization Details
	906	Support and Feedback
	907	Legitimate Interest
	908	As otherwise authorized by you or our customer in Service specific terms or thro
	>	ugh your or our customer’s use and configuration of features in a product.
	909	Data used will vary based on customer authorization
	910	Legitimate Interest
	911	Protecting the health and safety of our employees, visitors and our properties.
	912	Contact Information
	913	Customer Account Data
	914	Legal Obligation		875	Legal Obligation
n	915	Protecting the rights and freedoms of individuals, meeting legal or regulatory o	n
	>	bligations, including complying with valid court orders, disclosure requests, su
	>	bpoenas, and other appropriate legal mechanisms.
	916	Add-On Service Data
	917	Communications Usage Data
	918	Customer Content
	919	Device Information and IP
	920	Addresses
	921	Online Activity Information
	922	Marketing and Contact Preferences
	923	Payment Information
	924	Subscriber Records
	925	Telecommunication Data
	926	Security Identifier
	927	Legal Obligation
	928	Legitimate Interest
	929	How We Disclose Personal Data		876	How We Disclose Personal Data
n	930	We disclose personal data to third parties in limited circumstances in order to	n	877	An icon of a plus symbol
	>	provide the Services and to otherwise run our business. Below are the different
	>	scenarios under which we may disclose your data to third parties.
				878	An icon of a minus symbol
				879	We only share your data when it is necessary to provide our Services, run our bu
				>	siness, or comply with the law. We do not sell your data to third parties. In th
				>	e past 12 months, we may have shared personal data with the following categories
				>	of recipients:
				880	Table 5: Data Recipient Categories
				881	Data Recipient Categories
	931	Telecommunications Service Providers		882	Telecommunications Service Providers
n	932	Twilio’s communications products provide an easier way for developers to build a	n	883	Recipient Details:
	>	pplications that make use of the publicly switched telephone network ('PSTN') to
	>	send communications. Therefore, we engage with a global network of telecommunic
	>	ations operators, aggregators, carriers and other communication service provider
	>	s (collectively, “telecommunications service providers”) as necessary to route a
	>	nd connect those communications from the sender to the intended recipient. How t
	>	elecommunications service providers handle this data is generally determined by
	>	their own policies and local regulations.
	933	Where telecommunications service providers transmit the content of a communicati		884	Global network of operators, aggregators, and carriers who act as conduits for C
	>	on, they function neither as data controllers nor data processors, instead they		>	ustomer Content. These providers function as independent data controllers when p
	>	act simply as a conduit to transmit communication content. In the event telecomm		>	rocessing metadata for billing, fraud prevention, or legal compliance.
	>	unications services providers process any personal data for their own purposes s
	>	uch as communications metadata required to transmit the message, or for billing
	>	or fraud prevention purposes, they also act as data controllers.
	934	We may have to share Subscriber Records with local government authorities or loc		885	Important Note:
	>	al telecommunications carriers that provide connectivity services. However, we d
	>	on’t share subscriber records for purposes other than this, and we treat these r
	>	ecords with our highest confidentiality.
				886	Where required by local law, we share Subscriber Records with local carriers or
				>	authorities solely to provide connectivity, maintaining the highest confidential
				>	ity for these records.
				887	Reason for Sharing:
				888	To route and connect communications across the publicly switched telephone netwo
				>	rk (“PSTN”).
	935	Other Communications Service Providers		889	Other Communications Service Providers
n	936	For proper routing and connectivity, Twilio also enables sending or receiving co	n	890	Recipient Details:
	>	mmunications through communications service providers that do not use the PSTN,
	>	these are referred to as Over-the-Top ('OTT') communications service providers.
	>	If you or our customer chooses to use Twilio to send or receive communications b
	>	y way of these providers, Twilio will disclose communications content and other
	>	data to these providers as necessary to route and connect those communications f
	>	rom the sender to the intended recipient. How those OTT communications service p
	>	roviders, as data controllers, handle this data is determined by their own polic
	>	ies and local regulations.
				891	Over-the-Top (“OTT”) providers (such as WhatsApp) that function as independent d
				>	ata controllers.
				892	Reason for Sharing:
				893	To route and connect communications across the publicly switched telephone netwo
				>	rk (“PSTN”).
	937	Third Party Service Providers		894	Third Party Service Providers
n	938	Twilio engages third-party vendors and service providers to carry out certain pe	n	895	Recipient Details:
	>	rsonal data processing functions on our behalf. These providers are limited to o
	>	nly accessing or using personal data to provide services to us and must provide
	>	reasonable assurances they will appropriately safeguard the data.
	939	Add-On Partners		896	Third-party vendors and service providers engaged by Twilio to process personal
				>	data on our behalf.
	940	Add-ons are additional features, functionality or services offered by Twilio’s A		897	Reason for Sharing:
	>	dd-on partners (who are third parties not affiliated with Twilio). Twilio may ma
	>	ke Add-ons available through the Twilio Marketplace. Some Add-ons may need to ac
	>	cess or collect some of your information, including personal data. If you choose
	>	to use an Add-on, Twilio will disclose your information to the Add-on partner s
	>	o you can use the Add-on. Twilio does not control Add-on partners’ use of your i
	>	nformation and their use of your information will be in accordance with their ow
	>	n policies. If you do not want your information to be disclosed to an Add-on par
	>	tner, then you should not use the Add-on.
	941	Twilio Group Members		898	To perform specific operational functions, with access strictly limited to provi
				>	ding services to Twilio under robust security and confidentiality safeguards.
	942	We may disclose your personal data among Twilio Group Members. Twilio Group Memb		899	Partners & Integrated Service Providers
	>	ers will only use the information as described in this Notice. Twilio Group Memb
	>	ers are listed in Appendix 1 in our Binding Corporate Rules.
	943	Compliance with Legal Obligations		900	Recipient Details:
	944	We may disclose your personal data to a third party if:		901	Third party partners who provide 'add-ons' or integrations to our Services throu
				>	gh the Twilio Marketplace or other Twilio provided catalogue (such as Segment Co
				>	nnections).
