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 clause distinguishes between marketing communications, from which users may opt out, and transactional or account-related communications, which may continue regardless of opt-out status. This establishes separate pathways for different communication categories.
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 →Users receive marketing communications by default upon service use. The provision establishes a procedure for users to request cessation of marketing messages while preserving the company's authorization to send account and transaction-related communications.
How other platforms handle this
If you are a California resident, you have the right to: Know what personal information is being collected about you; Know whether your personal information is sold or disclosed and to whom; Say no to the sale of personal information; Access your personal information; Request deletion of your person...
Depending on where you live, you may have certain rights with respect to your personal information, such as the right to request access, correction, or deletion of your personal information, or to opt out of the sale or sharing of your personal information. If you are a California resident, you have...
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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"We may use your personal information to send you marketing communications about our products and services. You may opt out of receiving marketing communications from us at any time by clicking the unsubscribe link in any marketing email we send you, or by contacting us directly. Please note that even if you opt out of marketing communications, we may still send you non-marketing communications, such as those related to your account or transactions.— Excerpt from Twilio's Twilio Privacy Notice
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The clause distinguishes between marketing communications, from which users may opt out, and transactional or account-related communications, which may continue regardless of opt-out status. This establishes separate pathways for different communication categories.
Users receive marketing communications by default upon service use. The provision establishes a procedure for users to request cessation of marketing messages while preserving the company's authorization to send account and transaction-related communications.
ConductAtlas has identified this type of provision across 18 platforms. See the full comparison.
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