Twilio · Twilio Privacy Notice · View original document ↗

Exclusion of Customer API Data from Notice Scope

Medium severity Unique · 0 of 325 platforms
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Recent governance activity Twilio recorded 5 documented changes in the last 30 days.
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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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision clarifies the scope and applicability of the Privacy Notice by carving out customer-directed data processing from its coverage. It establishes that the Notice's protections and disclosures apply to controller-side processing only, while processor-side handling is governed separately by customer instructions and addendum terms.

Recent Activity

This document changed recently

Medium May 19, 2026

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 →
Medium Mar 19, 2026

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 →

Consumer impact (what this means for users)

For data processed under customer direction (through Data Protection Addendum or Service configurations), users' data handling is governed by customer instructions and processor agreements rather than by the representations in this Privacy Notice. The terms define which data handling practices fall outside the Notice's stated scope.

How other platforms handle this

Best Buy Medium

We collect information about you in a variety of ways depending on how you interact with us and our products and services. This includes information you provide directly, information we collect automatically when you use our services, and information we receive from third parties. We may collect ide...

Duolingo Medium

We collect information you provide directly to us when you use our services, such as when you create an account, make a purchase, or contact us for support. The types of information we may collect include your name, email address, password, age or date of birth, and any other information you choose ...

Datadog Medium

We collect information you provide directly to us, such as when you create an account, fill out a form, make a purchase, communicate with us via third-party social media sites, request customer support or otherwise communicate with us. The types of information we may collect include your name, email...

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▸ View Original Clause Language DOCUMENT RECORD
"
Twilio As Data Processor: We process personal data as directed by our customers - whether through specific instructions, our Data Protection Addendum, or their chosen Service configurations. In these cases, we must use and protect personal data in line with those directions. This Privacy Notice ("Notice") applies when Twilio acts as a Data Controller.

— Excerpt from Twilio's Twilio Privacy Notice

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Twilio Privacy Notice
Entity
Twilio
Document last updated
May 5, 2026
Tracking information
First tracked
May 10, 2026
Last verified
May 12, 2026
Record ID
CA-P-001327
Document ID
CA-D-00252
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
1e5bbf4d983ee8081c4ac6d66bb2964eb214225dcf4ded575c19b5ff3fe5f3d5
Analysis generated
May 10, 2026 09:42 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Twilio
Document: Twilio Privacy Notice
Record ID: CA-P-001327
Captured: 2026-05-10 09:42:01 UTC
SHA-256: 1e5bbf4d983ee808…
URL: https://conductatlas.com/platform/twilio/twilio-privacy-notice/exclusion-of-customer-api-data-from-notice-scope/
Accessed: May 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Twilio's Exclusion of Customer API Data from Notice Scope clause do?

This provision clarifies the scope and applicability of the Privacy Notice by carving out customer-directed data processing from its coverage. It establishes that the Notice's protections and disclosures apply to controller-side processing only, while processor-side handling is governed separately by customer instructions and addendum terms.

How does this clause affect you?

For data processed under customer direction (through Data Protection Addendum or Service configurations), users' data handling is governed by customer instructions and processor agreements rather than by the representations in this Privacy Notice. The terms define which data handling practices fall outside the Notice's stated scope.

Is ConductAtlas affiliated with Twilio?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Twilio.