	945	If we reasonably believe that disclosure is compelled by applicable law, regulat		902	Reason for Sharing:
	>	ion, legal process, or a government request (including to meet national security
	>	, emergency services, or law enforcement requirements);
	946	to enforce our agreements and policies;		903	To facilitate seamless interoperability between Twilio and third-party services.
				>	This includes disclosing Contact Data and Customer Account Data to those partne
				>	rs to enable the chosen functionality.
	947	to protect the security or integrity of our Services;		904	Twilio Group Companies
	948	to protect ourselves, our other customers, or the public from harm or illegal ac		905	Recipient Details:
	>	tivities, including security threats, spam and fraud; or
	949	to respond to an emergency which we believe in good faith requires us to disclos		906	Twilio group companies (subsidiaries and affiliates) as listed in our Binding Co
	>	e data to assist in preventing a death or serious bodily injury.		>	rporate Rules.
	950	For more details, please see the procedure laid out in our Binding Corporate Rul		907	Reason for Sharing:
	>	es.
	951	If Twilio is required by law to disclose any personal data about you, we will no		908	To facilitate global operations and Service delivery, with all members contractu
	>	tify you or our customers of the disclosure requirement to the extent legally pe		>	ally bound to use your information strictly as described in this Notice.
	>	rmitted and where Twilio determines such disclosure will not interfere with an o
	>	ngoing investigation. Further, we object to information requests we do not belie
	>	ve were issued properly.
	952	Business Transfers		909	Legal, Regulatory, & Judicial Parties
	953	In connection with a corporate sale, merger, reorganization, dissolution or simi		910	Recipient Details:
	>	lar event, personal data about you may be part of the assets transferred or disc
	>	losed in connection with the due diligence for any such transaction. If required
	>	by law, we will notify you prior to such a transfer and provide you with inform
	>	ation about any choices you may have with respect to your personal data.
				911	Law enforcement, government agencies, emergency services, private parties involv
				>	ed in legal proceedings (such as opposing counsel or court-appointed officers) o
				>	r a third party.
				912	Important Note:
				913	We notify users of legal requests whenever permitted and where Twilio determines
				>	the disclosure will not interfere with an on-going investigation. We object to
				>	any requests that are not properly issued.
				914	Reason for Sharing:
				915	To comply with legal obligations, respond to court orders or subpoenas in civil
				>	or criminal cases, enforce our agreements and policies, prevent fraud, and prote
				>	ct the safety and integrity of the platform or the public.
				916	Corporate Transaction Parties
				917	Recipient Details:
				918	Prospective or actual buyers, merger partners, and their professional advisors (
				>	such as legal and financial consultants).
				919	Important Note:
				920	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.
				921	Reason for Sharing:
				922	To conduct due diligence or complete a transfer of assets during a merger, sale,
				>	reorganization, or dissolution, ensuring business continuity.
	954	Aggregated, Anonymized or De-identified Data		923	Aggregated, Anonymized & De-Identified Data
	955	Aggregated, anonymized and de-identified data may be derived by Twilio from your		924	We may derive aggregated, anonymized, or de-identified data from your personal d
	>	personal data but is generally not considered personal data under data protecti		>	ata. Because this data does not identify you, it is not considered personal data
	>	on law as this data does not directly or indirectly reveal your identity. We may		>	under the law. We may use this data for any purpose. We commit to never attempt
	>	use and disclose de-identified, anonymized or aggregated data to third parties.		>	ing to re-identify this information, and we will only share it with third partie
	>	We do not disaggregate or reidentify de-identified data.		>	s who are legally or technically bound to keep it de-identified.
	956	International Data Transfers and Jurisdiction-Specific Provisions		925	U.S. Supplemental Disclosure
	957	As a global organization, we may need to transfer your personal data to Twilio a
	>	ffiliates, contractors, service providers and third parties in various countries
	>	and jurisdictions around the world. When we transfer your personal data, we tak
	>	e care to use appropriate safeguards to ensure your personal data remains protec
	>	ted.
	958	Data Transfers to the United States and Elsewhere
	959	When you use our account portal, or our other Services, your personal data may b
	>	e transferred to the United States, where our primary processing facilities are
	>	located, and possibly to other countries where we or our service providers opera
	>	te.
	960	Safeguards for Data Transfers
	961	Twilio employs appropriate safeguards for cross-border transfers of personal dat
	>	a, as required by applicable local law.
	962	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“)
	963	As set forth by the U.S. Department of Commerce Twilio is officially certified u
	>	nder 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 re
	>	mains liable for damages caused by third parties under the DPF unless Twilio did
	>	not cause the event giving rise to damage. The U.S. Federal Trade Commission ha
	>	s jurisdiction over Twilio’s compliance with the DPF. To learn more about the DP
	>	F Program, and to view our certifications, please visit the DPF website.
	964	Brazilian Standard Contractual Clauses
	965	Twilio uses the Brazilian Standard Contractual Clauses as the legal mechanism fo
	>	r transferring personal data from Brazil. Twilio’s incorporation of the Brazilia
	>	n SCCs, as well as a link to the Brazilian SCCs, is available at https://www.twi
	>	lio.com/en-us/legal/data-protection-addendum.
	966	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 Art
	>	icle 18. Twilio has appointed a DPO who provides oversight of Twilio's complianc
	>	e with applicable data protection laws and regulations. You may exercise your ri
	>	ghts by contacting our DPO at privacy@twilio.com.
	967	Twilio’s Binding Corporate Rules
	968	Twilio has established and implemented a set of Binding Corporate Rules for inte
	>	rnal transfers of personal data between Twilio Group Members in the European Uni
	>	on and Twilio Group Members elsewhere as a data controller. Twilio’s BCRs have b
	>	een approved by European Union Data Protection Authorities and are a commitment
	>	by Twilio to adequately protect personal data that Twilio processes regardless o
	>	f where the information resides. You can access Twilio’s BCR-Controller Policy h
	>	ere.
