Twilio uses cookies and tracking pixels from companies including Google, Adobe, and Segment to track your browsing behavior across the web and deliver targeted advertisements.
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 notice authorizes cross-site behavioral tracking by multiple third-party vendors, meaning your activity on Twilio's website may be used to serve you ads on other websites and applications.
Interpretive note: The complete list of third-party tracking vendors and the specific data each receives cannot be fully determined from the notice text; the page source reveals additional vendors not explicitly named in the policy text.
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 →Shifted from describing third-party tools generically to explicitly documenting actual technical implementations of Google Tag Manager and Segment with code snippets.
View full change record →Shifted from technical implementation details (specific script names, head element loading) to broader privacy policy language describing cookies, web beacons, and the purposes of cross-context behavioral advertising without technical specifics.
View full change record →This provision states that third-party vendors including Google, Adobe, and Segment may collect behavioral data through cookies and pixels on Twilio's website and use it for interest-based advertising on other sites.
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We may display advertisements on our Services and those advertisements may be targeted to your interests based on your personal information. We may share your personal information with advertising partners for interest-based advertising purposes. You may opt out of interest-based advertising by visi...
src="https://trc.taboola.com/1142432/trc/3/json" ... src="https://www.googletagmanager.com/gtag/js?id=DC-15299257" ... src="https://tr.snapchat.com/config/com/af90c7f8-bd28-4988-b1ce-1711aad792f4.js" ... src="https://tr.snapchat.com/config/com/8fbe1595-8c5a-46b1-bbb2-66f3d57debde.js" ... src="https:...
We use cookies and similar tracking technologies (collectively, "Cookies") to enhance your experience on our Platform... We may use Cookies for purposes such as recognizing you when you log in, remembering your preferences, delivering advertising to you on third-party websites, understanding how you...
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"We and our third-party partners may use cookies, web beacons, pixel tags, and other tracking technologies to collect information about your visits to our Services and other websites over time. This information may be used to serve you interest-based advertisements on our Services and on third-party sites and applications. We use third-party analytics and advertising tools, including those provided by Google, Adobe, and Segment, to help us understand how users interact with our Services and to deliver targeted advertising.— Excerpt from Twilio's Twilio Privacy Notice
(1) REGULATORY LANDSCAPE: Cross-site tracking via cookies and pixels engages GDPR and UK GDPR consent requirements for non-essential cookies, the ePrivacy Directive, and CCPA/CPRA sharing provisions for targeted advertising. The FTC has taken enforcement action regarding deceptive tracking disclosures. Under CPRA, sharing personal information with advertising partners for cross-context behavioral advertising may constitute a sale or sharing requiring an opt-out mechanism. (2) GOVERNANCE EXPOSURE: High. The deployment of multiple independent tracking vendors (Google Tag Manager, Adobe Launch, Segment, Visual Website Optimizer) on the same website creates a complex data flow that requires individual DPA coverage and consent signal propagation to each vendor. Failure to transmit consent signals to all vendors creates regulatory exposure under GDPR. (3) JURISDICTION FLAGS: EU and EEA users require opt-in consent for non-essential cookies under the ePrivacy Directive. California residents have opt-out rights for targeted advertising data sharing. Colorado, Virginia, and Connecticut residents have similar opt-out rights under their respective state privacy laws. (4) CONTRACT AND VENDOR IMPLICATIONS: Each named third-party vendor (Google, Adobe, Segment) operates under its own data processing terms. Procurement teams should verify that Twilio's contracts with these vendors restrict their use of data collected on Twilio's site to permitted purposes and prohibit secondary use for the vendor's own advertising. (5) COMPLIANCE CONSIDERATIONS: The TrustArc consent management platform visible in the page source should be audited to confirm it blocks all non-essential tracking scripts prior to consent. Compliance teams should verify that Global Privacy Control signals are honored at the cookie and pixel level for all listed vendors. Documentation of consent records should be maintained as required under GDPR.
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The notice authorizes cross-site behavioral tracking by multiple third-party vendors, meaning your activity on Twilio's website may be used to serve you ads on other websites and applications.
This provision states that third-party vendors including Google, Adobe, and Segment may collect behavioral data through cookies and pixels on Twilio's website and use it for interest-based advertising on other sites.
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