If you use Twilio to process personal data of individuals in the EU or elsewhere, a separate Data Protection Addendum governs how that data is handled, and both parties must follow it.
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
The clause creates a binding framework for how personal data is handled during service delivery by making a separate data protection document an enforceable part of the primary service agreement. This establishes specific compliance requirements and allocates data processing responsibilities between the parties.
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 →Individuals whose personal data flows through Twilio's platform (e.g., phone numbers, message content, location data) are protected by Twilio's Data Processing Addendum only if the business customer has properly incorporated it — creating a potential compliance gap if customers overlook this requirement.
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"To the extent Twilio processes any Personal Data (as defined in the Twilio Data Protection Addendum) on your behalf in connection with your use of the Services, the terms of the Twilio Data Protection Addendum, which are hereby incorporated by reference, shall apply and both parties agree to comply with such terms.— Excerpt from Segment's Segment Terms of Service
REGULATORY FRAMEWORK: GDPR Art. 28 mandates a written Data Processing Agreement between controllers and processors. CCPA §1798.100 and the CPRA impose service provider contract requirements. UK GDPR (post-Brexit) has equivalent DPA requirements. HIPAA 45 CFR § 164.308(b) requires Business Associate Agreements for covered healthcare entities processing PHI through Twilio.
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The clause creates a binding framework for how personal data is handled during service delivery by making a separate data protection document an enforceable part of the primary service agreement. This establishes specific compliance requirements and allocates data processing responsibilities between the parties.
Individuals whose personal data flows through Twilio's platform (e.g., phone numbers, message content, location data) are protected by Twilio's Data Processing Addendum only if the business customer has properly incorporated it — creating a potential compliance gap if customers overlook this requirement.
ConductAtlas has identified this type of provision across 6 platforms. See the full comparison.
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