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
Identity resolution means Twilio links data about an individual across multiple devices and interactions into a unified profile, expanding the scope of personal data aggregation.
Interpretive note: The excerpt also references advertising measurement and optimization as a separate use; 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 from different devices and touchpoints may be combined by Twilio into a single unified profile through identity resolution.
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We use information about you, information that we collect from within your account, information that you provide to our customer happiness team, and information about your interactions with the Service to resolve technical issues you experience with the Service.
Where we process your personal data, personal information, or personally identifiable information in the provision of Services to you, you acknowledge that Zoom is acting on your behalf and you determine the means and purposes of the processing.
"utilizing identity resolution to create unified profiles that ensure a consistent experience across different devices and touchpoints; measuring and optimizing the performance of our advertising activities...Excerpt from Twilio's Privacy Notice
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Identity resolution means Twilio links data about an individual across multiple devices and interactions into a unified profile, expanding the scope of personal data aggregation.
A reader's data from different devices and touchpoints may be combined by Twilio into a single unified profile through identity resolution.
ConductAtlas has identified this type of provision across 273 platforms. See the full comparison.
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