Twilio · Twilio Privacy Notice · View original document ↗

GDPR Lawful Basis and Data Subject Rights

Medium severity Medium confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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Document Record

What it is

If you are in the EU, UK, or Switzerland, Twilio processes your data under GDPR and must have a legal reason to do so; you have rights to access, correct, delete, or restrict your data and can complain to your local data protection authority.

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)

The notice asserts legitimate interests as one lawful basis for processing, which is subject to data subject objection rights under GDPR; EU and UK residents can formally object to certain types of processing, including marketing, at any time.

Interpretive note: The adequacy of the legitimate interests basis for specific processing activities, particularly behavioral advertising, depends on documented balancing tests that are not reproduced in the notice and may be subject to supervisory authority challenge.

Consumer impact (what this means for users)

This provision states that EU, UK, and Swiss residents have GDPR rights including access, erasure, restriction, and objection, exercisable by contacting privacy@twilio.com or submitting a request at https://privacy.twilio.com.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Email privacy@twilio.com specifying your request type (access, erasure, restriction, or objection) and include sufficient information to identify your account or interactions with Twilio. Alternatively, submit the request through https://privacy.twilio.com.

How other platforms handle this

Runway Medium

In addition to the above rights, your local laws (including those in the EU, UK, Japan, California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Virginia, or Utah) may afford you f...

Waze Medium

If you are located in the European Economic Area or the United Kingdom, you have certain rights under applicable data protection laws, including the right to access, correct, or delete your personal data, the right to object to or restrict processing, and the right to data portability. You may also ...

Smartsheet Medium

If you are located in the EEA or UK, you may have the following rights under applicable data protection law: the right to access your personal data; the right to rectify inaccurate personal data; the right to erasure of your personal data; the right to restrict processing of your personal data; the ...

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▸ View Original Clause Language DOCUMENT RECORD
"
If you are located in the European Economic Area, the United Kingdom, or Switzerland, we process your personal information on the following legal bases: performance of a contract, compliance with a legal obligation, your consent, and our legitimate interests (or the legitimate interests of a third party). You have the right to access, rectify, erase, restrict, or object to our processing of your personal information, and the right to data portability. You also have the right to lodge a complaint with your local supervisory authority. To exercise your rights, please contact us at privacy@twilio.com or visit https://privacy.twilio.com.

— Excerpt from Twilio's Twilio Privacy Notice

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: GDPR Article 6 requires a documented lawful basis for each processing activity. The legitimate interests basis under Article 6(1)(f) requires a balancing test and is subject to data subject objection rights under Article 21. UK GDPR imposes equivalent requirements. The relevant supervisory authorities are the EU member state DPAs and the UK ICO. (2) GOVERNANCE EXPOSURE: Medium. The use of legitimate interests as a lawful basis for marketing and behavioral tracking is subject to regulatory scrutiny, particularly following guidance from EU DPAs indicating that behavioral advertising may not satisfy the balancing test. Compliance teams should document legitimate interests assessments for each processing purpose that relies on this basis. (3) JURISDICTION FLAGS: EU and EEA residents have the strongest protections, with supervisory authority complaint rights and potential administrative fines. UK residents have equivalent rights under UK GDPR. Switzerland applies its Federal Act on Data Protection. Cross-border data transfers to the US require adequate transfer mechanisms such as Standard Contractual Clauses. (4) CONTRACT AND VENDOR IMPLICATIONS: Twilio's role as a data controller for website visitor data requires DPAs with all processors. Where Twilio engages US-based sub-processors, transfer impact assessments may be required under post-Schrems II guidance. B2B contracts should address data subject request handling obligations. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should verify that Twilio's EU-US data transfer mechanism is current, that data subject request procedures are tested and documented, and that objection requests for direct marketing processing are honored promptly. The notice should be reviewed against GDPR Article 13 requirements to confirm all required disclosures are present.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has jurisdiction over unfair or deceptive practices affecting US-based consumers; for EU and UK data subjects, complaints should be directed to the relevant national supervisory authority.
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
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-010913
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-010913
Captured: 2026-05-10 09:42:01 UTC
SHA-256: 1e5bbf4d983ee808…
URL: https://conductatlas.com/platform/twilio/twilio-privacy-notice/gdpr-lawful-basis-and-data-subject-rights/
Accessed: May 13, 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 GDPR Lawful Basis and Data Subject Rights clause do?

The notice asserts legitimate interests as one lawful basis for processing, which is subject to data subject objection rights under GDPR; EU and UK residents can formally object to certain types of processing, including marketing, at any time.

How does this clause affect you?

This provision states that EU, UK, and Swiss residents have GDPR rights including access, erasure, restriction, and objection, exercisable by contacting privacy@twilio.com or submitting a request at https://privacy.twilio.com.

Is ConductAtlas affiliated with Twilio?

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