The notice references GDPR as an applicable framework for EU/EEA users and discloses processing legal bases including consent and legitimate interests, along with user rights including access, deletion, correction, restriction, and data portability.
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 establishes that EU/EEA visitors to twilio.com are covered by GDPR protections, and that Twilio asserts multiple legal bases for processing, including legitimate interests, which under GDPR requires a documented balancing test for each processing activity so claimed.
Interpretive note: The specific legitimate interests assessments and the full text of GDPR-related provisions are not directly quoted in the available document text.
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 →Under these terms, EU/EEA users have rights to access, correct, delete, restrict, and port their personal data, and may object to processing based on legitimate interests. The agreement establishes that consent is the basis for cookie-based tracking, while other processing may be conducted under legitimate interests.
How other platforms handle this
You may contact our privacy team with any requests of disclosure, correction, or deletion of your personal information. You may also request suspension of use or suspension of sharing of your personal information with certain third parties.
If you choose to reveal any personal information about yourself to other users, you do so at your own risk. We strongly encourage you to use caution in disclosing any personal information online.
When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide some of our Services, you may not be able to use those Services.
(1) REGULATORY LANDSCAPE: This provision directly engages GDPR Articles 6, 12 through 22, and 30, as well as the ePrivacy Directive for cookie-based tracking.
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This provision establishes that EU/EEA visitors to twilio.com are covered by GDPR protections, and that Twilio asserts multiple legal bases for processing, including legitimate interests, which under GDPR requires a documented balancing test for each processing activity so claimed.
Under these terms, EU/EEA users have rights to access, correct, delete, restrict, and port their personal data, and may object to processing based on legitimate interests. The agreement establishes that consent is the basis for cookie-based tracking, while other processing may be conducted under legitimate interests.
ConductAtlas has identified this type of provision across 289 platforms. See the full comparison.
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