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The notice discloses that Twilio uses cookies, pixels, and web beacons for advertising purposes and acknowledges that under some U.S. state laws this activity constitutes sharing or targeted advertising. Users may opt out of advertising cookies at any time via the Cookie Preferences tool or browser settings.
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 acknowledges that cookie-based advertising activities may constitute sharing or targeted advertising under U.S. state privacy laws including CCPA and CPRA, and provides opt-out mechanisms via the Cookie Preferences tool, browser settings, Global Privacy Control, and ad industry opt-out tools. The notice also discloses that required cookies cannot be opted out of.
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, advertising cookies and web beacons are used to deliver targeted advertising, and the notice acknowledges this may constitute sharing under applicable U.S. state laws. Users may opt out of advertising and functional cookies through the Cookie Preferences icon in the Twilio website footer, browser settings, or the Global Privacy Control.
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"We use cookies, pixels, web beacons, and similar tools to secure our website, analyze performance, and deliver relevant ads. These tools help us recognize your device to make your experience more secure, efficient and tailored to your interests. Under some U.S. state laws, this is considered 'sharing' or 'targeted advertising.' [...] Advertising: Used to show you content and ads that are relevant to your interests. You can opt-out of advertising cookies at any time.Excerpt from Twilio's Privacy Notice
1) REGULATORY LANDSCAPE: CCPA and CPRA classify cookie-based advertising data sharing as a sale or sharing of personal information requiring an opt-out mechanism. The notice's acknowledgment that this activity constitutes sharing or targeted advertising under some U.S. state laws engages CPRA opt-out requirements enforced by the California Privacy Protection Agency. The FTC Act also applies to advertising tracking practices. 2) GOVERNANCE EXPOSURE: Medium. The notice provides multiple opt-out mechanisms including Global Privacy Control, which California regulations require to be honored as a valid opt-out signal. Compliance teams should verify that the GPC signal is operationally honored across all Twilio web properties. 3) JURISDICTION FLAGS: Heightened exposure in California under CPRA, and in U.S. states that have enacted similar opt-out rights for targeted advertising. EU and UK users are subject to ePrivacy Directive requirements for cookie consent prior to placing non-essential cookies, which the notice addresses through the Cookie Preferences tool. 4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers whose employees or contractors interact with Twilio web properties may have their activity tracked for advertising optimization. The notice's disclosure of identity resolution to create unified profiles across devices is operationally significant for enterprise users who may not expect cross-device tracking on a B2B platform. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should audit whether Twilio's Cookie Preferences tool meets ePrivacy Directive prior consent requirements for EU and UK users, confirm that Global Privacy Control signals are operationally honored, and assess whether identity resolution and unified profile creation for advertising optimization constitutes profiling subject to GDPR Article 22 protections.
This provision acknowledges that cookie-based advertising activities may constitute sharing or targeted advertising under U.S. state privacy laws including CCPA and CPRA, and provides opt-out mechanisms via the Cookie Preferences tool, browser settings, Global Privacy Control, and ad industry opt-out tools. The notice also discloses that required cookies cannot be opted out of.
Under this clause, advertising cookies and web beacons are used to deliver targeted advertising, and the notice acknowledges this may constitute sharing under applicable U.S. state laws. Users may opt out of advertising and functional cookies through the Cookie Preferences icon in the Twilio website footer, browser settings, or the Global Privacy Control.
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