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The notice states that Twilio uses advertising cookies, pixels, and web beacons for targeted advertising and acknowledges that under some U.S. state laws this constitutes sharing or targeted advertising, with opt-out available through the Cookie Preferences tool, browser settings, or Global Privacy Control.
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 discloses that Twilio's advertising tracking technologies engage U.S. state privacy law definitions of sharing and targeted advertising, which trigger opt-out rights under frameworks including CCPA as amended by CPRA. The notice provides multiple opt-out mechanisms and explicitly names Global Privacy Control as a recognized opt-out signal.
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 →The agreement establishes that advertising cookies and tracking pixels are deployed on Twilio websites and that this activity constitutes sharing or targeted advertising under applicable U.S. state laws. Under these terms, opt-out is available through the Cookie Preferences tool in the website footer, browser settings, or by enabling Global Privacy Control; advertising opt-outs apply per browser and device and must be reset if cookies are cleared.
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"We use cookies, pixels, web beacons, and similar tools to secure our website, analyze performance, and deliver relevant ads. These tools help us recognize your device to make your experience more secure, efficient and tailored to your interests. Under some U.S. state laws, this is considered 'sharing' or 'targeted advertising.' ... Advertising: Used to show you content and ads that are relevant to your interests. You can opt-out of advertising cookies at any time.Excerpt from Segment's Privacy Policy
1) REGULATORY LANDSCAPE: CCPA as amended by CPRA grants California residents the right to opt out of sharing of personal information for cross-context behavioral advertising and requires businesses to recognize Global Privacy Control as a valid opt-out signal. Similar provisions exist under Colorado, Connecticut, Virginia, and other state privacy laws. The FTC has jurisdiction over deceptive practices in advertising disclosures. Cookie consent requirements under ePrivacy Directive and national implementing laws apply in EU and EEA jurisdictions. 2) GOVERNANCE EXPOSURE: Medium. The notice discloses targeted advertising practices and provides opt-out mechanisms including GPC recognition, which aligns with CPRA and similar state law requirements. Compliance teams should verify that GPC signals are technically implemented and honored across all Twilio web properties and that cookie preferences tools accurately reflect the categories of cookies deployed. 3) JURISDICTION FLAGS: California residents have the most clearly defined opt-out rights under CPRA. EU and UK visitors are subject to ePrivacy and GDPR consent requirements for non-essential cookies; the notice's cookie preference tool must provide genuine prior consent options for EU/UK users rather than only opt-out functionality. Other U.S. states with targeted advertising opt-out requirements create additional compliance touchpoints. 4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers embedding Twilio tracking technologies in their own platforms or communications should assess whether their own cookie consent and privacy disclosures accurately describe Twilio's tracking data collection. Vendor assessments should confirm that Twilio's advertising partner ecosystem is disclosed and that data flows to advertising partners are covered by appropriate contractual mechanisms. 5) COMPLIANCE CONSIDERATIONS: Legal teams should audit whether Twilio's Cookie Preferences tool functions as a genuine opt-out mechanism or consent tool depending on applicable jurisdiction requirements. GPC signal recognition should be verified through technical testing. Marketing teams using Twilio's SendGrid service should note that web beacons placed in email bodies collect engagement data including opens and clicks, which may implicate email privacy requirements in certain jurisdictions.
This provision discloses that Twilio's advertising tracking technologies engage U.S. state privacy law definitions of sharing and targeted advertising, which trigger opt-out rights under frameworks including CCPA as amended by CPRA. The notice provides multiple opt-out mechanisms and explicitly names Global Privacy Control as a recognized opt-out signal.
The agreement establishes that advertising cookies and tracking pixels are deployed on Twilio websites and that this activity constitutes sharing or targeted advertising under applicable U.S. state laws. Under these terms, opt-out is available through the Cookie Preferences tool in the website footer, browser settings, or by enabling Global Privacy Control; advertising opt-outs apply per browser and device and must …
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