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
Businesses processing EU personal data through Twilio must execute the Data Protection Addendum to comply with GDPR — failure to do so exposes both the business and Twilio to regulatory penalties.
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-domici…
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.
How other platforms handle this
To the extent that Duo processes any Personal Data (as defined in the Duo Privacy Data Sheet) on behalf of Customer in connection with Customer's use of the Services, the terms of the Duo Data Processing Agreement ('DPA'), which are hereby incorporated by reference into this Agreement, shall apply a...
Cloudflare's current Privacy Policy is incorporated into this Agreement by this reference and is located at https://www.cloudflare.com/privacypolicy/. In addition, by using the Services, you acknowledge and agree that internet transmissions are never completely private or secure.
If you access or use any of Oura's location-based services, such as by enabling GPS-based activity tracking through our Services, Oura may process the approximate or precise location of your device while the service is active. This data may be obtained via your device's service provider network ID, ...
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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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Businesses processing EU personal data through Twilio must execute the Data Protection Addendum to comply with GDPR — failure to do so exposes both the business and Twilio to regulatory penalties.
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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