If you use Twilio to handle personal information about people, a separate Data Processing Addendum applies and governs how Twilio processes that data on your behalf.
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 terms establish that personal data processing is governed by a separately incorporated DPA, which is the operative compliance instrument for GDPR and CCPA obligations; customers must review and understand the DPA to meet their legal data processing obligations.
Interpretive note: The adequacy of the DPA for specific regulatory frameworks (GDPR, CCPA, HIPAA) cannot be assessed without reviewing the current DPA document, which is incorporated by reference.
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 →Customers processing personal data of end users through Twilio's platform are subject to the Data Processing Addendum, which governs Twilio's role as a data processor and the parties' respective data protection obligations.
How other platforms handle this
to request that your data be transferred to a third party (data portability)
Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.
"To the extent Customer uses the Services to process Personal Data, Customer agrees to the Data Processing Addendum (DPA), which is incorporated by reference into this Agreement and available at twilio.com/legal. The DPA governs the processing of Personal Data by Twilio on behalf of Customer.Excerpt from Segment's Terms of Service
(1) REGULATORY LANDSCAPE: This provision directly engages GDPR (particularly Articles 28 and 32, governing processor contracts and security obligations), CCPA (governing service provider relationships and data use restrictions), and potentially HIPAA where health-related communications are …
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The terms establish that personal data processing is governed by a separately incorporated DPA, which is the operative compliance instrument for GDPR and CCPA obligations; customers must review and understand the DPA to meet their legal data processing obligations.
Customers processing personal data of end users through Twilio's platform are subject to the Data Processing Addendum, which governs Twilio's role as a data processor and the parties' respective data protection obligations.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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