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The notice discloses that Twilio uses automated processing to make real-time decisions on account approvals and account suspensions, and states that affected users will be notified and given an opportunity to request human review of these decisions.
This analysis describes what Twilio'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
This provision establishes that account access and suspension decisions are made through automated processing and that a human review mechanism is available upon objection. The provision engages GDPR Article 22 and equivalent state-level protections, and the notice specifies the exercise mechanism as contact with privacy@twilio.com or Customer Support.
Interpretive note: The notice does not specify the timeline for user notification following automated suspension or for completing human review upon objection, creating ambiguity regarding compliance with GDPR Article 22 safeguard requirements.
The updated Privacy Notice now explicitly discloses that Twilio is subject to FTC investigatory and enforcement powers, clarifying the regulatory oversight applying to the company. The policy also establishes an opt-out right allowing users to prevent disclosure of their data to third parties (other than service providers) or use of data for purposes materially different from the original collection purpose. You can exercise this opt-out by contacting Twilio through the mechanisms described in the privacy notice.
View change record →The updated notice establishes more explicit disclosures of Twilio's Data Privacy Framework certifications and specifies the legal hierarchy governing data processing. Under the revised policy, the DPF Principles now take precedence if they conflict with other terms in the privacy notice. The updated language also clarifies your right to opt out of third-party disclosures (except to service providers acting on Twilio's behalf) and to opt out of uses that materially differ from original collection purposes. You can exercise these choices by contacting privacy@twilio.com.
View change record →The updated Privacy Notice now provides more detailed explanations of how Twilio collects and processes personal data, including explicit definitions of what constitutes personal data and descriptions of direct relationships (when you create an account or opt into communications) versus indirect relationships (when you are a customer of one of Twilio's customers). The revised language establishes that Twilio acts as a data controller and determines how and why personal data is processed, subject to applicable law. The notice states it aims to be transparent about data use and to explain how you can exercise your rights, but the change itself does not modify what data is collected, how it is used, or what rights or controls are available to you.
View change record →Under this clause, account approval and suspension decisions may be executed through automated processing without prior human review. The agreement states that users will be notified of automated suspension decisions and may request human review by contacting privacy@twilio.com.
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"Utilizing signals to make real-time automated security decisions, such as approving account applications or suspending fraudulent accounts (of which you will be notified and given an opportunity to object). [...] Object to and request a human review of decisions Twilio makes about you based solely on automated processing, which currently includes account approvals and account suspensions related to abusive or fraudulent activity, or other decisions that significantly affect you.Excerpt from Twilio's Privacy Notice
1) REGULATORY LANDSCAPE: This provision directly engages GDPR Article 22, which restricts solely automated decisions that produce legal or similarly significant effects on data subjects, and requires that controllers implement suitable safeguards including the right to obtain human intervention. The FTC and U.S. state attorneys general may also have jurisdiction where automated account actions constitute unfair or deceptive practices. 2) GOVERNANCE EXPOSURE: Medium. The notice states a human review mechanism exists and that users will be notified, which aligns with GDPR Article 22 safeguard requirements. However, the notice does not specify the timeline for notification or human review response, which may create compliance gaps under GDPR. 3) JURISDICTION FLAGS: Heightened exposure in the EEA and UK under GDPR Article 22. California CPRA grants consumers the right to opt out of automated decision-making that produces legal or similarly significant effects, and California regulations may impose additional notice and appeal requirements. 4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers whose sub-accounts or end-user accounts may be subject to automated suspension should evaluate whether their service agreements with Twilio address notification timelines and the operational impact of automated account actions on their business continuity. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should confirm the internal human review process for automated account decisions meets GDPR Article 22 safeguard requirements, verify that notification procedures meet applicable jurisdiction-specific timeliness requirements, and assess whether the scope of automated decisions extends beyond account approvals and suspensions to other significant operational decisions.
This provision establishes that account access and suspension decisions are made through automated processing and that a human review mechanism is available upon objection. The provision engages GDPR Article 22 and equivalent state-level protections, and the notice specifies the exercise mechanism as contact with privacy@twilio.com or Customer Support.
Under this clause, account approval and suspension decisions may be executed through automated processing without prior human review. The agreement states that users will be notified of automated suspension decisions and may request human review by contacting privacy@twilio.com.
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