Provision record
Twilio · Twilio Privacy Notice · View original document ↗

Twilio liable for third-party DPF violations

High confidence Common · 225 of 343 platforms
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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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

Generated by a model from the captured document; not read by a person

Twilio's retained liability for third-party DPF violations means individuals have a direct claim against Twilio even when the violation is committed by a downstream third party, subject to Twilio's ability to prove non-responsibility.

Recent Activity

This document changed recently

Medium May 19, 2026

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 →

Consumer impact (what this means for users)

Generated by a model from the captured document; not read by a person

If a third party that received your data from Twilio violates DPF Principles, Twilio is liable unless it proves it was not responsible for the violation.

How other platforms handle this

Ramp

Such indemnification obligations shall not apply to any damages to the extent they arise from or relate to (i) combination of the Subscription Services with information, services, materials, or products not supplied by Ramp; (ii) any modification of the Subscription Services...

Heap

Contentsquare will not be responsible for: (i) any Claim arising out of or in connection with Customer's or its User's combination of CS Service with goods or services provided by third parties, including any Third-Party Services

Credit Karma

The Credit Karma Parties reserve the right, at their own expense, to assume the exclusive defense and control of any matter subject to indemnification by you

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
Please note that if we share your personal data with a third-party acting on our behalf, Twilio remains liable under the DPF Principles (defined below) if that third-party processes your data in a way that violates those Principles, unless we prove we were not responsible for the violation.

Excerpt from Twilio's Privacy Notice

Provision details

Document information
Document
Twilio Privacy Notice
Entity
Twilio
Date stated by the document
April 9, 2026
As printed in Twilio’s text (version CA-V-007518), not a ConductAtlas date.
Tracking information
First captured by ConductAtlas
March 19, 2026
Text quoted from version
CA-V-004441, captured July 3, 2026
Record ID
CA-P-033356
Document ID
CA-D-000252
Evidence Provenance
Source URL
Wayback Machine
Extracted-text SHA-256 (version CA-V-004441)
9419eb7dec5f3301f5da5b1a8bbe0860ef439551d3cacb024c22402db293b1fe
Analysis generated
July 9, 2026 07:52 UTC
Methodology
Evidence
✓ Excerpt found in version CA-V-004441, captured July 3, 2026 (checked Oct. 6, 2026)
Not the current version. The document's current version is CA-V-007518, captured Oct. 14, 2026; this clause has not been re-checked against it.
Citation Record
Entity: Twilio
Document: Twilio Privacy Notice
Record ID: CA-P-033356
Version: CA-V-004441
Captured: 2026-07-03 00:33:34 UTC
SHA-256: 9419eb7dec5f3301…
URL: https://conductatlas.com/platform/twilio/twilio-privacy-notice/provision/CA-P-033356/twilio-liable-for-third-party-dpf-violations/
Accessed: Oct. 24, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Categories

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Frequently Asked Questions

What does Twilio's Twilio liable for third-party DPF violations clause do?

Twilio's retained liability for third-party DPF violations means individuals have a direct claim against Twilio even when the violation is committed by a downstream third party, subject to Twilio's ability to prove non-responsibility.

How does this clause affect you?

If a third party that received your data from Twilio violates DPF Principles, Twilio is liable unless it proves it was not responsible for the violation.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 225 platforms. See the full comparison.

Is ConductAtlas affiliated with Twilio?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Twilio.