Twilio · Twilio Privacy Notice · View original document ↗

Collection of Personal Identifiers and Behavioral Data

Medium severity Medium confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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Document Record

What it is

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

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.

Consumer impact (what this means for users)

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.

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.
  • Delete Your Data
    Visit https://privacy.twilio.com, select the data deletion or access request option, provide your contact details, and submit the form. Twilio will process the request in accordance with applicable law.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
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

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(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.

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC has jurisdiction over unfair or deceptive practices in the collection and use of consumer data on commercial websites.
    File a complaint →

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-010910
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-010910
Captured: 2026-05-10 09:42:01 UTC
SHA-256: 1e5bbf4d983ee808…
URL: https://conductatlas.com/platform/twilio/twilio-privacy-notice/collection-of-personal-identifiers-and-behavioral-data/
Accessed: May 13, 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 Collection of Personal Identifiers and Behavioral Data clause do?

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.

How does this clause affect you?

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.

Is ConductAtlas affiliated with Twilio?

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