This provision states that Twilio customers may opt in to a notification service that provides updates when changes are made to the sub-processor list.
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Under GDPR Article 28, processors are generally required to inform controllers of intended sub-processor changes and provide an opportunity to object; this provision establishes the mechanism by which Twilio delivers such notifications, making customer subscription operationally significant for maintaining GDPR compliance awareness.
Interpretive note: The document does not specify whether the opt-in notification mechanism satisfies GDPR Article 28 advance notice obligations or whether a separate contractual objection right applies; this depends on the specific DPA terms agreed with Twilio.
The document establishes an opt-in notification mechanism for customers to receive updates when the sub-processor list changes. Customers who do not subscribe to this notification service will not automatically receive advance notice of sub-processor additions or removals under the terms as stated.
Cross-platform context
See how other platforms handle Customer Subscription to Sub-Processor Change Notifications and similar clauses.
Compare across platforms →"Twilio customers may subscribe to notifications of sub-processor changes to receive updates.Excerpt from Segment's Sub-Processors
1) REGULATORY LANDSCAPE: GDPR Article 28(2) requires that processors obtain controller authorization before engaging new sub-processors and notify controllers of intended changes.
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Under GDPR Article 28, processors are generally required to inform controllers of intended sub-processor changes and provide an opportunity to object; this provision establishes the mechanism by which Twilio delivers such notifications, making customer subscription operationally significant for maintaining GDPR compliance awareness.
The document establishes an opt-in notification mechanism for customers to receive updates when the sub-processor list changes. Customers who do not subscribe to this notification service will not automatically receive advance notice of sub-processor additions or removals under the terms as stated.
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