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 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.
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 →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.
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"By clicking 'Next', you are indicating that you have read and agree to the TERMS OF USE AND PRIVACY POLICY"
We automatically collect certain information from your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Service, we collect information about the individual web pages or products th...
We may amend these Terms at any time, by providing reasonable advance notice of any change to the Terms that, in our sole determination, materially adversely affect your rights or your use of the Service. By continuing to use our Platform after the notice or 30 days after notification (whichever dat...
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"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
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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.
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.
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