The notice discloses that Twilio uses third-party services including Google Tag Manager, Adobe Launch, and Segment to collect and process visitor data, and that this data may be shared with advertising and analytics partners for targeting and measurement purposes.
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 personal data collected on twilio.com is transmitted to multiple third-party vendors on page load via embedded scripts, creating data flows that require documented legal bases and data processing agreements under GDPR and CCPA.
Interpretive note: The exact scope of data transmitted to each named third-party vendor and the consent configuration applied by TrustArc are not fully described 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 this disclosure, visitor identifiers, behavioral data, and device information may be transmitted to advertising and analytics vendors including Google and Adobe when a user visits twilio.com. The agreement establishes that TrustArc consent preferences govern whether these scripts execute for users in applicable jurisdictions.
How other platforms handle this
We will also provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected.
to request that your data be transferred to a third party (data portability)
Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.
(1) REGULATORY LANDSCAPE: This provision engages GDPR Articles 6 and 28 regarding lawful basis and processor contracts, the ePrivacy Directive regarding cookie consent, and CCPA/CPRA regarding data sharing for advertising purposes.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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This provision establishes that personal data collected on twilio.com is transmitted to multiple third-party vendors on page load via embedded scripts, creating data flows that require documented legal bases and data processing agreements under GDPR and CCPA.
Under this disclosure, visitor identifiers, behavioral data, and device information may be transmitted to advertising and analytics vendors including Google and Adobe when a user visits twilio.com. The agreement establishes that TrustArc consent preferences govern whether these scripts execute for users in applicable jurisdictions.
ConductAtlas has identified this type of provision across 289 platforms. See the full comparison.
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