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The document identifies Twilio and Iterable, both in the United States, as subprocessors for analytics, email, and SMS communications across all Claude products except Claude for Government. Twilio is designated for analytics and email/SMS communications; Iterable is designated for email communications.
This analysis describes what Anthropic's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
Analytics and communications subprocessors process contact information, behavioral signals, and communication content including email and SMS interactions. Enterprise customers subject to GDPR or CCPA should confirm that communications data flows to these vendors are addressed in their data processing documentation.
Under these provisions, analytics data and email and SMS communications related to Claude products are processed by Twilio and Iterable in the United States, excluding Claude for Government. This applies to all non-government product users who interact with Anthropic via email or SMS, or whose usage generates analytics events.
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"Twilio • Analytics, email/SMS communications United States Products: All Products except Claude for Government Iterable • Email communications United States Products: All Products except Claude for GovernmentExcerpt from Anthropic's Sub-Processors
(1) REGULATORY LANDSCAPE: Email and SMS communications processing engages CAN-SPAM Act and TCPA requirements for U.S. recipients. GDPR and UK GDPR apply to EU and UK residents' communications data transferred to these U.S.-based processors. FTC oversight applies to consumer data practices including behavioral analytics and communications data handling. (2) GOVERNANCE EXPOSURE: Low to medium. Analytics data combined with communications data can constitute behavioral profiling. GDPR transparency requirements may apply if analytics involve tracking of user behavior across sessions. TCPA consent requirements apply to SMS communications with U.S. residents. (3) JURISDICTION FLAGS: EU and UK users have transfer mechanism considerations for communications data sent to U.S.-based Twilio and Iterable. California residents may have CCPA rights regarding analytics and communications data. TCPA creates specific consent requirements for SMS communications with U.S. residents. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers should confirm that communications and analytics data flows to Twilio and Iterable are addressed in their Anthropic DPA. Organizations that have data minimization requirements should assess whether the analytics functions performed by Twilio are proportionate to stated processing purposes. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should confirm GDPR transfer mechanisms for Twilio and Iterable, assess whether CAN-SPAM and TCPA consent requirements are met for email and SMS communications, review whether analytics processing involves cross-session behavioral tracking requiring GDPR transparency disclosures, and update records of processing activities to reflect these subprocessors.
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Analytics and communications subprocessors process contact information, behavioral signals, and communication content including email and SMS interactions. Enterprise customers subject to GDPR or CCPA should confirm that communications data flows to these vendors are addressed in their data processing documentation.
Under these provisions, analytics data and email and SMS communications related to Claude products are processed by Twilio and Iterable in the United States, excluding Claude for Government. This applies to all non-government product users who interact with Anthropic via email or SMS, or whose usage generates analytics events.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Anthropic.