	969	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 t
	>	ransfer personal data outside the EEA, the UK, and Switzerland, such as Standard
	>	Contractual Clauses and the UK’s International Data Transfer Agreement.
	970	Global CBPR & Global PRP Participation
	971	Twilio’s privacy practices, described in this Notice, comply with the Global Cro
	>	ss Border Privacy Rules (“CBPR”) and Global Privacy Recognition for Processors (
	>	“PRP”) Systems. The global, CBPR and PRP systems provide a framework for organiz
	>	ations to ensure protection of personal data transferred among participating eco
	>	nomies. More information about this global framework can be found here.
	972	How We Secure Personal Data
	973	To protect personal data from loss, or unauthorized use, access or disclosure, T
	>	wilio uses reasonable and appropriate security measures designed to protect the
	>	security of your personal data both online and offline. These measures vary base
	>	d on the sensitivity of the personal data we collect, process and store and the
	>	current state of technology. All systems used to support our business are govern
	>	ed by Twilio’s Information Security Policy and Standards which are built on indu
	>	stry standards and best practices such as the ISO 27001 and NIST standards. More
	>	information about our security measures can be found in our Security Overview.
	974	How Long We Retain Personal Data
	975	We endeavor not to retain personal data in a form which permits identification o
	>	f individuals for longer than is necessary for the purposes for which that data
	>	is processed. We retain personal data in accordance with Twilio's record retenti
	>	on policies and guidelines as revised and updated from time to time.
	976	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. If you ask Twilio t
	>	o delete specific personal data from your Customer Account Data (see ‘Your Right
	>	s and Choices About Your Data’ below), we will honor this request, unless deleti
	>	ng that information prevents us from carrying out necessary business functions,
	>	such as billing for our services, calculating taxes, or conducting required audi
	>	ts.
	977	Your Rights and Choices About Your Data
	978	Depending on the data protection laws applicable to you, you may have the follow
	>	ing rights in relation to your personal data that we process as a data controlle
	>	r:
	979	that we provide details about the categories of personal data that we collect ab
	>	out you, including how we collect and share it;
	980	that we provide you access to, and a copy of, the personal data we collect about
	>	you;
	981	that we update or correct any inaccurate personal data we have about you;
	982	that we delete the personal data we have about you;
	983	that we restrict processing of personal data about you;
	984	that we provide you with your personal data in a structured, commonly used forma
	>	t and to transmit that information to another controller, and where feasible, tr
	>	ansmit the information directly;
	985	that we provide you with the right to object to the processing of personal data,
	>	including profiling;
	986	that we provide you with a free, easy mechanism to object to use of your persona
	>	l information for direct marketing purposes;
	987	that you not be subject to a decision based solely on automated processing, incl
	>	uding profiling, that produces legal effects or similarly affects your individua
	>	l rights;
	988	to withdraw your consent; and
	989	to complain to a competent supervisory authority and/or to commence proceedings
	>	in a court of competent jurisdiction.
	990	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 i
	>	nterest to process your data or can legitimately apply an exemption to the exerc
	>	ise of a right under applicable law. More information about these rights can be
	>	found in our Binding Corporate Rules Controller Policy Rule 10 and Appendix 3.
	991	If you are a US resident interested in what personal data we have disclosed late		926	If you are a US resident interested in what personal data we have disclosed late
	>	ly for our business purposes, here’s a list:		>	ly for our business purposes, here’s a list:
	992	Identifiers		927	Identifiers
	993	Commercial information		928	Commercial information
	995	Internet or other electronic activity information		930	Internet or other electronic activity information
	996	Geolocation information		931	Geolocation information
	997	Professional or employment information		932	Professional or employment information
n	998	By “our business purposes,” we mean that we only disclose personal data as we de	n	933	By “our business purposes,” we mean that we only disclose personal data as descr
	>	scribe in the section "How We Disclose Personal Data" above. Also, as described		>	ibed in this section.
	>	in the “How We Use Cookies & Other Tracking technologies” section below, we proc
	>	ess personal data to deliver ads targeted to your interests on other companies’
	>	websites and mobile apps. Some of these activities may be considered “sharing” o
	>	r “targeted advertising” under certain laws. You have the right to opt out of th
	>	e processing of your personal data for targeted advertising, and can do so by ad
	>	justing your preferences using our Cookie Preferences Tool located on the bottom
	>	right of the Twilio website you are visiting. Any choices concerning cookies ar
	>	e browser and/or device specific. If you clear your cookies from your browser on
	>	any of your devices, your choices will need to be reset.
	999	You also have the right to request the restriction of processing of your sensiti		934	International Transfers
	>	ve personal information. Where applicable, the respective sensitive personal inf
	>	ormation will be marked accordingly and may only be processed by us for certain
	>	purposes. At the current time, however, we do not use or disclose sensitive pers
	>	onal 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.
	1000	You may have additional rights under our Binding Corporate Rules in the EU. For		935	An icon of a plus symbol
	>	example, where you believe your personal data has been transferred by an EU-base
	>	d Twilio company to our US headquarters and processed by the US company in breac
	>	h of the Binding Corporate Rules, you may have a right to:
	1001	Lodge a complaint with the Twilio company that transferred your data outside Eur		936	An icon of a minus symbol
	>	ope;
	1002	Lodge a complaint with the supervisory authority in the same country as the Twil		937	As a global platform, we move data across borders to ensure seamless connectivit
	>	io company that transferred your data outside Europe; and		>	y, Service provision and business operations. While our primary processing facil
				>	ities are in the U.S., we use regulator-approved frameworks to ensure personal d
				>	ata receives the same high level of protection everywhere it travels. Whether we
				>	are transferring data internally within the Twilio group or externally to trust
				>	ed third parties, we rely on the following legal safeguards:
	1003	Bring a court action against the Twilio company that transferred your data outsi		938	Data Privacy Frameworks (or “DPF”): Primary mechanism for transfers from the EU,
	>	de Europe.		>	UK and Switzerland to the U.S.
				939	Binding Corporate Rules (or “BCRs”): EU-approved rules covering transfers to Twi
				>	lio group companies globally.
