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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These rights are not absolute and they may be limited in some situations. For example, where we can demonstrate that we have a legal requirement to process your data...
We do not control these platforms and are not responsible for their content, privacy practices, or use of your information.
Note that fulfilment of the request may not ensure complete or comprehensive removal (e.g., if the content or information has been reposted by another user).
"In certain cases, these rights may be limited or an exemption may be applicable, such as where Twilio can demonstrate that it has a legal requirement or legitimate interest to process your data.Excerpt from Twilio's Privacy Notice
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The clause states: “In certain cases, these rights may be limited or an exemption may be applicable, such as where Twilio can demonstrate that it has a legal requirement or legitimate interest to process your data.”
ConductAtlas has identified this type of provision across 281 platforms. See the full comparison.
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