Twilio uses Visual Website Optimizer (VWO) to run A/B tests and personalization experiments on its website, which tracks your behavior to determine which version of a page you see and may profile your browsing patterns.
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 provision establishes the operational framework for behavioral testing on Twilio's digital properties, enabling the collection and analysis of user interaction data across different website variations. The consent state management mechanism indicates the testing framework adjusts its operation based on whether users have provided consent.
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 →Removal of specific vendor implementation details (account ID, technical settings) reduces information that could facilitate targeting or exploitation, aligning with privacy-by-design principles.
View full change record →VWO's body-hiding initialization technique (opacity:0) means your page experience is briefly suppressed while the profiling script loads, and your session data is used to segment you into A/B test groups, which constitutes behavioral profiling under GDPR.
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"var account_id=1176295, version=2.2, settings_tolerance=2000, hide_element='body', hide_element_style = 'opacity:0 !important;filter:alpha(opacity=0) !important;background:none !important'; ... w._vwo_code=code;code.init(); ... VWO.init(allowed ? 1 : 3); window.VWO.consentState = state;— Excerpt from Twilio's Twilio Privacy Notice
REGULATORY FRAMEWORK: GDPR Art. 22 (automated decision-making and profiling), Art. 6(1)(a) (consent for profiling), Art. 13 (transparency about profiling activities), EU ePrivacy Directive Art. 5(3), and UK PECR Reg. 6. The VWO consent wrapper (VWO.init with consentState) suggests an attempt at consent-gated initialization, but the primary VWO code loads unconditionally before consent check.
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The provision establishes the operational framework for behavioral testing on Twilio's digital properties, enabling the collection and analysis of user interaction data across different website variations. The consent state management mechanism indicates the testing framework adjusts its operation based on whether users have provided consent.
VWO's body-hiding initialization technique (opacity:0) means your page experience is briefly suppressed while the profiling script loads, and your session data is used to segment you into A/B test groups, which constitutes behavioral profiling under GDPR.
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