Provision record
Segment · Segment Terms of Service · View original document ↗

Data Processing and Privacy Obligations

High severity Common · 279 of 352 platforms
Stay ahead of the changes
Track Segment and get the diff the day its terms change.
Share 𝕏 Share in Share 🔒 PDF
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

MyFitnessPal Medium

We use your personal information to comply with applicable legal and regulatory obligations and respond to legally valid requests and communications from law enforcement authorities to the extent required by applicable law.

Lyft Medium

We may infer certain information from your interactions with the Lyft Platform and other personal information available to us. For example, if you frequently ride to or from airports, we may infer you are a frequent traveler.

Square Medium

we may use this information to make it easier for you to find the people you want to send payments to, for account and identity verification and fraud prevention purposes, to reduce the risk you will send payments to the wrong person, or to provide other personalized services.

See all platforms with this clause type →
▸ 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 Terms of Service

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

REGULATORY FRAMEWORK: GDPR Art.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →
  • Department Of Health & Human Services, Office For Civil Rights (hhs Ocr)
    Enforces HIPAA Privacy and Security Rules, which protect health information held by healthcare providers, health plans, and their business associates.
    Who can file: Anyone whose HIPAA rights may have been violated by a covered entity (healthcare provider, health plan, or healthcare clearinghouse)
    What you need: Name of the entity, description of the violation, date of the incident, and your contact information. Must file within 180 days of the violation.
    What to expect: HHS OCR investigates and may require the entity to take corrective action. Does not provide individual compensation. Serious violations can result in civil monetary penalties.
    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/provision/CA-P-006413/data-processing-and-privacy-obligations/
Accessed: Sept. 20, 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

Get the research letter

Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.

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 279 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.