Twilio shares your personal information with outside companies that help it run its business, including analytics, advertising, and email service providers, as well as Twilio's own corporate family of companies.
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 authorizes disclosure of personal information to an undefined number of third-party service providers across functional categories including advertising and analytics, as well as to corporate affiliates, which may include entities operating under different privacy standards.
Interpretive note: The notice does not enumerate all service providers by name, making it difficult to assess the complete scope of third-party data flows from the notice text alone.
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 explicit disclosure about data sharing with service providers and affiliates reduces transparency about third-party access to personal information.
View full change record →Clarifies data sharing practices with third parties and affiliates while requiring data protection standards, addressing transparency and accountability concerns in data processing.
View full change record →This provision states that personal information collected on Twilio's website may be shared with third-party vendors in advertising, analytics, payment processing, and email delivery, as well as with Twilio's corporate subsidiaries and parent companies.
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"We may share your personal information with third-party vendors, service providers, contractors, or agents who perform services on our behalf, such as analytics, advertising, payment processing, customer support, and email delivery. We may also share your information with our corporate affiliates, including subsidiaries and parent companies, for purposes consistent with this privacy notice. We require these parties to maintain the confidentiality and security of the personal information they process on our behalf and to use it only as directed by us.— Excerpt from Twilio's Twilio Privacy Notice
(1) REGULATORY LANDSCAPE: Data sharing with service providers engages GDPR processor requirements under Article 28, requiring written data processing agreements. Under CCPA and CPRA, sharing with service providers must be governed by a written contract prohibiting secondary use of the data. The FTC has jurisdiction over deceptive disclosures about third-party data sharing. (2) GOVERNANCE EXPOSURE: Medium. The notice does not enumerate all third-party service providers by name, which limits the ability of data subjects and compliance teams to assess the full scope of data flows. The assertion that recipients are contractually bound to confidentiality and restricted use should be verified through vendor DPA audits. (3) JURISDICTION FLAGS: EU and UK residents have rights to know the identity of processors and sub-processors. California residents have the right to know categories of third parties with whom their data is shared. The sharing with corporate affiliates may involve cross-border transfers requiring adequate transfer mechanisms. (4) CONTRACT AND VENDOR IMPLICATIONS: B2B customers using Twilio's services should note that this provision applies to the website and marketing context, not necessarily to data processed as part of the communications platform. Procurement teams should request Twilio's sub-processor list and verify DPA coverage for all vendors receiving personal data. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should obtain and maintain Twilio's current sub-processor list, audit DPAs for each vendor category, and confirm that affiliate data sharing is covered by intra-group data transfer agreements where cross-border transfers are involved.
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The notice authorizes disclosure of personal information to an undefined number of third-party service providers across functional categories including advertising and analytics, as well as to corporate affiliates, which may include entities operating under different privacy standards.
This provision states that personal information collected on Twilio's website may be shared with third-party vendors in advertising, analytics, payment processing, and email delivery, as well as with Twilio's corporate subsidiaries and parent companies.
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