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
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 you use our Services, we may automatically collect your Data including IP address, operating system, browser you are using, your Account's preference settings, advertising identifiers, WiFi/WLAN Bluetooth, mobile network information...
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.
"When you download and open the Authy desktop or mobile app, we automatically collect your device type and unique device identifier.Excerpt from Twilio's Privacy Notice
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The clause states: “When you download and open the Authy desktop or mobile app, we automatically collect your device type and unique device identifier.”
ConductAtlas has identified this type of provision across 286 platforms. See the full comparison.
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