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 provision grants Twilio operational discretion to determine retention duration based on stated purposes and legal obligations rather than establishing defined retention windows. This approach allows retention to extend across multiple regulatory frameworks and business purposes without preset expiration dates.
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 →Users' personal information remains in Twilio's systems indefinitely pending the company's assessment that retention purposes have been satisfied or legal requirements no longer apply. The terms do not establish user rights to request deletion after specific periods or mechanisms for challenging the necessity determination.
How other platforms handle this
We keep your personal information for as long as we need it for the purposes described in this Privacy Statement, to provide you with the Netflix service, to administer your account (including maintaining your account if you become an inactive member), and to comply with our legal obligations. This ...
We retain personal data for as long as necessary to provide our services, fulfill the purposes described in this Privacy Policy, comply with our legal obligations, resolve disputes, and enforce our agreements. The specific retention period for each category of personal data depends on the purpose fo...
We retain your personal information for as long as necessary to fulfill the purposes outlined in this privacy policy, unless a longer retention period is required or permitted by law. We may also retain and use your information to comply with our legal obligations, resolve disputes, and enforce our ...
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"We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements, and as long as required by applicable laws.— Excerpt from Twilio's Twilio Privacy Notice
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The provision grants Twilio operational discretion to determine retention duration based on stated purposes and legal obligations rather than establishing defined retention windows. This approach allows retention to extend across multiple regulatory frameworks and business purposes without preset expiration dates.
Users' personal information remains in Twilio's systems indefinitely pending the company's assessment that retention purposes have been satisfied or legal requirements no longer apply. The terms do not establish user rights to request deletion after specific periods or mechanisms for challenging the necessity determination.
ConductAtlas has identified this type of provision across 1 platforms. See the full comparison.
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