9 Total

Key Facts · in the document’s own words

Will each sub-processor process personal data for the duration that the customer uses the applicable service?
“For each sub-processor below, processing of personal data will be for the duration that the customer uses and continues to use the applicable service(s), and for the retention periods as set out in customer's agreement with Twilio.”
Version CA-V-006433, captured Sept. 5, 2026 · live source ↗
Our reading, not the document’s words
Twilio states that each sub-processor will process personal data for the duration that the customer uses the applicable service(s) and for the retention periods set out in the customer's agreement with Twilio.
Where will data relating to a customer's account and use of Twilio Services other than regional data be processed?
“At this time, all other data relating to your account and use of the Twilio Services will continue to be processed in the United States to allow Twilio to continue to provide and improve our Services to you.”
Version CA-V-006433, captured Sept. 5, 2026 · live source ↗
Our reading, not the document’s words
Twilio states that all data relating to a customer's account and use of Twilio Services other than regional data will continue to be processed in the United States.
Where does Twilio store and process Customer Content when the customer uses Regional Twilio for supported products?
“If using Regional Twilio for supported products, Customer Content is stored and processed in the region selected (Ireland or Australia). Exceptions will occur as necessary to investigate issues of fraud and abuse.”
Version CA-V-006433, captured Sept. 5, 2026 · live source ↗
Our reading, not the document’s words
Twilio stores and processes Customer Content in the customer-selected region (Ireland or Australia) when the customer uses Regional Twilio for supported products, with exceptions occurring as necessary to investigate issues of fraud and abuse.
What obligations does Twilio impose on its sub-processors?
“Twilio imposes obligations on its sub-processors to implement appropriate technical and organizational measures ensuring that the sub-processing of personal data is protected to the standards required by applicable data protection laws.”
Version CA-V-006433, captured Sept. 5, 2026 · live source ↗
Our reading, not the document’s words
Twilio imposes obligations on its sub-processors to implement appropriate technical and organizational measures ensuring that sub-processing of personal data is protected to the standards required by applicable data protection laws.
Has Twilio performed Transfer Impact Assessments for cross-border transfers of personal data where engaging a sub-processor requires such a transfer?
“Where the engagement of a sub-processor requires the cross-border transfer of personal data, Twilio has performed Transfer Impact Assessments for such data transfer.”
Version CA-V-006433, captured Sept. 5, 2026 · live source ↗
Our reading, not the document’s words
Twilio has performed Transfer Impact Assessments for cross-border transfers of personal data where engaging a sub-processor requires such a transfer.
When does Twilio Inc. act as a sub-processor for the Twilio contracting entity?
“If Twilio Inc. is not the Twilio party to the agreement, then Twilio Inc. is acting as a sub-processor for that Twilio party. (For example. If you are contracting with Twilio Ireland Ltd, then Twilio Inc. is acting as a sub-processor...)”
Version CA-V-006433, captured Sept. 5, 2026 · live source ↗
Our reading, not the document’s words
Twilio Inc. acts as a sub-processor for the Twilio contracting entity when Twilio Inc. is not itself the party to the customer's agreement.
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Summary
Generated by a model from the captured document; not read by a person

This document lists the third-party companies Twilio uses to process customer data and explains the rules those companies must follow. Your data is processed for as long as you use Twilio services and for whatever retention period your agreement specifies—it is not automatically deleted when you stop using a service unless your agreement says so. Unless you have set up a regional data arrangement selecting Ireland or Australia, your account and usage data is processed in the United States.

Analysis

This document establishes Twilio's sub-processor framework, identifying the third parties Twilio engages to process customer personal data and the obligations imposed on them. Sub-processors are contractually required to implement appropriate technical and organizational measures meeting applicable data protection law standards. Personal data retention by sub-processors runs for the duration of active service use and for any retention periods defined in the customer's agreement with Twilio. Cross-border transfers involving sub-processors have been evaluated through Transfer Impact Assessments, and data residency is governed by customer-selected regions (Ireland or Australia) for Regional Twilio supported products, with a default of United States processing for all other account and service usage data. Telecommunications providers used by Twilio are explicitly excluded from the sub-processor classification and its attendant obligations.

What this means for you

As an individual user, your personal data is held by Twilio's sub-processors for the full period you use the applicable service and any additional period your agreement specifies. Key infrastructure, including AWS, processes data in the USA, and third-party sub-processors such as OpenAI and Lakera also operate in the USA within Twilio's automated and AI-powered workflows. Telecommunications providers are not covered by the sub-processor obligations described in this document. One concrete action available to you: you can subscribe to Twilio's sub-processor change notifications to receive updates whenever the list of sub-processors is modified.

Institutional Analysis
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Featured provisions
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Complete Provision Index

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9 provisions
8 featured
4 clause types
Disclosure and Transparency Requirements 1
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Archival ProvenanceSource & Archival Record
This version captured September 5, 2026 00:40 UTC
Last successful capture October 15, 2026 00:36 UTC
Capture Method Automated scheduled archival capture
Document ID CA-D-000933
Version ID CA-V-006433
SHA-256 (extracted text, extractor v5) 7f04d0ea5ecad67f402e2a169ac54492b72618ac2d266a27b2434a7f99045507
✓ Snapshot stored Archived-bytes anchor not yet recorded

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