This provision states that customers using Regional Twilio may select Ireland or Australia for data storage and processing, but that this regional restriction is subject to an exception permitting US processing when Twilio investigates fraud or abuse. Non-content account and usage data continues to be processed in the United States regardless of regional selection.
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 the regional data residency guarantee is conditional, with an explicit carve-out for fraud and abuse investigations that routes data to US processing without specifying procedural safeguards, notification requirements, or limits on scope. Customers with strict data residency obligations under sector-specific regulations or contractual commitments should assess whether this exception is compatible with those requirements.
Interpretive note: The document does not specify which transfer mechanism applies during US processing under the fraud exception, leaving the GDPR Chapter V compliance basis for those transfers unclear.
Under this clause, customers who select regional processing in Ireland or Australia may have their Customer Content processed in the United States if Twilio determines that a fraud or abuse investigation requires it. Additionally, the document states that account and usage data (outside of Customer Content) is processed in the United States regardless of the regional setting selected.
Cross-platform context
See how other platforms handle Regional Processing Exception for Fraud and Abuse Investigations and similar clauses.
Compare across platforms →"* If using Regional Twilio for supported products, Customer Content is stored and processed in the region selected (Ireland or Australia). Exceptions will occur as necessary to investigate issues of fraud and abuse. At this time, all other data relating to your account and use of the Twilio Services will continue to be processed in the United States to allow Twilio to continue to provide and improve our Services to you.Excerpt from Segment's Sub-Processors
1) REGULATORY LANDSCAPE: This provision may require evaluation under GDPR Chapter V, as processing EU personal data in the United States requires an adequate transfer mechanism; the fraud exception does not specify which transfer mechanism …
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This provision establishes that the regional data residency guarantee is conditional, with an explicit carve-out for fraud and abuse investigations that routes data to US processing without specifying procedural safeguards, notification requirements, or limits on scope. Customers with strict data residency obligations under sector-specific regulations or contractual commitments should assess whether this exception is compatible with those requirements.
Under this clause, customers who select regional processing in Ireland or Australia may have their Customer Content processed in the United States if Twilio determines that a fraud or abuse investigation requires it. Additionally, the document states that account and usage data (outside of Customer Content) is processed in the United States regardless of the regional setting selected.
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