Segment · Segment Privacy Policy · View original document ↗

Twilio liability for third-party DPF principle violations

High severity High confidence Explicitdocumentlanguage Common · 230 of 352 platforms
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Recent governance activity Segment recorded 2 documented changes in the last 30 days.
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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)

Segment's retained liability for third-party violations means the reader retains a claim against Segment even after data is transferred, subject to Segment's ability to prove non-responsibility.

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.

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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.

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Consumer impact (what this means for users)

If a third party that received your data from Segment violates the DPF Principles, Segment is liable to you unless Segment proves it was not responsible for the violation.

How other platforms handle this

Instacart Medium

Any access to or use of the Services or goods through your account by others, including your spouse, dependents, Recipients, and any access by AI Agents you enable or that operate on your behalf...

Twilio Medium

Indemnifying Party will not settle any Claim for which it has an obligation to indemnify under this Section 6 admitting liability or fault on behalf of Indemnified Party, nor create any obligation on behalf of Indemnified Party without Indemnified Party's prior written consent...

DeepL Medium

DeepL shall not settle or recognise claims of third parties without Customer's consent which shall not be unreasonably withheld or delayed.

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▸ View Original Clause Language DOCUMENT RECORD
"
Twilio remains liable under the DPF Principles (defined below) if that third-party processes your data in a way that violates those Principles, unless we prove we were not responsible for the violation.

— Excerpt from Segment's Segment Privacy Policy

Applicable regulations

FTC Act Section 5
United States Federal

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-055074
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-055074
Captured: 2026-07-09 09:48:26 UTC
SHA-256: e37e6bb1abdf882c…
URL: https://conductatlas.com/platform/segment/segment-privacy-policy/provision/CA-P-055074/twilio-liability-for-third-party-dpf-principle-violations/
Accessed: July 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Segment's Twilio liability for third-party DPF principle violations clause do?

Segment's retained liability for third-party violations means the reader retains a claim against Segment even after data is transferred, subject to Segment's ability to prove non-responsibility.

How does this clause affect you?

If a third party that received your data from Segment violates the DPF Principles, Segment is liable to you unless Segment proves it was not responsible for the violation.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 230 platforms. See the full comparison.

Is ConductAtlas affiliated with Segment?

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