Segment · Segment Terms of Service · View original document ↗

Data Processing and Privacy Obligations

High severity Rare · 6 of 343 platforms
Share 𝕏 Share in Share 🔒 PDF
Monitor governance changes for Segment Create a free account to receive the weekly governance digest and monitor one platform for governance changes.
Create free account No credit card required.
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)

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.

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-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 →
Medium May 5, 2026

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 →

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

Signal Medium

Signal can optionally discover which contacts in your address book are Signal users, using a service designed to protect the privacy of your contacts. Information from the contacts on your device may be cryptographically hashed and transmitted to the server in order to determine which of your contac...

Walmart Medium

We collect information about you when you shop in our stores, including through store cameras, loyalty programs, payment processing systems, and other in-store technologies. This information is used to improve store operations, loss prevention, and marketing.

LinkedIn Medium

We target (and measure the performance of) ads to Members, Visitors and others both on and off our Services directly or through a variety of partners, using the following data, whether separately or combined: Data from advertising technologies on and off our Services, like web beacons, pixels, ad ta...

See all platforms with this clause type →

Monitoring

Segment has changed this document before.

Receive same-day alerts, structured change summaries, and monitoring for up to 25 platforms.

Start Monitor free trial Or create a free account →
▸ 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.

Track 1 platform — free Try Monitor free for 14 days

Free: track 1 platform + weekly digest. Monitor: 25 platforms + same-day alerts. No credit card required.

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: June 30, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

Related Analysis

Compliance Governance Intelligence

Need to monitor specific governance provisions?

Compliance includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.

Arbitration clauses AI governance Data rights Indemnification Retention policies
Start Compliance free trial

Or start with Monitor →

Built from archived source documents, structured governance mappings, and historical version tracking.

Frequently Asked Questions

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

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.

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.