This provision discloses that where the contracting Twilio entity is not Twilio Inc. (for example, Twilio Ireland Ltd.), Twilio Inc. is classified as a sub-processor for that entity, meaning US-based processing by Twilio Inc. constitutes a sub-processor engagement subject to the same transfer mechanism requirements as external sub-processors.
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This provision establishes that EU or UK customers contracting with Twilio Ireland Ltd. or another non-US Twilio entity are subject to an intra-group transfer to Twilio Inc. in the United States for provision of all services, which requires a valid GDPR Chapter V transfer mechanism and is subject to the same regional processing exception noted elsewhere in the document.
Under this clause, customers contracting with a non-US Twilio entity (such as Twilio Ireland Ltd.) are subject to personal data transfers to Twilio Inc. in the United States as part of service delivery, with Twilio Inc. classified as a sub-processor. This intra-group transfer is subject to the same regional processing exception for fraud and abuse investigations stated elsewhere in the document.
Cross-platform context
See how other platforms handle Twilio Inc. as Intra-Group Sub-Processor and similar clauses.
Compare across platforms →"Twilio Inc. All Services If Twilio Inc. is not the Twilio party to the agreement, then Twilio Inc. is acting as a sub-processor for that Twilio party. (For example. If you are contracting with Twilio Ireland Ltd, then Twilio Inc. is acting as a sub-processor for the provision of the services.) Provision of the Twilio Services USA*Excerpt from Segment's Sub-Processors
1) REGULATORY LANDSCAPE: This provision directly engages GDPR Article 28 sub-processing requirements and GDPR Chapter V third-country transfer obligations.
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This provision establishes that EU or UK customers contracting with Twilio Ireland Ltd. or another non-US Twilio entity are subject to an intra-group transfer to Twilio Inc. in the United States for provision of all services, which requires a valid GDPR Chapter V transfer mechanism and is subject to the same regional processing exception noted elsewhere in the document.
Under this clause, customers contracting with a non-US Twilio entity (such as Twilio Ireland Ltd.) are subject to personal data transfers to Twilio Inc. in the United States as part of service delivery, with Twilio Inc. classified as a sub-processor. This intra-group transfer is subject to the same regional processing exception for fraud and abuse investigations stated elsewhere in the …
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