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.
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.
How other platforms handle this
We use cookies and similar tracking technologies to track the activity on our websites and services and store certain information. Tracking technologies used include beacons, tags, and scripts to collect and track information and to improve and analyze our services. You can instruct your browser to ...
American gets this information by using technologies, including cookies, web beacons, and mobile device geolocation to provide and improve our Interactive Services and advertising, including across browsers and devices (also known as cross-device linking). This technical information may be combined ...
We use cookies, web beacons, pixel tags, and other tracking technologies to collect information about your use of our Services. This information may include your IP address, browser type, operating system, referring URLs, and information about how you interact with our Services.
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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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