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
This provision operationalizes Twilio's compliance framework for EEA and UK residents by defining available legal bases for data processing and establishing procedural rights that data subjects may exercise. The specification of multiple legal bases indicates that different processing activities operate under different authorization mechanisms.
Interpretive note: The specific lawful basis asserted for each processing activity is not individually enumerated in the notice, creating some ambiguity about which basis applies to which use case, which affects how objection rights and consent withdrawal rights apply in practice.
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 →EEA and UK users may exercise statutory rights to access, correct, delete, restrict, or object to their personal information, and to obtain portable copies of their data. The processing of personal information occurs under one of four specified legal bases, which determines the conditions under which each processing activity is authorized.
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"If you are located in the European Economic Area or the United Kingdom, you have certain rights regarding your personal information under applicable data protection law, including the right to access, correct, or delete your personal information, the right to restrict or object to our processing of your personal information, and the right to data portability. We process your personal information on the basis of legitimate interests, performance of a contract, compliance with a legal obligation, or with your consent, depending on the specific processing activity.— Excerpt from Twilio's Twilio Privacy Notice
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This provision operationalizes Twilio's compliance framework for EEA and UK residents by defining available legal bases for data processing and establishing procedural rights that data subjects may exercise. The specification of multiple legal bases indicates that different processing activities operate under different authorization mechanisms.
EEA and UK users may exercise statutory rights to access, correct, delete, restrict, or object to their personal information, and to obtain portable copies of their data. The processing of personal information occurs under one of four specified legal bases, which determines the conditions under which each processing activity is authorized.
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