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 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 →A reader's data from different devices and touchpoints may be combined by Twilio into a single unified profile through identity resolution.
How other platforms handle this
Authenticating and verifying individual identities
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"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 Twilio Privacy Notice
We read the privacy policies and terms of service of 38 AI platforms. Here is what they say about training, retention, arbitration, and liability.
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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.
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