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The notice states that Twilio's services are not directed to children under 13 in the U.S. and UK or under 16 in the EEA, and that accounts found to belong to children will be deactivated and data deleted.
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 sets age thresholds consistent with COPPA in the U.S. and GDPR Article 8 in the EEA, and provides a reporting mechanism for inadvertent collection at privacy@twilio.com. The notice applies a higher threshold of 16 for EEA users, which aligns with the maximum age of digital consent available to EU member states under GDPR.
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, Twilio's services are restricted to users aged 13 and above in the U.S. and UK and 16 and above in the EEA. Accounts identified as belonging to children will be deactivated and associated data deleted, and reports of inadvertent child data collection may be submitted to privacy@twilio.com.
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"Our Services are not directed to or intended to be used by children (under the age of 13 in the U.S. and UK, or 16 in the EEA). If we discover that a child has created an account, we will deactivate it and delete the data as quickly as possible. If you believe we have inadvertently collected data from a child, please contact us at privacy@twilio.com with the subject line 'Children'.Excerpt from Twilio's Privacy Notice
1) REGULATORY LANDSCAPE: This provision engages COPPA in the U.S. (enforced by the FTC), GDPR Article 8 in the EEA, and equivalent UK GDPR provisions. The EEA threshold of 16 aligns with the upper bound available to member states under GDPR Article 8, though individual member states may set lower thresholds. The UK's Age Appropriate Design Code (Children's Code) may also be relevant for UK-facing services. 2) GOVERNANCE EXPOSURE: Low. The provision aligns with standard COPPA and GDPR Article 8 compliance language. The deactivation and deletion commitment upon discovery is consistent with regulatory requirements. 3) JURISDICTION FLAGS: Individual EEA member states may apply age thresholds lower than 16 under GDPR Article 8, which could create compliance variance for Twilio's uniform 16-year threshold. The UK Children's Code may impose additional obligations for services accessible to minors. 4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers who deploy Twilio services in consumer-facing contexts where minors may be present should evaluate their own COPPA and GDPR Article 8 compliance obligations, as Twilio's processor role means Twilio will follow customer instructions for data handling in those contexts. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether Twilio's age restriction mechanism includes active age verification procedures or relies on self-attestation, and evaluate whether the 16-year EEA threshold is consistently applied across all EEA member states given varying national implementations of GDPR Article 8.
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This provision sets age thresholds consistent with COPPA in the U.S. and GDPR Article 8 in the EEA, and provides a reporting mechanism for inadvertent collection at privacy@twilio.com. The notice applies a higher threshold of 16 for EEA users, which aligns with the maximum age of digital consent available to EU member states under GDPR.
Under this clause, Twilio's services are restricted to users aged 13 and above in the U.S. and UK and 16 and above in the EEA. Accounts identified as belonging to children will be deactivated and associated data deleted, and reports of inadvertent child data collection may be submitted to privacy@twilio.com.
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