Segment · Segment Sub-Processors · View original document ↗

Sub-Processing On Customer Behalf

High severity High confidence Explicitdocumentlanguage Common · 280 of 352 platforms
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Recent governance activity Segment recorded 2 documented changes in the last 30 days.
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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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

Sub-processors are contractually bound to act on behalf of customers and follow customer instructions, establishing that customer instructions—mediated through Twilio—govern sub-processor conduct.

Consumer impact (what this means for users)

Personal data processed by sub-processors is handled on the customer's behalf and according to instructions the customer communicates through Twilio.

How other platforms handle this

MyFitnessPal Medium

We use your personal information to send you newsletters and other promotional communications, including information about MyFitnessPal's new offerings, features, offers, events, webinars, and other information.

Lyft Medium

We may infer certain information from your interactions with the Lyft Platform and other personal information available to us. For example, if you frequently ride to or from airports, we may infer you are a frequent traveler.

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▸ View Original Clause Language DOCUMENT RECORD
"
process personal data (i) on behalf of Twilio customers; (ii) in accordance with customer instructions as communicated by Twilio

— Excerpt from Segment's Segment Sub-Processors

Applicable regulations

CCPA/CPRA
California, USA
Colorado AI Act
US-CO
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
FTC Act Section 5
United States Federal
GDPR
European Union

Provision details

Document information
Document
Segment Sub-Processors
Entity
Segment
Document last updated
July 6, 2026
Tracking information
First tracked
July 7, 2026
Last verified
July 9, 2026
Record ID
CA-P-067197
Document ID
CA-D-00937
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
eb0c920c72df0732ba3434b4acbc87ddf3cac2ad805f3e24639ec619d81bba39
Analysis generated
July 7, 2026 00:28 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Segment
Document: Segment Sub-Processors
Record ID: CA-P-067197
Captured: 2026-07-07 00:28:28 UTC
SHA-256: eb0c920c72df0732…
URL: https://conductatlas.com/platform/segment/segment-sub-processors/provision/CA-P-067197/sub-processing-on-customer-behalf/
Accessed: July 12, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Segment's Sub-Processing On Customer Behalf clause do?

Sub-processors are contractually bound to act on behalf of customers and follow customer instructions, establishing that customer instructions—mediated through Twilio—govern sub-processor conduct.

How does this clause affect you?

Personal data processed by sub-processors is handled on the customer's behalf and according to instructions the customer communicates through Twilio.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 280 platforms. See the full comparison.

Is ConductAtlas affiliated with Segment?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Segment.