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.
View change record →How other platforms handle this
With respect to the personal data received or transferred pursuant to the DPF, Patreon, Inc. is subject to the regulatory enforcement powers of the US Federal Trade Commission.
To the fullest extent permitted by applicable laws and regulations, the validity, interpretation, modification, supplement, termination, execution of this Agreement and any dispute or claim resulting from or in connection with this Agreement will be governed by and construed in accordance with the l...
Except as provided in the dispute resolution section above, all claims arising out of or relating to these Terms will be brought exclusively in the federal or state courts of San Francisco, California.
"Twilio Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).Excerpt from Twilio's Privacy Notice
Get the weekly coverage letter
Companies change their terms without announcing it. We capture governance documents, compare each new version with the last, and publish what changed, with the source text behind it. One email a week on what we found and what we could not reach.
The clause states: “Twilio Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).”
ConductAtlas has identified this type of provision across 264 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Twilio.