Twilio uses cookies, pixels, and similar tracking technologies on its website to collect device identifiers, browsing behavior, and usage data, which is used for analytics, advertising, and site optimization.
This analysis describes what Segment'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
This provision authorizes collection of behavioral and device-level data from all website visitors, including through third-party tools such as Google Tag Manager and Adobe Launch, which may transmit data to external parties.
Interpretive note: The exact text of the privacy notice body was not available in the provided document source, which consisted primarily of page HTML and navigation infrastructure; tracking technology disclosures are inferred from technical scripts present in the page source.
The updated policy establishes a new opt-out mechanism allowing users to decline having their data disclosed to third parties (other than service providers) or used for purposes materially different from the original collection purpose. The policy also explicitly discloses that Twilio Inc. is subject to FTC investigatory and enforcement powers, providing users with notice of the regulatory authority overseeing the company's privacy practices. You can exercise this opt-out right by contacting Segment through the mechanism specified in their privacy policy.
View change record →The updated terms establish clearer disclosure of how Segment transfers personal data internationally. Segment now explicitly certifies its compliance with the EU-U.S. Data Privacy Framework, UK Extension, and Swiss-U.S. Data Privacy Framework, and states that these DPF Principles take precedence if they conflict with other policy terms. The updated policy also adds specific rights allowing you to opt out of: (i) disclosure of your personal data to third parties other than service providers acting under Segment's instructions, or (ii) use of your personal data for purposes materially different from the original purpose or your subsequent authorization. You can exercise these rights by contacting privacy@twilio.com.
View change record →Removal of this broad provision may indicate that cookie and tracking practices have been reorganized into more specific provisions like 'Segment Analytics Tracking' or consolidated into other sections.
View full change record →Visitors to twilio.com have device identifiers, browsing activity, and behavioral data collected via tracking technologies; this data may be shared with advertising and analytics partners. Users can manage these preferences through the TrustArc consent tool on the site.
How other platforms handle this
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
If we collect health information from these integrations (such as heart rate), we will not sell or use it for advertising or other similar purposes; we do not disclose it to third parties without your prior consent; and we will only use it for the specific purposes described in this Policy.
We collect your personal data when you use our Services, create a new eBay account, provide us with information via a web form, add or update information in your eBay account, participate in online community discussions or otherwise interact with us.
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(1) REGULATORY LANDSCAPE: This provision engages the EU ePrivacy Directive, GDPR Article 6 lawful basis requirements, and CPRA opt-out of cross-context behavioral advertising. The relevant enforcement authorities include EU Data Protection Authorities, the UK ICO, and the California Privacy Protection Agency. Where behavioral advertising cookies are used, valid prior consent is required under GDPR and ePrivacy frameworks before firing tracking tags. (2) GOVERNANCE EXPOSURE: Medium. The use of Google Tag Manager and Adobe Launch on the same page as the privacy notice, combined with a TrustArc consent wrapper, raises questions about whether third-party tags fire only after valid consent is obtained. The adequacy of the consent flow would require technical audit to confirm. (3) JURISDICTION FLAGS: EU and UK users are protected by ePrivacy and GDPR consent requirements; California users have CPRA opt-out rights for cross-context behavioral advertising. The provision applies globally to all twilio.com visitors, creating heightened exposure in these jurisdictions. (4) CONTRACT AND VENDOR IMPLICATIONS: Procurement teams evaluating Twilio should assess whether data collected via these tracking technologies is processed under a data processing agreement, and whether sub-processors (Google, Adobe) are disclosed in a sub-processor list. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should conduct a technical audit of the TrustArc implementation to confirm tags do not fire before consent is captured; review sub-processor disclosures for advertising and analytics vendors; and confirm lawful basis documentation for behavioral tracking under GDPR.
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This provision authorizes collection of behavioral and device-level data from all website visitors, including through third-party tools such as Google Tag Manager and Adobe Launch, which may transmit data to external parties.
Visitors to twilio.com have device identifiers, browsing activity, and behavioral data collected via tracking technologies; this data may be shared with advertising and analytics partners. Users can manage these preferences through the TrustArc consent tool on the site.
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