This provision states that Twilio has conducted Transfer Impact Assessments for all sub-processor engagements involving cross-border personal data transfers, and maintains a current list of sub-processor names and processing locations.
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 asserts that Transfer Impact Assessments have been completed for cross-border transfers, which is a GDPR Schrems II compliance mechanism; however, the assessments themselves are not published in this document, and customers relying on them for their own accountability obligations would need to request access or review Twilio's supplementary measures documentation linked externally.
Interpretive note: The adequacy of the Transfer Impact Assessments cannot be evaluated from this document alone, as the assessments are referenced but not reproduced or linked for all sub-processors.
The document states that Twilio has performed Transfer Impact Assessments for sub-processor engagements requiring cross-border data transfers, asserting a baseline of GDPR transfer compliance. Customers whose data is processed by US-based sub-processors listed in this document are subject to these assessments, though the assessments themselves are not reproduced in this document.
Cross-platform context
See how other platforms handle Cross-Border Transfer Impact Assessments and similar clauses.
Compare across platforms →"Where the engagement of a sub-processor requires the cross-border transfer of personal data, Twilio has performed Transfer Impact Assessments for such data transfer. Twilio maintains an up-to-date list of the names and locations of all sub-processors below.Excerpt from Segment's Sub-Processors
1) REGULATORY LANDSCAPE: This provision engages GDPR Chapter V and the Schrems II ruling (Case C-311/18), which requires that cross-border transfers to third countries be subject to Transfer Impact Assessments when standard contractual clauses are …
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This provision asserts that Transfer Impact Assessments have been completed for cross-border transfers, which is a GDPR Schrems II compliance mechanism; however, the assessments themselves are not published in this document, and customers relying on them for their own accountability obligations would need to request access or review Twilio's supplementary measures documentation linked externally.
The document states that Twilio has performed Transfer Impact Assessments for sub-processor engagements requiring cross-border data transfers, asserting a baseline of GDPR transfer compliance. Customers whose data is processed by US-based sub-processors listed in this document are subject to these assessments, though the assessments themselves are not reproduced in this document.
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