Segment · Segment Terms of Service · View original document ↗

Data Processing and Privacy Obligations

High severity Rare · 6 of 325 platforms
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Document Record

What it is

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

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.

Recent Activity

This document changed recently

Medium May 9, 2026

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…

Consumer impact (what this means for users)

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

Duo Security Medium

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 Medium

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.

Oura Medium

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, ...

See all platforms with this clause type →

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▸ View Original Clause Language DOCUMENT RECORD
"
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

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

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.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC enforces data privacy obligations under FTC Act Section 5 for US businesses and has authority over unfair data processing practices that affect consumers.
    File a complaint →
  • Hhs Ocr
    Healthcare entities using Twilio to transmit protected health information must execute a HIPAA Business Associate Agreement; HHS OCR enforces HIPAA compliance requirements.
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
Colorado AI Act
US-CO
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
FTC Act Section 5
United States Federal
GDPR
European Union

Provision details

Document information
Document
Segment Terms of Service
Entity
Segment
Document last updated
May 5, 2026
Tracking information
First tracked
May 8, 2026
Last verified
May 8, 2026
Record ID
CA-P-006413
Document ID
CA-D-00699
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
977430b2264496ecbdb714c775602a9bdf2f57f24a6495ba35f765f94113b442
Analysis generated
May 8, 2026 09:56 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Segment
Document: Segment Terms of Service
Record ID: CA-P-006413
Captured: 2026-05-08 09:56:53 UTC
SHA-256: 977430b2264496ec…
URL: https://conductatlas.com/platform/segment/segment-terms-of-service/data-processing-and-privacy-obligations/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Segment's Data Processing and Privacy Obligations clause do?

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.

How does this clause affect you?

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 many platforms have this type of clause?

ConductAtlas has identified this type of provision across 6 platforms. See the full comparison.

Is ConductAtlas affiliated with Segment?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Segment.