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 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 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 will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
We store information until it is no longer necessary to provide our services and WhatsApp Products, or until your account is deleted or becomes inactive, whichever comes first. This is a case-by-case determination that depends on things like the nature of the information, why it is collected and pro...
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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.
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