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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Data obtained from you in connection with this text messaging service may include your mobile phone number, your carrier's name, and the date, time and content of your messages and other information you provide...
We collect payment and billing information when you register for certain paid Services. We use external secure payment processing services to collect and process payment information, such as payment card details.
When Connected Vehicle Information is transmitted from the vehicle, it is generally associated with a VIN or other unique identifiers, and the VIN or other unique identifiers can be linked to you.
"To create an Authy account, we require a phone number... This phone number serves as your "primary device and the unique identifier for your Authy account.Excerpt from Twilio's Privacy Notice
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The clause states: “To create an Authy account, we require a phone number... This phone number serves as your "primary device and the unique identifier for your Authy account.”
ConductAtlas has identified this type of provision across 286 platforms. See the full comparison.
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