Twilio collects names, email addresses, phone numbers, company names, and browsing behavior including pages visited and links clicked whenever you use its website.
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
The notice authorizes collection of both directly provided contact information and passively gathered behavioral data, which together can build a detailed profile of a visitor's interests and identity.
Interpretive note: The exact scope of passive data collection and the identity of all sub-processors receiving this data cannot be fully determined from the notice text alone.
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 →Removal of explicit description of directly collected personal identifiers reduces transparency about what data Twilio collects from users during account creation and interactions.
View full change record →Formally discloses the categories of personal data collected (directly provided and automatically collected), which is a standard and legally required element of privacy notices.
View full change record →This provision states that Twilio collects identifiers (name, email, phone, company) and behavioral data (IP address, pages viewed, links clicked) from website visitors, including those who do not create accounts.
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"We collect information you provide directly to us, such as when you fill out a form, create an account, make a purchase, request customer support, or otherwise communicate with us. The types of information we may collect include your name, email address, postal address, phone number, company name, job title, and any other information you choose to provide. We also automatically collect certain information about your device and how you interact with our Services, including your IP address, browser type, operating system, referring URLs, pages viewed, links clicked, and the date and time of your visit.— Excerpt from Twilio's Twilio Privacy Notice
(1) REGULATORY LANDSCAPE: Collection of IP addresses, device identifiers, and browsing activity constitutes personal data processing under GDPR and UK GDPR, requiring a valid lawful basis. Under CCPA and CPRA, IP addresses, browsing history, and inferences drawn from this data qualify as personal information subject to disclosure and opt-out rights. The FTC has jurisdiction over unfair or deceptive data practices affecting US consumers. (2) GOVERNANCE EXPOSURE: Medium. The combination of directly submitted contact data and passively collected behavioral data enables cross-session tracking and profile building. The legal basis asserted for passive collection (legitimate interests under GDPR) requires a documented balancing test and is subject to data subject objection rights. (3) JURISDICTION FLAGS: EU and UK residents have the right to object to processing on legitimate interests grounds. California residents have rights to know and delete collected personal information. Illinois, Virginia, Colorado, and Connecticut residents may have additional rights under state privacy laws. (4) CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should verify that data processing agreements covering passive collection (cookies, server logs) extend to all sub-processors receiving this data. The notice identifies multiple analytics vendors; each represents a separate data flow requiring contractual coverage. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should document the lawful basis for each category of data collection, maintain records of processing activities, and ensure the privacy notice is surfaced to users at the point of data collection. GDPR Article 13 disclosure requirements should be audited against the categories listed in this provision.
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The notice authorizes collection of both directly provided contact information and passively gathered behavioral data, which together can build a detailed profile of a visitor's interests and identity.
This provision states that Twilio collects identifiers (name, email, phone, company) and behavioral data (IP address, pages viewed, links clicked) from website visitors, including those who do not create accounts.
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