This provision establishes that all listed sub-processors process personal data under written contracts with Twilio that require implementation of appropriate technical and organizational measures meeting applicable data protection law standards. Processing occurs on behalf of customers and in accordance with customer instructions as relayed by Twilio.
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 the contractual basis for the entire sub-processing chain and asserts that Twilio maintains written agreements with each sub-processor requiring data protection standards consistent with applicable law. Compliance teams relying on this chain for their own GDPR Article 28 obligations should verify that the sub-processor contracts include all required provisions and that the described obligations are enforceable across jurisdictions where sub-processors operate.
Under this provision, personal data processed through Twilio services is handled by third-party companies bound by written contracts with Twilio requiring appropriate technical and organizational data protection measures. The agreement asserts that processing occurs in accordance with customer instructions as communicated by Twilio, establishing an indirect instruction chain between the customer and each sub-processor.
Cross-platform context
See how other platforms handle Third-Party Sub-Processor Engagement and Contractual Obligations and similar clauses.
Compare across platforms →"Twilio uses the third party companies below (each, a "sub-processor") to process personal data (i) on behalf of Twilio customers; (ii) in accordance with customer instructions as communicated by Twilio; and (iii) in strict accordance with the terms of a written contract between Twilio and the sub-processor. Twilio imposes obligations on its sub-processors to implement appropriate technical and organizational measures ensuring that the sub-processing of personal data is protected to the standards required by applicable data protection laws.Excerpt from Segment's Sub-Processors
1) REGULATORY LANDSCAPE: This provision directly engages GDPR Article 28, which requires that controllers use only processors providing sufficient guarantees to implement appropriate technical and organizational measures, and that sub-processing arrangements be governed by equivalent …
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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This provision establishes the contractual basis for the entire sub-processing chain and asserts that Twilio maintains written agreements with each sub-processor requiring data protection standards consistent with applicable law. Compliance teams relying on this chain for their own GDPR Article 28 obligations should verify that the sub-processor contracts include all required provisions and that the described obligations are enforceable across …
Under this provision, personal data processed through Twilio services is handled by third-party companies bound by written contracts with Twilio requiring appropriate technical and organizational data protection measures. The agreement asserts that processing occurs in accordance with customer instructions as communicated by Twilio, establishing an indirect instruction chain between the customer and each sub-processor.
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