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
This right provides a human oversight mechanism for automated decisions that directly affect account access, which is a meaningful procedural protection.
Interpretive note: The word 'currently' indicates the scope of covered automated decisions may change; this qualifier is preserved in the canonical claim.
The updated Privacy Notice now explicitly discloses that Twilio is subject to FTC investigatory and enforcement powers, clarifying the regulatory oversight applying to the company. The policy also establishes an opt-out right allowing users to prevent disclosure of their data to third parties (other than service providers) or use of data for purposes materially different from the original collection purpose. You can exercise this opt-out by contacting Twilio through the mechanisms described in the privacy notice.
View change record →The updated notice establishes more explicit disclosures of Twilio's Data Privacy Framework certifications and specifies the legal hierarchy governing data processing. Under the revised policy, the DPF Principles now take precedence if they conflict with other terms in the privacy notice. The updated language also clarifies your right to opt out of third-party disclosures (except to service providers acting on Twilio's behalf) and to opt out of uses that materially differ from original collection purposes. You can exercise these choices by contacting privacy@twilio.com.
View change record →The updated Privacy Notice now provides more detailed explanations of how Twilio collects and processes personal data, including explicit definitions of what constitutes personal data and descriptions of direct relationships (when you create an account or opt into communications) versus indirect relationships (when you are a customer of one of Twilio's customers). The revised language establishes that Twilio acts as a data controller and determines how and why personal data is processed, subject to applicable law. The notice states it aims to be transparent about data use and to explain how you can exercise your rights, but the change itself does not modify what data is collected, how it is used, or what rights or controls are available to you.
View change record →A reader may object to and request human review of any Twilio decision made solely by automated processing, including current uses such as account approvals and suspensions for abusive or fraudulent activity.
How other platforms handle this
Request a review of decisions made solely based on automated processing of personal data.
Mailchimp uses a combination of automated and human detection review processes to ensure that Members are complying with our Standard Terms of Use and this Acceptable Use Policy.
Object to an automated decision-making (including profiling) in certain circumstances.
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"Object to and request a human review of decisions Twilio makes about you based solely on automated processing, which currently includes account approvals and account suspensions related to abusive or fraudulent activity...— Excerpt from Twilio's Twilio Privacy Notice
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This right provides a human oversight mechanism for automated decisions that directly affect account access, which is a meaningful procedural protection.
A reader may object to and request human review of any Twilio decision made solely by automated processing, including current uses such as account approvals and suspensions for abusive or fraudulent activity.
ConductAtlas has identified this type of provision across 215 platforms. See the full comparison.
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