The notice states that Twilio may derive aggregated, anonymized, or de-identified data from personal data and use it for any purpose, and may share it with third parties bound by legal or technical obligations to keep it de-identified.
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
This provision authorizes unrestricted use of data derived from personal data once it has been de-identified or aggregated, subject to a commitment not to re-identify and to share only with parties bound to maintain de-identification. The adequacy of de-identification standards varies across jurisdictions and regulatory frameworks, and the notice does not specify which technical standard is applied.
Interpretive note: The notice does not specify the technical de-identification standard applied, and the adequacy of de-identification under GDPR, CCPA, and CPRA depends on specific technical and legal thresholds that vary by jurisdiction.
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 →Under this clause, data derived from personal data through de-identification or aggregation may be used by Twilio for any purpose and shared with third parties who are contractually or technically restricted from re-identifying it. The notice does not specify the technical standard used to achieve de-identification.
Cross-platform context
See how other platforms handle De-Identified and Aggregated Data Use and similar clauses.
Compare across platforms →"We may derive aggregated, anonymized, or de-identified data from your personal data. Because this data does not identify you, it is not considered personal data under the law. We may use this data for any purpose. We commit to never attempting to re-identify this information, and we will only share it with third parties who are legally or technically bound to keep it de-identified.Excerpt from Twilio's Privacy Notice
1) REGULATORY LANDSCAPE: The de-identification standard sufficient to remove data from the scope of privacy regulation varies across frameworks.
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This provision authorizes unrestricted use of data derived from personal data once it has been de-identified or aggregated, subject to a commitment not to re-identify and to share only with parties bound to maintain de-identification. The adequacy of de-identification standards varies across jurisdictions and regulatory frameworks, and the notice does not specify which technical standard is applied.
Under this clause, data derived from personal data through de-identification or aggregation may be used by Twilio for any purpose and shared with third parties who are contractually or technically restricted from re-identifying it. The notice does not specify the technical standard used to achieve de-identification.
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