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The agreement establishes that customers are solely responsible for all use of services under their account and for all acts, omissions, and activities of their End Users, including End User compliance with the agreement, the Acceptable Use Policy, and applicable law.
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 places the full compliance burden for End User conduct on the customer, meaning that violations by End Users trigger the customer's obligations under the agreement, including indemnification, fee liability, and potential suspension, regardless of whether the customer directly participated in the violation.
The updated terms establish a binding arbitration requirement for users domiciled or registered in Mexico, replacing prior dispute resolution procedures. Under the revised Section 10.5, Mexico-domiciled users must first engage in good faith negotiations with Segment for up to 30 days, and if unresolved, disputes proceed to binding arbitration administered by the Centro de Arbitraje de México (CAM) in Mexico City before a sole arbitrator, with both parties splitting arbitration costs. Additionally, the agreement now explicitly carves out Mexico's Federal Consumer Protection Law (Ley Federal de Protección al Consumidor), stating it does not apply to this commercial agreement. Mexico users also face a new obligation to comply with anti-money laundering and anti-corruption requirements under applicable Mexican law.
View change record →Segment's updated terms now apply Japan-specific dispute resolution, verification, and tax requirements to customers domiciled or registered in Japan. The agreement now states that arbitration proceedings for Japanese customers will take place in Mexico City, Japan (implied Tokyo venue under the new Japan section), conducted in English. Japanese customers may be required to submit government-issued ID documents and complete verification processes as required under applicable Japanese law, including the Act on Prevention of Transfer of Criminal Proceeds and the Telecommunications Business Act. All fees are payable in Japanese Yen, and taxes will include Japanese consumption tax. Intellectual property rights now incorporate Japanese Copyright Act provisions. You can review the specific verification requirements by contacting Segment or reviewing the applicable service section.
View change record →Under this clause, customers bear sole responsibility for all End User activity conducted through their accounts, including compliance with the Twilio Acceptable Use Policy and applicable law, creating direct contractual exposure for downstream user behavior the customer may not have directly authorized or monitored.
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"You will: (a) be solely responsible for all use of the Services and Documentation under your account and the Customer Services; (b) not transfer, resell, lease, license, or otherwise make available the Services to third parties (except to make the Services available to your End Users) or offer them on a standalone basis; (c) use the Services only in accordance with this Agreement, the Twilio Acceptable Use Policy, the applicable Documentation, any applicable Order Form(s), and applicable law or regulation; (d) be solely responsible for all acts, omissions, and activities of your End Users, including their compliance with this Agreement, the Twilio Acceptable Use Policy, the applicable Documentation, any applicable Order Form(s), and applicable law or regulation.Excerpt from Segment's Terms of Service
REGULATORY LANDSCAPE: The allocation of End User compliance responsibility to the customer engages telecommunications regulatory frameworks, including carrier compliance obligations incorporated by reference in the Twilio Acceptable Use Policy and Service and Country Specific Requirements. In the EU, platform liability frameworks under the Digital Services Act may interact with how this allocation of responsibility applies to customer-operated services built on the Twilio platform. GOVERNANCE EXPOSURE: High. For customers operating high-volume automated communications, marketplace platforms, or developer APIs built on Twilio, the scope of End User activity that falls within this responsibility allocation is significant and may be difficult to monitor in real time. Violations by any End User can trigger suspension of all customer accounts under Section 2.3. JURISDICTION FLAGS: Telecommunications compliance obligations for End User-generated traffic vary significantly by jurisdiction. Customers operating services in the United States should pay particular attention to TCPA compliance obligations for End User messaging conduct. EU customers should evaluate how DSA platform liability standards interact with the contractual allocation of End User compliance responsibility. CONTRACT AND VENDOR IMPLICATIONS: The sole responsibility allocation for End User conduct makes robust downstream End User agreements operationally critical. Procurement and legal teams should ensure that End User terms of service include enforceable AUP obligations and that monitoring and enforcement mechanisms are in place to detect and remediate End User violations before they trigger platform-level suspension. COMPLIANCE CONSIDERATIONS: Compliance teams should implement monitoring procedures calibrated to the categories of End User conduct that constitute AUP violations under the Twilio Acceptable Use Policy and Service and Country Specific Requirements. Incident response plans should address procedures for promptly notifying Twilio of unauthorized access or use as required by Section 2.2(e).
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This provision places the full compliance burden for End User conduct on the customer, meaning that violations by End Users trigger the customer's obligations under the agreement, including indemnification, fee liability, and potential suspension, regardless of whether the customer directly participated in the violation.
Under this clause, customers bear sole responsibility for all End User activity conducted through their accounts, including compliance with the Twilio Acceptable Use Policy and applicable law, creating direct contractual exposure for downstream user behavior the customer may not have directly authorized or monitored.
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