				940	EU, UK Standard Contractual Clauses (or “SCCs”): Transfer mechanisms used for EU
				>	and UK transfers where the DPF or BCR’s do not apply.
				941	Brazil Standard Contractual Clauses (or “Brazil SCCs”): Primary mechanism for tr
				>	ansfers from Brazil.
				942	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 p
				>	rotection of data transferred among participating economies. More on these progr
				>	ams can be found here.
				943	For our customers, all international data transfers are governed by our Data Pro
				>	tection Addendum (“DPA”), which provides detailed information on our contractual
				>	safeguards.
				944	Data Security & Retention
				945	An icon of a plus symbol
				946	An icon of a minus symbol
				947	Twilio protects personal data through a risk-based security framework and data l
				>	ifecycle management processes.
				948	Security Measures
				949	To protect against loss, unauthorized use, access, or disclosure, Twilio uses re
				>	asonable and appropriate security measures designed to protect personal data bot
				>	h online and offline.
				950	Risk-Based Protections: These measures vary based on the sensitivity of the pers
				>	onal data we collect, process, and store, as well as the current state of techno
				>	logy.
				951	Global Standards: All systems are governed by policies built on industry best pr
				>	actices, including ISO 27001 and NIST standards.
				952	More information about our security measures can be found in our Security Overvi
				>	ew.
				953	Retention Policy
				954	We endeavor not to retain personal data in a form which permits identification o
				>	f individuals for longer than is necessary for the purposes for which that data
				>	is processed. We retain personal data in accordance with Twilio’s record retenti
				>	on policies and guidelines.
				955	Customer Account Data is stored as long as needed to provide Services and operat
				>	e our business. Please note that requests to delete Customer Account Data are su
				>	bject to the Limitations set forth in the Privacy Rights & Choices section of th
				>	is Notice.
				956	Managing Your Data
				957	We provide the tools you need to store, access, delete, and exercise control ove
				>	r your data. The specific choices available to you depend entirely on which Serv
				>	ice you use and how you have configured it. The Twilio Docs repository is a cent
				>	ralized hub that includes product-specific instructions for managing your data,
				>	plus step-by-step guides on our retention and deletion practices.
				958	Privacy Rights & Choices
				959	An icon of a plus symbol
				960	An icon of a minus symbol
				961	Depending on the applicable data protection laws, you may have the following rig
				>	hts in relation to the personal data that we process as a data controller:
				962	Table 6: Privacy Rights & Choices
				963	Privacy Rights & Choices
				964	Transparency & Control Rights
				965	Be Informed: Request clear details on data categories, sources, purposes, and th
				>	ird-party sharing.
				966	Access: View or request a copy of your data.
				967	Correct: Update inaccurate or outdated information.
				968	Delete: Request data destruction when no legal or legitimate business reason for
				>	retention exists.
				969	Portability: Receive data in a structured, machine-readable format for transfer.
				970	Object or Restrict: Oppose or limit data processing, including automated decisio
				>	n making and related profiling.
				971	Withdraw Consent: Rescind your consent for processing at any time.
				972	Important Note: Account closure or deletion is permanent and results in immediat
				>	e loss of access to some or all data. Requests are subject to limitations set fo
				>	rth below.
				973	How to Exercise Rights:
				974	Self-service via Twilio console.
				975	Customer Support for requests outside of self-service tools.
				976	Marketing Communications & Targeted Advertising Rights
				977	Opt out of marketing communications; update your communications preferences; upd
				>	ate cookie preferences; opt out of targeted advertising.
				978	Important Note: Marketing opt-outs may take up to three days to process. Essenti
				>	al service communications— such as billing or password resets—will continue unle
				>	ss your account is deactivated.
				979	How to Exercise Rights:
				980	Click “unsubscribe” at the bottom of any Twilio marketing email.
				981	Update your communications preferences.
				982	For targeted advertising, see Cookies & Tracking Technologies section of this No
				>	tice.
				983	Contact Customer Support.
				984	Automated-Decision Making Rights
				985	Object to and request a human review of decisions Twilio makes about you based s
				>	olely on automated processing, which currently includes account approvals and ac
				>	count suspensions related to abusive or fraudulent activity, or other decisions
				>	that significantly affect you.
				986	How to Exercise Rights:
				987	Contact privacy@twilio.com.
				988	Contact Customer Support.
				989	Complaint Rights
				990	Submit a complaint to Twilio; file an official complaint with a government data
				>	protection regulator; take legal action through the relevant court system.
				991	How to Exercise Rights:
				992	See Resolving Complaints section in this Notice.
				993	Additional Rights
				994	Depending on your jurisdiction, you may exercise specific controls over your dat
				>	a:
				995	Sensitive Data: Restrict the use of sensitive personal data to what is strictly
				>	necessary for Service delivery. Twilio currently limits processing to the specif
				>	ic purposes in this Notice or as permitted by law.
				996	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 tran
				>	sferring Twilio company or its local supervisory authority, or bring a court act
				>	ion against the company.
				997	U.S. CPNI: U.S. account holders can opt-out of the use of Customer Proprietary N
				>	etwork Information (e.g., call quantity, type, and destination) for marketing ne
				>	w services without affecting current services.
				998	Brazil: Brazilian data subjects may exercise Article 18 rights by contacting our
				>	Data Protection Officer at privacy@twilio.com.
				999	Security & Verification
				1000	To protect your account, we must verify your identity before processing certain
				>	requests (e.g. deletion).
				1001	Verification Process: We typically ask for proof of your recent interactions wit
				>	h us or login verification.
				1002	Authorized Agents: If you use an authorized agent to make a request, we may requ
				>	ire proof in the form of a power of attorney or written authority to act on your
				>	behalf.
				1003	Limitations
				1004	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 legitim
				>	ate interest to process your data. More information about these rights can be fo
				>	und in our Binding Corporate Rules Controller Policy Rule 10 and Appendix 3. We
				>	will not discriminate against you or change the price of our Services if you exe
				>	rcise your rights, but if you ask us to delete your data, it may affect your abi
				>	lity to use our Services.
