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Children's Privacy and Age Restriction

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Recent governance activity Segment recorded 3 documented changes in the last 30 days.
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Document Record

What it is

The notice states that Twilio's services are not directed to children under 13 in the U.S. and UK or under 16 in the EEA, and that accounts identified as belonging to children will be deactivated and data deleted.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision establishes age thresholds aligned with COPPA in the U.S. and GDPR Article 8 in the EEA, and discloses a remediation procedure for inadvertently collected child data. The differentiated age thresholds for U.S./UK versus EEA reflect applicable legal requirements in each jurisdiction.

Recent Activity

This document changed recently

Medium May 22, 2026

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 →
Medium May 19, 2026

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 →

Consumer impact (what this means for users)

The agreement establishes that Twilio's services are not available to individuals under 13 in the U.S. and UK or under 16 in the EEA, and that accounts identified as belonging to children will be deactivated and associated data deleted. Individuals with information about a child account can report it to privacy@twilio.com with the subject line 'Children'.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    If you believe Twilio has inadvertently collected data from a child, send an email to privacy@twilio.com with the subject line 'Children' and provide details of the account or data in question.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
Our Services are not directed to or intended to be used by children (under the age of 13 in the U.S. and UK, or 16 in the EEA). If we discover that a child has created an account, we will deactivate it and delete the data as quickly as possible. If you believe we have inadvertently collected data from a child, please contact us at privacy@twilio.com with the subject line 'Children'.

Excerpt from Segment's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: COPPA applies in the U.S. to online services directed to children under 13 and imposes parental consent and data minimization requirements. GDPR Article 8 establishes age of digital consent thresholds for information society services, with member states permitted to set thresholds between 13 and 16; the EEA threshold of 16 stated in the notice reflects Twilio's stated compliance position. The UK Age Appropriate Design Code (Children's Code) imposes additional obligations for services likely to be accessed by children under 18. 2) GOVERNANCE EXPOSURE: Low for this specific provision given that Twilio's services are developer-focused and not directed to children. The notice provides a compliant remediation procedure. However, enterprise customers using Twilio to build consumer-facing services that may be accessed by minors bear primary responsibility for age verification and COPPA or GDPR Article 8 compliance at the application layer. 3) JURISDICTION FLAGS: The differentiated age threshold of 13 for U.S. and UK versus 16 for EEA reflects applicable statutory requirements. Enterprise customers deploying Twilio in consumer contexts should assess whether their own platforms impose adequate age verification to prevent child access to Twilio-powered services. 4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers building consumer-facing applications on Twilio's infrastructure should assess COPPA and GDPR Article 8 compliance obligations at the application layer, as Twilio's notice addresses its own direct services rather than downstream applications built on its APIs. 5) COMPLIANCE CONSIDERATIONS: Legal teams at enterprise customers deploying Twilio for consumer communications should verify that age verification mechanisms are in place at the application layer. Organizations subject to the UK Children's Code should assess whether services accessible to minors under 18 meet the code's requirements independent of Twilio's stated age threshold.

Full institutional analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC enforces COPPA and has jurisdiction over children's online privacy practices for services accessible to users under 13 in the United States.
    File a complaint →

Provision details

Document information
Document
Segment Privacy Policy
Entity
Segment
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-016196
Document ID
CA-D-00700
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
e37e6bb1abdf882cdf3d4b9a7ddcbcb1b521744fd46b9d3d4d5f19d611714b48
Analysis generated
July 9, 2026 09:48 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Segment
Document: Segment Privacy Policy
Record ID: CA-P-016196
Captured: 2026-07-09 09:48:26 UTC
SHA-256: e37e6bb1abdf882c…
URL: https://conductatlas.com/platform/segment/segment-privacy-policy/provision/CA-P-016196/childrens-privacy-and-age-restriction/
Accessed: July 23, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Low
Categories

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Frequently Asked Questions

What does Segment's Children's Privacy and Age Restriction clause do?

This provision establishes age thresholds aligned with COPPA in the U.S. and GDPR Article 8 in the EEA, and discloses a remediation procedure for inadvertently collected child data. The differentiated age thresholds for U.S./UK versus EEA reflect applicable legal requirements in each jurisdiction.

How does this clause affect you?

The agreement establishes that Twilio's services are not available to individuals under 13 in the U.S. and UK or under 16 in the EEA, and that accounts identified as belonging to children will be deactivated and associated data deleted. Individuals with information about a child account can report it to privacy@twilio.com with the subject line 'Children'.

Is ConductAtlas affiliated with Segment?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Segment.