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
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.
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 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.
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"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
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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.
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.
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