Google Tag Manager (container GTM-5JLZ694) is deployed on twilio.com and loads synchronously in the page head, enabling activation of additional tracking, analytics, and advertising tags through a centralized tag management container.
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Google Tag Manager operates as a tag management system that can load and fire additional third-party scripts and pixels beyond those disclosed individually in the page source. The container GTM-5JLZ694 controls which additional data collection tools are deployed, and its full contents are not disclosed in the privacy notice page source.
Interpretive note: The full contents of GTM container GTM-5JLZ694 are not disclosed in the page source; actual data collection scope depends on the specific tags, triggers, and variables configured within the container.
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 →This provision establishes that Google Tag Manager is active on twilio.com, meaning visitor data including page views, events, and identifiers may be collected and forwarded to Google and to any additional tags configured within the GTM container. The full scope of tags deployed through this container is not visible from the page source alone.
How other platforms handle this
src="https://trc.taboola.com/1142432/trc/3/json" ... src="https://www.googletagmanager.com/gtag/js?id=DC-15299257" ... src="https://tr.snapchat.com/config/com/af90c7f8-bd28-4988-b1ce-1711aad792f4.js" ... src="https://tr.snapchat.com/config/com/8fbe1595-8c5a-46b1-bbb2-66f3d57debde.js" ... src="https:...
With your permission, we may also receive data from your mobile device's health app (like Apple HealthKit or Google Health Connect), including hours of sleep and sleep goals. However, we do not infer any health-related characteristics from this information and only process it consistent with the pur...
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
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"(function (w, d, s, l, i) { w[l] = w[l] || []; w[l].push({ "gtm.start": new Date().getTime(), event: "gtm.js" }); ... j.src = "https://www.googletagmanager.com/gtm.js?id=" + i + dl; ... })(window, document, "script", "dataLayer", 'GTM-5JLZ694');— Excerpt from Twilio's Twilio Privacy Notice
1) REGULATORY LANDSCAPE: Google Tag Manager's deployment engages GDPR data processing obligations and ePrivacy Directive cookie requirements, as GTM can load advertising pixels and tracking scripts that may require consent. Google operates as a data processor under its GTM terms; the relevant enforcement authorities include EU national DPAs and the UK ICO. CCPA disclosure obligations apply to any California resident data forwarded to Google or tags loaded through GTM. 2) GOVERNANCE EXPOSURE: Medium. The GTM container may load additional tracking technologies not individually disclosed in the privacy notice, creating a potential gap between disclosed and actual data processing activities. Compliance exposure depends on the contents of the GTM container and whether consent conditions are applied to tag firing rules within GTM. 3) JURISDICTION FLAGS: EU and EEA visitors face the highest exposure given GDPR requirements for lawful basis and the potential for undisclosed data processors introduced through the GTM container. California residents are affected if GTM loads advertising or cross-site tracking tags that qualify as sale or sharing under CCPA. 4) CONTRACT AND VENDOR IMPLICATIONS: A Data Processing Agreement with Google for Google Tag Manager should be confirmed and documented. Privacy teams should audit the GTM container GTM-5JLZ694 to inventory all active tags, triggers, and variables and cross-reference against the categories of third parties disclosed in the privacy notice. Any advertising or cross-site tracking tags within GTM require specific consent legal basis documentation. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should implement server-side tag firing rules within GTM that respect TrustArc consent categories and prevent advertising or analytics tags from firing for users who have not consented. A periodic audit of the GTM container contents should be scheduled to maintain alignment between deployed tags and privacy notice disclosures.
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Google Tag Manager operates as a tag management system that can load and fire additional third-party scripts and pixels beyond those disclosed individually in the page source. The container GTM-5JLZ694 controls which additional data collection tools are deployed, and its full contents are not disclosed in the privacy notice page source.
This provision establishes that Google Tag Manager is active on twilio.com, meaning visitor data including page views, events, and identifiers may be collected and forwarded to Google and to any additional tags configured within the GTM container. The full scope of tags deployed through this container is not visible from the page source alone.
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