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 automatically collect data about your approximate location, such as country, state or city, based on your SIM card or IP address.
We receive information about you when you or your administrator integrate or link a third-party service with our Services. For example, if you create an account or log into the Services using your Google credentials, we receive your name and email address...
Depending on your device and app settings, we also collect location data from your devices. If your mobile device is connected to your vehicle via Bluetooth or tether, vehicle location may be derived from mobile...
"If you have location services enabled, we collect your location based on your IP address. We use this information for anti-fraud purposes, to detect suspicious activity...Excerpt from Twilio's Privacy Notice
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The clause states: “If you have location services enabled, we collect your location based on your IP address. We use this information for anti-fraud purposes, to detect suspicious activity...”
ConductAtlas has identified this type of provision across 286 platforms. See the full comparison.
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