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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
Twilio's retained liability for third-party DPF violations means individuals have a direct claim against Twilio even when the violation is committed by a downstream third party, subject to Twilio's ability to prove non-responsibility.
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 →If a third party that received your data from Twilio violates DPF Principles, Twilio is liable unless it proves it was not responsible for the violation.
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"Twilio remains liable under the DPF Principles (defined below) if that third-party processes your data in a way that violates those Principles, unless we prove we were not responsible for the violation.Excerpt from Twilio's Privacy Notice
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Twilio's retained liability for third-party DPF violations means individuals have a direct claim against Twilio even when the violation is committed by a downstream third party, subject to Twilio's ability to prove non-responsibility.
If a third party that received your data from Twilio violates DPF Principles, Twilio is liable unless it proves it was not responsible for the violation.
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