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
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.
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 detailed GDPR compliance framework and enumeration of data subject rights substantially weakens transparency for European users regarding their legal protections.
View full change record →Introduces comprehensive GDPR compliance disclosures including lawful bases and data subject rights, demonstrating enhanced privacy governance for European jurisdictions.
View full change record →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.
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"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
(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.
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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.
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.
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