Provision record
Twilio · Twilio Privacy Notice · View original document ↗

Collection of Personal Identifiers and Behavioral Data

Medium severity Medium confidence Explicit document language Common · 289 of 352 platforms
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Document Record

What it is

Twilio collects names, email addresses, phone numbers, company names, and browsing behavior including pages visited and links clicked whenever you use its website.

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 authorizes collection of both directly provided contact information and passively gathered behavioral data, which together can build a detailed profile of a visitor's interests and identity.

Interpretive note: The exact scope of passive data collection and the identity of all sub-processors receiving this data cannot be fully determined from the notice text alone.

Recent Activity

This document changed recently

Medium May 22, 2026

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 →
Medium May 19, 2026

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 →
Medium Mar 19, 2026

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 →

Clause Stability Mostly Stable

2
Changes
5
Months Monitored
May 12, 2026
First Seen
May 20, 2026
Last Seen
This clause type exists across 5149 other provisions on other platforms.
This clause has changed 2 times in 5 months of monitoring, averaging roughly once every 2 months.

Change history

removed May 22, 2026

Removal of explicit description of directly collected personal identifiers reduces transparency about what data Twilio collects from users during account creation and interactions.

View full change record →
added May 19, 2026

Formally discloses the categories of personal data collected (directly provided and automatically collected), which is a standard and legally required element of privacy notices.

View full change record →

Consumer impact (what this means for users)

This provision states that Twilio collects identifiers (name, email, phone, company) and behavioral data (IP address, pages viewed, links clicked) from website visitors, including those who do not create accounts.

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
    Visit https://privacy.twilio.com, select the data deletion or access request option, provide your contact details, and submit the form. Twilio will process the request in accordance with applicable law.

How other platforms handle this

Tinder Medium

If you choose to reveal any personal information about yourself to other users, you do so at your own risk. We strongly encourage you to use caution in disclosing any personal information online.

Square Medium

to request that your data be transferred to a third party (data portability)

Google Cloud Medium

Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
We collect information you provide directly to us, such as when you fill out a form, create an account, make a purchase, request customer support, or otherwise communicate with us. The types of information we may collect include your name, email address, postal address, phone number, company name, job title, and any other information you choose to provide. We also automatically collect certain information about your device and how you interact with our Services, including your IP address, browser type, operating system, referring URLs, pages viewed, links clicked, and the date and time of your visit.

Excerpt from Twilio's Privacy Notice

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: Collection of IP addresses, device identifiers, and browsing activity constitutes personal data processing under GDPR and UK GDPR, requiring a valid lawful basis.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    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-010910
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-010910
Captured: 2026-05-10 09:42:01 UTC
SHA-256: 1e5bbf4d983ee808…
URL: https://conductatlas.com/platform/twilio/twilio-privacy-notice/provision/CA-P-010910/collection-of-personal-identifiers-and-behavioral-data/
Accessed: Sept. 8, 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 Collection of Personal Identifiers and Behavioral Data clause do?

The notice authorizes collection of both directly provided contact information and passively gathered behavioral data, which together can build a detailed profile of a visitor's interests and identity.

How does this clause affect you?

This provision states that Twilio collects identifiers (name, email, phone, company) and behavioral data (IP address, pages viewed, links clicked) from website visitors, including those who do not create accounts.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 289 platforms. See the full comparison.

Is ConductAtlas affiliated with Twilio?

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