	1004	If Twilio processes your personal data as a data processor on behalf of a custom		1005	Important Note: If Twilio processes your data as a data processor on behalf of a
	>	er, we will either direct you to contact our customer to exercise your rights.		>	customer, we will direct you to contact our customer to exercise your rights.
	1005	How To Exercise Your Rights and Choices		1006	Children’s Privacy
	1006	The following sections provide information about how to exercise certain rights		1007	An icon of a plus symbol
	>	in relation to your personal data. To exercise any other rights, please contact
	>	us at privacy@twilio.com.
	1007	Accessing and Controlling Account Data		1008	An icon of a minus symbol
	1008	As part of our Services, we provide you with a number of self-service features a		1009	Our Services are not directed to or intended to be used by children (under the a
	>	t no additional cost within the Twilio console itself, including the ability to		>	ge of 13 in the U.S. and UK, or 16 in the EEA). If we discover that a child has
	>	access your data, update any incorrect data, download a copy of your data, delet		>	created an account, we will deactivate it and delete the data as quickly as poss
	>	e your data, or restrict the use of your data. You can make various choices abou		>	ible. If you believe we have inadvertently collected data from a child, please c
	>	t your Customer Account Data through the account portal when you log into your T		>	ontact us at privacy@twilio.com with the subject line “Children”.
	>	wilio account or through the marketing preferences center. Any other requests ab
	>	out your data you cannot make through these self-service tools, you can request
	>	by contacting Customer Support.
	1009	Closing Your Account and Deletion		1010	Cookies & Tracking Technologies
	1010	To request closure or deletion of your Twilio account, you can contact Customer		1011	An icon of a plus symbol
	>	Support. Please be aware that closure or deletion of your Twilio account will re
	>	sult in you permanently losing access to your account and the data in the accoun
	>	t. After closure of your account, certain information associated with your accou
	>	nt may remain on Twilio’s servers in an aggregated form that does not identify y
	>	ou. Similarly, after you close your account, we will retain data — including per
	>	sonal data — associated with your account that we are required to maintain for l
	>	egal purposes or for necessary business operations (see “How Long We Retain Pers
	>	onal Data” section above) until it’s no longer needed.
	1011	Identity Verification		1012	An icon of a minus symbol
	1012	In some instances, we will need to verify your identity before honoring your req		1013	We use cookies, pixels, web beacons, and similar tools to secure our website, an
	>	uest. We will generally verify your identity by asking you to provide personal d		>	alyze performance, and deliver relevant ads. These tools help us recognize your
	>	ata related to your recent interactions with us. Thereafter, we will process you		>	device to make your experience more secure, efficient and tailored to your inter
	>	r request and inform you of any decisions we have made about your request. Addit		>	ests. Under some U.S. state laws, this is considered "sharing" or "targeted adve
	>	ionally, you may exercise your privacy rights through an authorized agent. If we		>	rtising."
	>	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 h
	>	as valid written authority to submit requests to exercise rights on your behalf.
	>	If you are an authorized agent seeking to make a request, please contact us at
	>	privacy@twilio.com.
	1013	We won’t discriminate against you or change the price of our services if you mak
	>	e a request, but if you ask us to delete your data, it may affect your ability t
	>	o use our Services.
	1014	Customer Proprietary Network Information (CPNI)
	1015	As an individual Twilio account holder or as an authorized representative of a T
	>	wilio customer in the US, you have the right to restrict Twilio’s use of CPNI. T
	>	o 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. Please note th
	>	at, if you have subscribed for the services on behalf of an organization, the CP
	>	NI relates to the service usage by that organization and not you individually. O
	>	pting-out of the use of CPNI for marketing will not unsubscribe you from other t
	>	ypes of marketing contacts from Twilio and will not affect the status of the ser
	>	vices you currently have with us. Your approval or opt-out of the use of your CP
	>	NI outside of the services to which you are already subscribed is valid until yo
	>	u affirmatively revoke or limit such approval.
	1016	Communication Preferences
	1017	You can opt out of receiving marketing communications from us at any time throug
	>	h your marketing preferences page by clicking the “unsubscribe” link at the bott
	>	om of any marketing email you receive from Twilio. You can also update your comm
	>	unication preferences using our online form or contact our Customer Support Team
	>	to communicate your choice to opt out. 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. You will not be able to opt out of service emails from us, such as pas
	>	sword reset emails, billing emails, or notifications of updates to our terms, un
	>	less you deactivate your account.
	1018	How We Use Cookies and Other Tracking Technologies
	1019	Twilio uses common information gathering tools such as cookies, web beacons, pix
	>	els 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.
	1020	Cookies		1014	Cookies
n	1021	A cookie is a small text file that is stored in your browser or elsewhere on you	n	1015	Cookies are small files stored on your device that help us recognize you, making
	>	r hard drive. Cookies allow Twilio to identify your device as you navigate our w		>	your experience more efficient and personalized. We use both session cookies (w
	>	ebsites or your account. This makes navigating and interacting with our websites		>	hich expire when you close your browser) and persistent cookies (which remain on
	>	or your account more efficient, easy and meaningful for you.		>	your device for a set period). Our cookies fall into three categories:
	1022	Twilio uses both session and persistent cookies. Session cookies are cookies tha		1016	Required: Essential for the website to function (e.g., secure log-in or remember
	>	t disappear from your computer or browser when you turn off your computer. Persi		>	ing where you are at in the order process. You cannot opt-out of required cookie
	>	stent cookies stay on your computer even after you’ve turned it off.		>	s.
	1023	The cookies on our websites fall into three categories: (1) Required Cookies, (2		1017	Functional: Used to remember your choices (e.g, language or region) and analyze
	>	) Functional Cookies, and (3) Advertising Cookies. To learn more about each cate		>	site usage to improve customer experience and site performance. You can opt-out
	>	gory of cookie, you can visit our cookie consent tool by clicking on the “Cookie		>	of functional cookies, however some site features may not work properly.
	>	Preferences” link on the bottom right of the Twilio website you are visiting.
