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 establishes the operational scope of data sharing across Twilio's service ecosystem and third-party partners. By characterizing certain sharing as a potential 'sale' or 'sharing' under California law, the clause creates a defined legal framework for how personal information flows beyond Twilio's direct control.
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, users' personal information may be disclosed to multiple categories of third parties for marketing, advertising, and analytics purposes as part of Twilio's standard service operations. Users operating under these terms have their personal information subject to sharing with advertising networks and analytics platforms identified by Twilio.
How other platforms handle this
We may share your information with third-party vendors and service providers that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. We may also share your information with third-party advertising p...
Sending you information about Adobe products and services, special offers and similar information, and sharing your information with third parties for their own marketing purposes, where your consent is not required; In some cases, in order to show you more relevant ads, we disclose with social medi...
We may share your personal information with third-party vendors and service providers that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. We may also share your personal information with busines...
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"We may share your personal information with third-party vendors and service providers that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. We may also share your personal information with third-party advertising and analytics partners, including social media companies, to deliver targeted advertisements and analyze the effectiveness of our marketing campaigns. This sharing may constitute a 'sale' or 'sharing' of personal information under California law.— Excerpt from Twilio's Twilio Privacy Notice
ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.
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The provision establishes the operational scope of data sharing across Twilio's service ecosystem and third-party partners. By characterizing certain sharing as a potential 'sale' or 'sharing' under California law, the clause creates a defined legal framework for how personal information flows beyond Twilio's direct control.
Under this clause, users' personal information may be disclosed to multiple categories of third parties for marketing, advertising, and analytics purposes as part of Twilio's standard service operations. Users operating under these terms have their personal information subject to sharing with advertising networks and analytics platforms identified by Twilio.
ConductAtlas has identified this type of provision across 17 platforms. See the full comparison.
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