Twilio keeps your personal information for as long as it needs it to run its business or meet legal requirements, without specifying fixed deletion timelines for most data categories.
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 does not state specific retention periods for most categories of personal data, meaning data collected from website visits and marketing interactions may be retained for extended periods at Twilio's discretion.
Interpretive note: The notice does not specify retention periods for individual data categories; actual retention durations depend on internal Twilio policies not published in the notice.
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 →Removal of data retention policy details eliminates clarity on how long Twilio stores personal information and the criteria used to determine retention periods.
View full change record →Establishes explicit data retention principles and criteria, demonstrating commitment to data minimization and compliance with privacy law retention requirements.
View full change record →This provision states that retention periods are determined by Twilio based on business need and legal requirements without publishing specific timelines, which may affect how long contact, behavioral, and device data is held.
How other platforms handle this
We retain personal information for as long as necessary to provide our services, comply with legal obligations, resolve disputes, and enforce our agreements. The specific retention periods depend on the type of information and the purposes for which it is processed.
We keep information for as long as we need it to provide our products, comply with legal obligations, or for other legitimate purposes, such as to maintain safety, security, and integrity.
After your account is deleted, we keep data about interactions you've had on our service to prevent abuse, ban evaders and others in an effort to protect and ensure the safety and security of our service and our members.
Monitoring
Twilio has changed this document before.
Receive same-day alerts, structured change summaries, and monitoring for up to 25 platforms.
"We retain 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. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the data, whether we can achieve those purposes through other means, and the applicable legal requirements.— Excerpt from Twilio's Twilio Privacy Notice
(1) REGULATORY LANDSCAPE: GDPR requires that personal data be kept in a form that permits identification for no longer than necessary for the purpose for which it was processed, per the storage limitation principle. The absence of specific retention periods in the notice may be assessed by EU supervisory authorities as insufficient transparency. CCPA does not impose specific retention limits but requires disclosure of retention practices. (2) GOVERNANCE EXPOSURE: Medium. The criteria-based approach to retention without published timeframes is common in enterprise privacy notices but may be challenged by EU regulators as insufficiently specific. Compliance teams should maintain internal retention schedules that map to the criteria described. (3) JURISDICTION FLAGS: EU and UK supervisory authorities have indicated that GDPR-compliant retention notices should include either specific periods or the criteria used to determine them in sufficient detail for data subjects to understand expected retention. The current language meets the minimum criteria-based standard but may not satisfy all supervisory authority expectations. (4) CONTRACT AND VENDOR IMPLICATIONS: Service providers receiving personal data should be subject to retention obligations consistent with Twilio's stated criteria. DPAs should specify maximum retention periods or require vendors to delete data upon termination of the service relationship. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should document internal retention schedules for each data category, align vendor agreements with those schedules, and ensure deletion or anonymization procedures are operative. EU and UK data subjects have the right to erasure where retention is no longer necessary, and the request process should be tested against retention system capabilities.
Full compliance analysis
Regulatory citations, enforcement risk, and due diligence action items.
Free: track 1 platform + weekly digest. Monitor: 25 platforms + same-day alerts. No credit card required.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
Compliance Governance Intelligence
Need to monitor specific governance provisions?
Compliance includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.
Built from archived source documents, structured governance mappings, and historical version tracking.
The notice does not state specific retention periods for most categories of personal data, meaning data collected from website visits and marketing interactions may be retained for extended periods at Twilio's discretion.
This provision states that retention periods are determined by Twilio based on business need and legal requirements without publishing specific timelines, which may affect how long contact, behavioral, and device data is held.
ConductAtlas has identified this type of provision across 136 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Twilio.