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
User data is used to train AI/ML systems, meaning personal data may feed ongoing model development beyond immediate service delivery.
Interpretive note: The excerpt includes additional independent uses (real-time automated decisions) not stated in the canonical claim; recorded in omitted_material.
The updated terms establish explicit certification under the EU-U.S., UK, and Swiss-U.S. Data Privacy Frameworks, meaning Twilio commits to comply with DPF Principles in processing personal data from those regions. The policy now states that Twilio remains liable if third-party processors acting on its behalf violate DPF Principles, unless Twilio proves it was not responsible for the violation. The revised language adds specific opt-out rights: you can opt out of disclosure of your personal data to third parties (other than service providers following Twilio's instructions) or use of your data for purposes materially different from the original collection purpose. For UK residents, the policy establishes a 30-day acknowledgment timeline for complaints and clarifies that unresolved complaints may be escalated to the UK Information Commissioner's Office. You can exercise these rights by contacting privacy@twilio.com.
View change record →A reader's data may be used by Twilio to train AI/ML models intended to detect security and fraud threats.
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StockX may use fraud protection measures, including algorithms and automated systems, to monitor for fraud. Such measures may result in cancellation of orders or listings or account suspension.
To the extent we engage in automated processing or profiling to prevent, detect, protect against or respond to fraudulent activity, we are not required to offer the right to opt-out.
We regularly monitor our AI systems for fairness, accuracy, and security.
"training AI/ML models to recognize evolving security vulnerabilities and fraud signatures; and, utilizing signals to make real-time automated security decisions, such as approving account applications or suspending fraudulent accounts...Excerpt from Twilio's Privacy Notice
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User data is used to train AI/ML systems, meaning personal data may feed ongoing model development beyond immediate service delivery.
A reader's data may be used by Twilio to train AI/ML models intended to detect security and fraud threats.
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