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

Cookies and Targeted Advertising

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Document Record

What it is

The notice discloses that Twilio uses cookies, pixels, and web beacons for advertising purposes and acknowledges that under some U.S. state laws this activity constitutes sharing or targeted advertising. Users may opt out of advertising cookies at any time via the Cookie Preferences tool or browser settings.

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)

This provision acknowledges that cookie-based advertising activities may constitute sharing or targeted advertising under U.S. state privacy laws including CCPA and CPRA, and provides opt-out mechanisms via the Cookie Preferences tool, browser settings, Global Privacy Control, and ad industry opt-out tools. The notice also discloses that required cookies cannot be opted out of.

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 Stable

0
Changes
5
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under this clause, advertising cookies and web beacons are used to deliver targeted advertising, and the notice acknowledges this may constitute sharing under applicable U.S. state laws. Users may opt out of advertising and functional cookies through the Cookie Preferences icon in the Twilio website footer, browser settings, or the Global Privacy Control.

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.
  • Opt Out of Arbitration
    Click the 'Cookie Preferences' icon in the footer of any Twilio website to access the cookie management tool and opt out of advertising and functional cookies. Choices are browser and device specific and must be reset if cookies are cleared.

Cross-platform context

See how other platforms handle Cookies and Targeted Advertising and similar clauses.

Compare across platforms →
▸ View Original Clause Language DOCUMENT RECORD
"
We use cookies, pixels, web beacons, and similar tools to secure our website, analyze performance, and deliver relevant ads. These tools help us recognize your device to make your experience more secure, efficient and tailored to your interests. Under some U.S. state laws, this is considered 'sharing' or 'targeted advertising.' [...] Advertising: Used to show you content and ads that are relevant to your interests. You can opt-out of advertising cookies at any time.

Excerpt from Twilio's Privacy Notice

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: CCPA and CPRA classify cookie-based advertising data sharing as a sale or sharing of personal information requiring an opt-out mechanism.

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 →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Provision details

Document information
Document
Twilio Privacy Notice
Entity
Twilio
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-015387
Document ID
CA-D-00252
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
e37e6bb1abdf882cdf3d4b9a7ddcbcb1b521744fd46b9d3d4d5f19d611714b48
Analysis generated
July 9, 2026 07:52 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Twilio
Document: Twilio Privacy Notice
Record ID: CA-P-015387
Captured: 2026-07-09 07:52:51 UTC
SHA-256: e37e6bb1abdf882c…
URL: https://conductatlas.com/platform/twilio/twilio-privacy-notice/provision/CA-P-015387/cookies-and-targeted-advertising/
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 Cookies and Targeted Advertising clause do?

This provision acknowledges that cookie-based advertising activities may constitute sharing or targeted advertising under U.S. state privacy laws including CCPA and CPRA, and provides opt-out mechanisms via the Cookie Preferences tool, browser settings, Global Privacy Control, and ad industry opt-out tools. The notice also discloses that required cookies cannot be opted out of.

How does this clause affect you?

Under this clause, advertising cookies and web beacons are used to deliver targeted advertising, and the notice acknowledges this may constitute sharing under applicable U.S. state laws. Users may opt out of advertising and functional cookies through the Cookie Preferences icon in the Twilio website footer, browser settings, or the Global Privacy Control.

Is ConductAtlas affiliated with Twilio?

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