	1024	Manage Your Cookie Preferences		1018	Advertising: Used to show you content and ads that are relevant to your interest
				>	s. You can opt-out of advertising cookies at any time.
	1025	Twilio uses a cookie consent tool, which you can utilize to customize your cooki		1019	Web Beacons (Pixels)
	>	e preferences. When you visit our website for the first time, a cookie consent b
	>	anner will pop up and ask you to customize your cookie preferences. If you decid
	>	e to change your preferences at a later date, you can easily do so by clicking o
	>	n the “Cookie Preferences” link on the bottom right of the Twilio website you ar
	>	e visiting. Please note that Required Cookies cannot be disabled and if you deci
	>	de to opt-out of Functional Cookies, certain functionality of our websites or yo
	>	ur account may be impacted. Any choices concerning cookies are browser and/or de
	>	vice specific. If you clear your cookies from your browser on any of your device
	>	s, your choices will need to be reset.
	1026	Manage Cookies Using Your Browser		1020	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.
	1027	In addition to using our Cookie Consent tool, you can use your browser settings		1021	Your Controls: How to Manage Tracking Technologies
	>	to opt out of Functional Cookies and Advertising Cookies. For more information o
	>	n how to do that, click here. To manage privacy and storage settings for cookies
	>	, click here.
	1028	Universal Opt-Out Mechanisms		1022	We provide multiple ways for you to manage tracking technologies:
				1023	Twilio Cookie Preferences Tool: The easiest way to manage your settings is by cl
				>	icking the “Cookie Preferences” icon located in the footer of any Twilio website
				>	. Any choices concerning cookies are browser and/or device specific. If you clea
				>	r your cookies from your browser on any of your devices, your choices will need
				>	to be reset.
				1024	Browser Settings: You can use your browser settings to opt out of Functional Coo
				>	kies and Advertising Cookies. For more information on how to do that, click here
				>	. To manage privacy and storage settings for cookies, click here.
	1029	Global Privacy Control (GPC) and Do Not Track (DNT) are tools that you can use t		1025	Universal Opt-Outs: Global Privacy Control (“GPC”) and Do Not Track (“DNT”) are
	>	o inform websites of your privacy preferences in regard to ad trackers. To set u		>	tools that you can use to inform websites of your privacy preferences in regard
	>	p GPC, you can visit the Global Privacy Control page. To set DNT, you can visit		>	to ad trackers. To set up GPC, you can visit the Global Privacy Control page. To
	>	the All About DNT page. Please note that this may impact the functionality of ou		>	set DNT, you can visit the All About DNT page. Please note that this may impact
	>	r websites or your account.		>	the functionality of our websites or your account.
	1030	Opt Out of Advertising Cookies		1026	Ad Industry Tools: To learn more about how to opt out of targeting and advertisi
				>	ng cookies, you can visit Your Online Choices, the Network Advertising Initiativ
				>	e, and the Digital Advertising Alliance.
	1031	To learn more about how to opt out of targeting and advertising cookies, you can		1027	Service Specific Privacy Notices
	>	go to the Your Online Choices page, the Network Advertising Initiative page, an
	>	d the Digital Advertising Alliance’s Consumer Choice page. These opt-out tools a
	>	re provided by third parties, not Twilio. We do not control or operate these too
	>	ls or the choices that advertisers and others provide through these tools.
	1032	Web Beacons		1028	An icon of a plus symbol
	1033	Twilio also uses web beacons to gather data about your use of our websites, your		1029	An icon of a minus symbol
	>	account, and how you interact with emails we have sent to you. Web beacons are
	>	clear electronic images that can recognize certain types of data on your compute
	>	r, like when you view a particular website tied to the web beacon, and a descrip
	>	tion of a website tied to the web beacon. Additionally, we may put web beacons i
	>	n marketing emails that notify us when you click on a link in the email that dir
	>	ects you to a Twilio website.
	1034	Children		1030	If you utilize any of the following Services, we are required to provide additio
				>	nal details as to how we use the specified data categories and the purpose. Addi
				>	tional information regarding the products can be found at the links below or in
				>	the Twilio Docs.
	1035	Our Services are not directed to or intended to be used by children (under the a		1031	Authy
	>	ge of 13 in the US and UK, or 16 in the EEA). We do not knowingly permit childre
	>	n to sign up for a Twilio account. If we become aware that a child has signed up
	>	for an account, we will take reasonable steps to deactivate the account and rem
	>	ove their personal data from our records as quickly as possible. If you believe
	>	an underage person has signed up for a Twilio account, please contact us at priv
	>	acy@twilio.com with the subject line “Children”.
	1036	Automated Decision Making		1032	The Authy service is our standalone two-factor authentication (“2FA”) service fo
				>	r desktop and mobile. The Authy apps generate one time passwords and push notifi
				>	cations to provide an additional layer of security for your Authy-compatible acc
				>	ounts. Authy’s 2FA can be used independently or with applications that integrate
				>	directly with Authy 2FA API.
	1037	Automated decision-making occurs when an electronic system uses personal data to		1033	Due to the nature of the Authy service, Twilio collects the following additional
	>	make a decision about you, without human involvement. Twilio uses automated dec		>	personal data elements to our other Services:
	>	ision-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. We may also u
	>	se this information to evaluate your account application and make decisions abou
	>	t whether to approve or decline. If your account is suspended or not approved un
	>	der these circumstances you will be notified and given an opportunity to request
	>	human review of the decision.
	1038	We may rely on other automated decision-making where:		1034	Identifiers
	1039	We have notified you of the decision and provided you with the opportunity to re		1035	To create an Authy account, we require a phone number. We send a verification co
	>	quest a human review of the decision		>	de to that phone number to be sure that the person creating the Authy account ha
				>	s control over the device. This phone number serves as your “primary device and
				>	the unique identifier for your Authy account. We use that phone number to identi
				>	fy you, provide 2FA services, and maintain security and anti-fraud logs. We also
				>	collect your email address for identity verification and account recovery purpo
				>	ses.
