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
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.
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We may disclose information we collect when we believe disclosure is appropriate to comply with the law; to enforce or apply applicable terms and conditions and other agreements; to facilitate the financing, securitization, insuring, sale...
To the extent the law allows it, we will attempt to provide you with prior notice before disclosing your information in response to such a request.
Smartsheet will notify individual Users of its publicly posted Privacy Notice (available on the Site) and will process personal data collected by Smartsheet...as a data controller pursuant to the Privacy Notice.
"We notify users of legal requests whenever permitted and where Twilio determines the disclosure will not interfere with an on-going investigation. We object to any requests that are not properly issued.Excerpt from Twilio's Privacy Notice
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The clause states: “We notify users of legal requests whenever permitted and where Twilio determines the disclosure will not interfere with an on-going investigation. We object to any requests that are not properly issued.”
ConductAtlas has identified this type of provision across 267 platforms. See the full comparison.
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