Twilio · Twilio Privacy Notice · View original document ↗

CCPA Sale or Sharing Opt-Out

Medium severity High confidence Explicitdocumentlanguage Unique · 0 of 343 platforms
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Recent governance activity Twilio recorded 2 documented changes in the last 30 days.
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Document Record

What it is

California residents can opt out of having their data shared for targeted advertising by using Twilio's privacy portal or by enabling Global Privacy Control in their browser.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

The notice acknowledges that sharing data with advertising partners may qualify as a sale or sharing under CCPA/CPRA, which triggers a legally mandated right for California residents to opt out of this specific data use.

Recent Activity

This document changed recently

Medium May 22, 2026

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 →
Medium May 19, 2026

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 →
Medium Mar 19, 2026

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 →

Clause Stability Mostly Stable

2
Changes
3
Months Monitored
May 12, 2026
First Seen
May 20, 2026
Last Seen
This clause type exists across 3350 other provisions on other platforms.
This clause has changed 2 times in 3 months of monitoring — averaging roughly once every 1 month.

Change history

removed May 22, 2026

Removal of specific CCPA opt-out procedures and privacy portal reference eliminates clear guidance for California residents on exercising their statutory privacy rights.

View full change record →
added May 19, 2026

Adds explicit CCPA compliance language and opt-out mechanism, reflecting evolving California privacy law requirements and consumer protection obligations.

View full change record →

Consumer impact (what this means for users)

This provision states that California residents can exercise opt-out rights for targeted advertising data sharing via https://privacy.twilio.com or by using a Global Privacy Control-enabled browser, which Twilio states it will honor.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Opt Out of Arbitration
    Navigate to https://privacy.twilio.com, select the option to opt out of the sale or sharing of personal information, and complete the request form. Alternatively, enable Global Privacy Control in a compatible browser before visiting twilio.com.

How other platforms handle this

Garmin Medium

If you are a California resident, you have the right to know what personal information we collect, use, and disclose about you; the right to request deletion of your personal information; the right to opt out of the sale or sharing of your personal information; the right to correct inaccurate person...

Skillshare Medium

If you are a California resident, you have the right to: Know what personal information is being collected about you; Know whether your personal information is sold or disclosed and to whom; Say no to the sale of personal information; Access your personal information; Request deletion of your person...

Ancestry Medium

Depending on where you live, you may have certain rights with respect to your personal information, such as the right to request access, correction, or deletion of your personal information, or to opt out of the sale or sharing of your personal information. If you are a California resident, you have...

See all platforms with this clause type →

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▸ View Original Clause Language DOCUMENT RECORD
"
California residents have the right to opt out of the sale of their personal information. As described in this notice, we may share certain personal information with third parties for purposes of cross-context behavioral advertising, which may constitute a sale or sharing under California law. To opt out of the sale or sharing of your personal information, please visit our privacy request portal at https://privacy.twilio.com or enable a Global Privacy Control signal in your browser, which we will treat as a valid opt-out request.

— Excerpt from Twilio's Twilio Privacy Notice

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: CCPA and CPRA require businesses that sell or share personal information for cross-context behavioral advertising to provide a clear opt-out mechanism. The California Privacy Protection Agency and California Attorney General are the primary enforcement authorities. Failure to honor opt-out signals, including Global Privacy Control, may constitute a violation of CPRA. (2) GOVERNANCE EXPOSURE: High. The notice acknowledges that current data sharing practices may constitute a sale or sharing under California law, confirming that CPRA opt-out obligations are triggered. Compliance teams must ensure the opt-out mechanism covers all downstream data flows to advertising vendors. (3) JURISDICTION FLAGS: This provision applies specifically to California residents under CCPA and CPRA. Similar opt-out rights exist for residents of Colorado, Virginia, Connecticut, Texas, and other states with comprehensive privacy laws, though the notice's explicit coverage of these states should be verified. (4) CONTRACT AND VENDOR IMPLICATIONS: Vendors receiving data flagged for opt-out must be contractually prohibited from processing that data for advertising purposes. Twilio's service agreements with advertising partners should include provisions requiring them to honor opt-out signals propagated from Twilio. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should audit whether the Global Privacy Control signal is technically detected and propagated to all advertising and analytics vendors on the Twilio website. The opt-out mechanism should be tested for functionality on each page that deploys tracking scripts. Records of opt-out requests and their processing should be maintained.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • State AG
    The California Attorney General and California Privacy Protection Agency enforce CCPA and CPRA opt-out of sale and sharing obligations.
    File a complaint →

Applicable regulations

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

Provision details

Document information
Document
Twilio Privacy Notice
Entity
Twilio
Document last updated
May 5, 2026
Tracking information
First tracked
May 10, 2026
Last verified
May 12, 2026
Record ID
CA-P-010912
Document ID
CA-D-00252
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
1e5bbf4d983ee8081c4ac6d66bb2964eb214225dcf4ded575c19b5ff3fe5f3d5
Analysis generated
May 10, 2026 09:42 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Twilio
Document: Twilio Privacy Notice
Record ID: CA-P-010912
Captured: 2026-05-10 09:42:01 UTC
SHA-256: 1e5bbf4d983ee808…
URL: https://conductatlas.com/platform/twilio/twilio-privacy-notice/ccpa-sale-or-sharing-opt-out/
Accessed: July 4, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Twilio's CCPA Sale or Sharing Opt-Out clause do?

The notice acknowledges that sharing data with advertising partners may qualify as a sale or sharing under CCPA/CPRA, which triggers a legally mandated right for California residents to opt out of this specific data use.

How does this clause affect you?

This provision states that California residents can exercise opt-out rights for targeted advertising data sharing via https://privacy.twilio.com or by using a Global Privacy Control-enabled browser, which Twilio states it will honor.

Is ConductAtlas affiliated with Twilio?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Twilio.