	1040	It is necessary to perform a contract with you and appropriate measures are in p		1036	Device Information
	>	lace to safeguard your rights
	1041	We have your consent and we have put in place appropriate measures to safeguard		1037	When you download and open the Authy desktop or mobile app, we automatically col
	>	your rights		>	lect your device type and unique device identifier. This ensures we deliver the
				>	correct version of the app, as well as the appropriate technical support. We als
				>	o use your device information to ensure proper delivery, maintenance, and securi
				>	ty of the Authy app.
				1038	Login History and Authy Account History
				1039	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
				>	. This includes your IP address, the application you accessed, and the timestamp
				>	of the login. We also maintain a log of any changes made to the phone number or
				>	email address associated with your account. We collect this information to moni
				>	tor for suspicious activity and to verify your identity if we suspect your accou
				>	nt may be compromised.
				1040	Geolocation information
				1041	If you have location services enabled, we collect your location based on your IP
				>	address. 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 o
				>	f a suspected account compromise.
				1042	Frontline Services
				1043	To use the Frontline services, you must log in to the Frontline app using a thir
				>	d party account through your Single Sign-On provider. 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. We only access the informati
				>	on you or our customers provide, and we use it solely for the purposes for which
				>	it was shared. Please see the Frontline App Terms for specific details about yo
				>	ur relationship with us.
				1044	SendGrid Services
				1045	The SendGrid Services also collect additional data through web beacons placed in
				>	the body of emails delivered via our platform. This allows us to track email en
				>	gagement, including whether a message was delivered, opened, or clicked, bounced
				>	, or marked as spam. You can learn more about our use of web beacons in the sect
				>	ion titled “Cookies and Tracking Technologies” above.
				1046	Conversational Intelligence
				1047	Conversational Intelligence incorporates artificial intelligence and machine lea
				>	rning to transcribe and analyze voice calls into a structured format that allows
				>	our customers to drive their business processes. To translate voice calls into
				>	structured content, Twilio processes certain data, including personal data withi
				>	n voice calls, as an independent controller. This includes information provided
				>	to us by our customers through their use of the Conversational Intelligence Serv
				>	ice.
	1042	How to Contact Us		1048	How to Contact Us
n	1043	If you have any questions, concerns or complaints about this Notice or our data	n	1049	If you have questions about this Notice or our privacy practices, please contact
	>	protection practices, please do not hesitate to contact our Data Protection Offi		>	our Data Protection Officer (“DPO”) at privacy@twilio.com.
	>	cer by emailing us at privacy@twilio.com or by writing to us at any of the follo
	>	wing addresses:
				1050	You can also write to us at our global headquarters:
	1044	Worldwide Headquarters		1051	Worldwide Headquarters
	1045	Twilio Inc.		1052	Twilio Inc.
	1046	101 Spear Street, 5th Floor		1053	101 Spear Street, 5th Floor
	1047	San Francisco CA 94105		1054	San Francisco CA 94105
	1048	EEA Headquarters		1055	EEA Headquarters
	1049	Twilio Ireland Limited		1056	Twilio Ireland Limited
n	1050	70 Sir John Rogerson's Quay	n	1057	78 Sir John Rogerson’s Quay,
	1051	Dublin 2		1058	Dublin 2
	1052	D02 R296, Ireland		1059	D02 R296, Ireland
n	1053	Complaints	n	1060	Resolving Complaints
	1054	We will endeavor to resolve questions, concerns or complaints you raise with us		1061	We aim to resolve any questions or concerns in accordance with our Complaints Ha
	>	in accordance with our Complaints Handling Procedure. In the unlikely event that		>	ndling Procedure. If you have a question or wish to lodge a complaint (whether r
	>	we are unable to resolve your concern, you can find information about your opti		>	elated to our privacy practices or otherwise), please contact the Twilio Privacy
	>	ons to seek assistance through independent dispute resolution mechanisms or comp		>	Team at privacy@twilio.com or by mail at the physical addresses referenced unde
	>	laints to your local data protection authority here.		>	r “How to Contact Us.”
	1055	In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and t		1062	We encourage you to use these direct channels to ensure a prompt response, howev
	>	he Swiss-U.S. DPF, Twilio commits to refer unresolved complaints concerning our		>	er, we will address complaints received through any other means. If we are unabl
	>	handling of personal data received in reliance on the EU-U.S. DPF and the UK Ext		>	e to resolve your concern to your satisfaction, you may pursue further resolutio
	>	ension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute		>	n through the following channels:
	>	resolution provider based in the United States, the European Union, the United
	>	Kingdom, and/or Switzerland. 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.jams
	>	adr.com/DPF-Dispute-Resolution for more information or to file a complaint. The
	>	services of JAMS are provided at no cost to you.
	1056	You have the possibility, under certain conditions, to invoke binding arbitratio		1063	Data Protection Frameworks (“DPF”): For practices covered by our DPF certificati
	>	n for complaints regarding DPF compliance that are not resolved by any of the ot		>	on, contact our U.S.-based third party dispute resolution provider (free of char
	>	her DPF mechanisms. You can find more information in the DPF ANNEX-I-introductio		>	ge) at https://www.jamsadr.com/DPF-Dispute-Resolution. Under certain circumstanc
	>	n.		>	es, you may also invoke binding arbitration. For details, see Annex I of the EU-
				>	U.S. Data Privacy Framework Principles.
	1057	If your question or complaint relates to personal data we process as a data proc		1064	Global CBPR and PRP Systems: For unresolved concerns related to our CBPR or PRP
	>	essor on behalf of a customer, we will direct you to contact our customer to add		>	certifications, contact our U.S.-based third-party dispute resolution provider (
	>	ress your question or complaint.		>	free of charge) at https://feedback-form.truste.com/watchdog/request.
				1065	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 l
				>	aws.
				1066	EEA Residents: You have the right to lodge a complaint with the Data Protection
				>	Commissioner in Ireland, where our EEA headquarters are located.
				1067	If your complaint relates to a company using our Services (e.g., you want to sto
				>	p receiving emails from a specific brand), please contact that company directly.
