This provision states that telecommunications providers used by Twilio are not classified as Twilio processors or customer sub-processors, and therefore are not subject to the sub-processor contractual framework described in this document.
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 exclusion means that personal data transmitted through telecommunications providers in the course of Twilio service delivery falls outside the sub-processor contractual chain described in this document, which may have implications for GDPR Article 28 compliance analysis and customers' own records of processing activities where telecommunications routing is involved.
Interpretive note: The legal classification of telecommunications providers as independent controllers rather than processors under GDPR may be subject to supervisory authority interpretation depending on the specific role and data access involved.
Under this provision, telecommunications providers used by Twilio in delivering services are excluded from the sub-processor classification and therefore from the contractual data protection obligations described in this document. Customers relying on this sub-processor list for a comprehensive map of entities handling their personal data should note that telecommunications carriers are explicitly carved out.
Cross-platform context
See how other platforms handle Telecommunications Providers Exclusion from Sub-Processor Classification and similar clauses.
Compare across platforms →"Please note that telecommunications providers used by Twilio are not processors of Twilio or sub-processors of our customers. Additional information about this position can be found here.Excerpt from Segment's Sub-Processors
1) REGULATORY LANDSCAPE: This provision engages GDPR Article 28 and the distinction between processors and independent data controllers or third parties that process data under their own legal bases.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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This exclusion means that personal data transmitted through telecommunications providers in the course of Twilio service delivery falls outside the sub-processor contractual chain described in this document, which may have implications for GDPR Article 28 compliance analysis and customers' own records of processing activities where telecommunications routing is involved.
Under this provision, telecommunications providers used by Twilio in delivering services are excluded from the sub-processor classification and therefore from the contractual data protection obligations described in this document. Customers relying on this sub-processor list for a comprehensive map of entities handling their personal data should note that telecommunications carriers are explicitly carved out.
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