A cloud communications platform that provides APIs and tools for businesses to integrate voice, messaging, video, and email capabilities into their applications and services. The company enables developers to build communication features like SMS notifications, voice calls, and video conferencing directly into software products. Their policies are significant for consumers because personal communications data flows through their infrastructure when businesses use Twilio's services to reach customers.

3 Documents
80 All provisions 21 High severity 47 Medium severity 12 Low severity
16 Changes · 12 mo
Jul 17, 2026 Last change

High, provisions that significantly limit your legal rights, authorize broad data collection, or create material financial exposure. Medium, provisions worth knowing about but with partial protections or limited scope. Low, standard terms with minimal consumer impact.

Governance Coverage
Data Usage
40 provisions · 4 high · 13 med
Contract Terms
38 provisions · 7 high · 28 med
Data Collection
26 provisions · 5 high · 17 med
Data Sharing
22 provisions · 6 high · 11 med
Privacy Rights
19 provisions · 4 high · 11 med
Payment Fees
15 provisions · 7 high · 7 med
Legal Jurisdiction
12 provisions · 4 high · 8 med
Ai Automated
11 provisions · 3 high · 8 med
Enforcement Actions
10 provisions · 8 high · 2 med
Arbitration
8 provisions · 2 high · 6 med
Quick Facts
Arbitration: Mandatory
AI Training: Disclosed (high impact)
Data Retention: Specified
Key Governance Provisions
High Prohibition On Reselling Or Sublicensing Services

This prohibition prevents customers from commercialising or redistributing Twilio's services independently, while preserving the ability to pass services through to End Users.

High Twilio Inc. acts as sub-processor for non-US contracting entities

This means Twilio Inc. can process customer personal data as a sub-processor even when it is not the direct contracting party, which affects the chain of data processing responsibility and applicable…

High Non-regional account data processed in United States

Customers who have not selected a regional data arrangement should expect their account and service usage data to be processed in the United States, with the legal and compliance implications that en…

High Regional Twilio customer content stored in selected region

Regional data residency is not absolute; Twilio retains the ability to move Customer Content outside the selected region when investigating fraud or abuse, which is a meaningful limitation on the reg…

High Duration of processing tied to customer service use

The duration of personal data processing by sub-processors is directly linked to both active service use and contractually agreed retention periods, meaning data is not automatically deleted upon sto…

Document Coverage
Privacypolicy Subprocessorlist Termsofservice
Last change detected: Jul 17, 2026 Changes (12 months): 16 Documents monitored: 3 Provisions tracked: 80
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Documents

Twilio Sub-Processors

Medium

This document lists the third-party companies Twilio uses to process customer data and explains the rules those companies must follow. Your data is processed for as long as you use …

Last updated July 6, 2026 · Sub processor list
8 provisions 1 version captured Version history →

Twilio Privacy Notice

Medium

Twilio's Privacy Notice explains how Twilio collects and uses your personal data—including the actual content of communications like emails and texts—to deliver its services, detect fraud, and build unified profiles …

Last updated May 5, 2026 · Privacy policy
10 provisions 9 versions captured 3 significant changes Version history →

Twilio Terms of Service

High

This document sets the rules for using Twilio's services: Twilio must deliver the services and meet its SLA, and you are solely responsible for everything that happens under your account. …

Last updated May 5, 2026 · Terms of service
10 provisions 7 versions captured 4 significant changes Version history →

Recent Changes

May 22, 2026 · Twilio Privacy Notice Medium

Twilio added two new disclosures to its Privacy Notice on May 22, 2026. First, the policy now explicitly states that Twilio Inc. is subject to FTC investigatory and enforcement powers. …

View change record →
May 19, 2026 · Twilio Privacy Notice Medium

Twilio updated its privacy notice on May 19, 2026 to provide more explicit detail about its Data Privacy Framework (DPF) compliance and certification. The revised language states that Twilio Inc. …

View change record →
May 9, 2026 · Twilio Terms of Service Medium

Twilio updated its Terms of Service on May 9, 2026, making substantial changes to dispute resolution procedures for Mexico-based customers and removing arbitration provisions for Mexico from its general arbitration …

View change record →
April 19, 2026 · Twilio Terms of Service Medium

Twilio updated its Terms of Service on April 19, 2026 to expand the geographic scope of service entities, add new Mexico and Brazil-specific entities to the agreement, and clarify how …

View change record →
April 10, 2026 · Twilio Terms of Service Medium

Twilio updated its Terms of Service on April 10, 2026 to reflect new regional entity assignments and clarifications to service definitions. The revised terms now direct customers in Mexico and …

View change record →
📈 Policy Drift Analysis View all changes →

Low Severity Provisions (11)

View all high severity provisions → Compare Twilio with other platforms →

Applicable Regulations

CCPA/CPRA
California, USA
View official text ↗
CFAA
United States Federal
View official text ↗
Connecticut Data Privacy Act Amendments
US-CT
View official text ↗
CAN-SPAM
United States Federal
View official text ↗
ePrivacy Directive
European Union
View official text ↗
FAA
United States Federal
View official text ↗
FTC Act Section 5
United States Federal
View official text ↗
GDPR
European Union
View official text ↗
Indiana Consumer Data Protection Act
US-IN
View official text ↗
Kentucky Consumer Data Protection Act
US-KY
View official text ↗
Universal Opt-Out Mechanism Expansion 2026
US
View official text ↗

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Frequently Asked Questions

What Twilio documents does ConductAtlas track?

ConductAtlas tracks 3 Twilio documents including terms of service, privacy policy, and other governance documents. Every document is captured daily with cryptographic verification.

How many policy changes has Twilio made in the past year?

Twilio has made 16 policy changes in the past 12 months across the documents ConductAtlas tracks.

How many provisions has ConductAtlas classified for Twilio?

ConductAtlas has classified 80 provisions across Twilio's tracked documents. 21 are rated high severity, 47 medium, and 12 low.

Can I get alerts when Twilio changes their policies?

Yes. Monitor subscribers ($4.99/month) can add Twilio to their watchlist and receive same-day email alerts whenever any tracked document changes.