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
An explicit no-sale commitment addresses a key consumer privacy concern and, depending on jurisdiction, carries legal weight under laws like the CCPA.
Interpretive note: The excerpt contains two related but independently stated propositions (general no-sale of data; specific no-sale/no-share of mobile information for marketing). The canonical claim states both because they are closely related and the second is a specific subset of the first; however they could be treated as independent. The primary proposition is the general no-sale commitment.
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 personal data and mobile information will not be sold to third parties, and mobile information will not be shared with third parties for marketing or promotional purposes.
How other platforms handle this
Your personal information may be transferred to countries other than where you live, such as, for example, to our servers in the US.
we also transfer personal information to all other countries in which Adobe or its affiliates, providers, and partners operate. We carry out these transfers in compliance with applicable laws – for example, by putting data transfer agreements in place...
By using one of these tools, you agree that Public.com may transfer that information to the applicable third party service.
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"we do not sell your data to third parties... no mobile information will be shared with or sold to any third parties for marketing or promotional purposes.— Excerpt from Twilio's Twilio Privacy Notice
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An explicit no-sale commitment addresses a key consumer privacy concern and, depending on jurisdiction, carries legal weight under laws like the CCPA.
A reader's personal data and mobile information will not be sold to third parties, and mobile information will not be shared with third parties for marketing or promotional purposes.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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