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
Automated decisions can directly affect account access, and the notification and objection requirement is the key procedural protection for affected individuals.
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 →If Twilio makes an automated security decision about a reader's account, Twilio is required to notify the reader and give them an opportunity to object.
How other platforms handle this
Opt-out of profiling/automated decision making. You can opt-out of automated processing or profiling performed on personal information to evaluate, analyze, or predict personal aspects...
You may contact Uber here with questions about Uber's use of your data for purposes of automated decision making, including regarding the factors considered... to request review of any such decisions by Uber personnel.
We process your information and, in some cases, apply automated processing and manual (that is, human) review to maintain the security and integrity of our Services.
"utilizing signals to make real-time automated security decisions, such as approving account applications or suspending fraudulent accounts (of which you will be notified and given an opportunity to object).Excerpt from Twilio's Privacy Notice
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Automated decisions can directly affect account access, and the notification and objection requirement is the key procedural protection for affected individuals.
If Twilio makes an automated security decision about a reader's account, Twilio is required to notify the reader and give them an opportunity to object.
ConductAtlas has identified this type of provision across 210 platforms. See the full comparison.
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