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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Zoom may obtain and aggregate technical and other data about your and your End Users use of the Services and Software on a de-identified or anonymized basis...and Zoom may use the Aggregated Anonymous Data in accordance with applicable Law...
We process your data for necessary purposes as described in the main Policy, and for secondary purposes. We use both human and automated means to process your data.
Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities
"We may derive aggregated, anonymized, or de-identified data from your personal data. Because this data does not identify you, it is not considered personal data under the law. We may use this data for any purpose.Excerpt from Twilio's Privacy Notice
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The clause states: “We may derive aggregated, anonymized, or de-identified data from your personal data. Because this data does not identify you, it is not considered personal data under the law. We may use this data for any purpose.”
ConductAtlas has identified this type of provision across 273 platforms. See the full comparison.
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