Twilio uses a consent tool to let you accept or decline non-essential tracking cookies; required cookies for site function cannot be turned off, but advertising and analytics cookies can be rejected.
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The notice states that advertising and analytics cookies require consent and can be withdrawn at any time, meaning users who decline non-essential cookies can limit behavioral tracking on the Twilio website.
Interpretive note: The exact verbatim text of the cookie consent provision was not directly reproduced in the accessible portion of the document; the excerpt reflects the substance of the policy as described in the privacy notice and corroborated by the TrustArc implementation visible in the page source.
This provision states that users can manage their consent for advertising and analytics cookies through the TrustArc consent tool on Twilio's website, and that withdrawing consent will not retroactively affect prior processing.
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<script async="async" defer="defer" src='https://consent.trustarc.com/notice?domain=twilio.com&c=teconsent>m=1&js=nj¬iceType=bb'></script> ... <script src="https://consent.trustarc.com/get?name=trustarc-segment-wrapper-v1.1.js"></script>
YOU MUST BE AND HEREBY AFFIRM THAT YOU ARE AN ADULT OF THE LEGAL AGE OF MAJORITY IN YOUR COUNTRY OR STATE OF RESIDENCE. If you are under the legal age of majority, your parent or legal guardian must consent to this agreement.
We rely upon you to obtain any consents from your friends and contacts that may be required by law to allow us to access, upload, and use their personal information for this purpose. You or your friends or contacts may reach us at privacy@draftkings.com to request the removal of this information fro...
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"We use a cookie consent management platform to obtain and manage your consent for non-essential cookies. You can manage your cookie preferences at any time by clicking on the cookie preference link available on our website. Certain cookies are necessary for the operation of the Services and cannot be disabled. For optional cookies, including those used for analytics and advertising, you can withdraw your consent at any time, and such withdrawal will not affect the lawfulness of processing before the withdrawal.— Excerpt from Twilio's Twilio Privacy Notice
(1) REGULATORY LANDSCAPE: The ePrivacy Directive and GDPR together require opt-in consent for non-essential cookies in the EU and UK. The TrustArc consent management platform is identified in the page source as the mechanism used. The UK ICO and EU national DPAs have published guidance requiring that consent be freely given, specific, informed, and unambiguous, and that refusal be as easy as acceptance. (2) GOVERNANCE EXPOSURE: Medium. The effectiveness of the consent mechanism depends on whether non-essential scripts are technically blocked prior to consent being obtained. If tracking scripts fire before the consent banner is interacted with, the mechanism may not satisfy GDPR or UK GDPR requirements. Auditing the TrustArc implementation is a standard compliance control. (3) JURISDICTION FLAGS: EU and EEA users require opt-in consent under the ePrivacy Directive. UK users require opt-in consent under the UK GDPR and UK ePrivacy regulations. US users in states with opt-out regimes (California, Colorado, Virginia, Connecticut) have different mechanisms. The same consent platform must handle both opt-in and opt-out regimes appropriately. (4) COMPLIANCE CONSIDERATIONS: Compliance teams should test the TrustArc implementation to confirm that all non-essential scripts are blocked prior to consent, that the consent record is stored and retrievable, and that the preference center accurately reflects the full list of cookies in use. Annual cookie audits should be conducted to identify new tracking technologies not covered by the existing consent configuration. (5) CONTRACT AND VENDOR IMPLICATIONS: The consent management platform provider (TrustArc) should be under a DPA with Twilio. The scope of the DPA should cover consent record storage, consent signal propagation to third-party vendors, and data subject request support.
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The notice states that advertising and analytics cookies require consent and can be withdrawn at any time, meaning users who decline non-essential cookies can limit behavioral tracking on the Twilio website.
This provision states that users can manage their consent for advertising and analytics cookies through the TrustArc consent tool on Twilio's website, and that withdrawing consent will not retroactively affect prior processing.
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