				>	As a data processor, we cannot resolve complaints about our customers' data pra
				>	ctices.
	1058	Changes to Our Privacy Notice		1068	Changes to Our Privacy Notice
t	1059	We will periodically review this Notice and may change it to address legal, tech	t	1069	We periodically review and update this Notice to make clarifications or to refle
	>	nical or business development requirements or make clarifications. When we chang		>	ct legal, technical, or business changes. The latest version will always be post
	>	e this Notice, the most current version will be available at https://www.twilio.		>	ed at twilio.com/legal/privacy with the “Last Updated” date at the top. If we ma
	>	com/legal/privacy with the date indicating when it was last updated. If we make		>	ke significant changes that affect your rights, we will provide advance notice v
	>	material changes that affect your rights, we will provide you with advance notic		>	ia the Twilio console or by email and obtain your consent where legally required
	>	e, such as by posting a message in the Twilio console or sending an email to the		>	.
	>	address we have on file for you. We will comply with applicable law with respec
	>	t to any changes we make to this Notice. We will also seek your consent to mater
	>	ial changes, where required by applicable law.
	1060	Twilio Product Privacy
	1061	Twilio offers a range of industry-leading communications and customer data platf
	>	orm services to our customers. Depending on the Service, Twilio may be a data co
	>	ntroller and data processor of personal data used to provide the Services.
	1062	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 cu
	>	stomer and in accordance with the terms of our agreement with a customer, our Da
	>	ta Protection Addendum, and service specific terms. Our Services provide custome
	>	rs with ways to control, access and secure their data.
	1063	We also offer customers the ability to store, delete, access, or exercise other
	>	choices about their personal data. The ability to make these choices depends on
	>	the Service being used and how it is being used by a customer. Customers are ref
	>	erred to our API docs for each of our Services, along with SendGrid’s documentat
	>	ion and Segment’s documentation to find more detailed information about managing
	>	personal data collected and stored in connection with their use of our Services
	>	. We also provide an overview of our retention and deletion practices, including
	>	how to delete data you control in our support documentation. We provide informa
	>	tion about the security measures we use to protect our customer’s data in our Se
	>	curity 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 meas
	>	ures here.
	1064	For some of the Services we also act as a data controller where disclosed and ag
	>	reed to by our customer in the agreement, Data Protection Addendum, product spec
	>	ific terms or via the customers’ use and configuration of a product or feature.A
	>	s a data controller, Twilio is responsible for the processing of the personal da
	>	ta.
	1065	For more detail on our Services, please find information below or by visiting ou
	>	r products page.
	1066	Authy
	1067	The Authy service is our standalone two-factor authentication (2FA) service for
	>	desktop and mobile. The Authy apps generate one time passwords and push notifica
	>	tions that can be used as a part of a two-step verification process with your Au
	>	thy-compatible accounts to add another layer of security. Authy’s 2FA can be use
	>	d on its own or with applications that directly integrate with Authy’s 2-factor
	>	authentication API.
	1068	Due to the nature of the Authy service, Twilio collects the following additional
	>	personal data elements to our other Services:
	1069	Identifiers
	1070	Once you open the Authy app, we ask you to provide us with a phone number to cre
	>	ate your Authy account. We send a verification code to that phone number to be s
	>	ure that the person creating the Authy account also has control over the phone n
	>	umber entered. This phone number is considered your “primary device,” and will b
	>	e the identifier for your Authy account. We use that phone number to identify yo
	>	u, to provide you 2FA services, and to maintain logs for security and anti-fraud
	>	purposes. We also collect your email address, and we use it for identity verifi
	>	cation and account recovery purposes.
	1071	Device Information
	1072	When you download and open the Authy desktop or mobile app, we automatically col
	>	lect information about the type of device you have downloaded the app on and you
	>	r device identifier. We collect this to ensure we deliver the right version of t
	>	he app for your device and so that we can provide appropriate follow up support
	>	as necessary. We also use your device information to ensure proper delivery of o
	>	ur service and to provide and deliver support and maintenance of the Authy app.
	1073	Login History and Authy Account History
	1074	When you use an Authy token to log into an account, whether the token was genera
	>	ted on the app or one sent to you via your phone number, we collect and keep inf
	>	ormation associated with your login activity including information like your IP
	>	address, what application you logged in to, that you logged in, and when. If you
	>	change your phone number or email associated with your Authy account, we will a
	>	lso keep a log of that. We collect this information to monitor for suspicious ac
	>	tivity and also as another piece of information that could be used to verify you
	>	r identity if we suspect your account may be compromised.
	1075	Geolocation information
	1076	If you have location services turned on, we collect your location based on your
	>	IP address. We use this information for anti-fraud purposes, to check for suspic
	>	ious activity and as another piece of information we can use to verify your iden
	>	tity if we suspect your account may be compromised.
	1077	Frontline Services
	1078	To use the Frontline services, you must log in to the Frontline app using a thir
	>	d party account (through your Single Sign-On provider). The authentication of yo
	>	ur login details is handled by that third party and we only collect the informat
	>	ion you expressly agree to share with us at the time you give permission to link
	>	the Frontline app with the third party account. 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. Please see the Frontline Ap
	>	p Terms for specific details about your relationship with us.
	1079	SendGrid Services
	1080	The SendGrid services also collect additional data in the form of web beacons pl
	>	aced in the body of emails delivered using the SendGrid platform. 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. You can learn more about web beacon
	>	s in the section titled “How We Use Cookies and Other Tracking Technologies” abo
	>	ve.
	1081	Voice Intelligence
	1082	Voice Intelligence incorporates artificial intelligence and machine learning to
	>	transcribe and analyze voice calls into a structured format that allows our cust
	>	omers to drive their business processes. To translate voice calls into structure
	>	d content, Twilio processes certain data as a controller, including personal dat
	>	a contained in voice calls disclosed to us by our customer through their use of
	>	the service.
	1083	Twilio		1070	Twilio
	1084	Twilio		1071	Twilio
	1085	Twilio careers		1072	Twilio careers