49 Total
6 High severity
14 Medium severity
29 Low severity

Key Facts

Will each sub-processor process personal data for the duration that the customer uses the applicable service?
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?
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?
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 sub-processing of personal data is protected to the standards required by applicable data protection laws.
Must Twilio's sub-processors implement appropriate technical and organizational measures?
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?
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?
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.
Where can data be located for AWS's hosting services and storage for Twilio's CDP Segment product?
AWS serves as an infrastructure provider for hosting services and storage for Twilio's CDP Segment product, with data located in the USA or EU (Dublin) as selected by customers.
Where is data located for AWS's hosting services and storage for Twilio's services?
AWS serves as an infrastructure provider for hosting services and storage for Twilio's services, with data located in the USA.
Does Twilio offer customers the ability to subscribe to notifications of sub-processor changes?
Twilio offers customers the ability to subscribe to notifications of sub-processor changes to receive updates.
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Summary

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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Which mapped governance frameworks each document engages, tied to the specific provisions that engage them.

Featured, High severity
Featured, Medium severity

Complete Provision Index

Every distinct legal provision identified in this document. Featured provisions appear above with analysis.

49 provisions
12 featured
7 clause types
6 high severity
Disclosure and Transparency Requirements 1
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Mapped Governance Frameworks

CCPA/CPRA
California, USA
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Connecticut Data Privacy Act Amendments
US-CT
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CAN-SPAM
United States Federal
View official text ↗
FTC Act Section 5
United States Federal
View official text ↗
GDPR
European Union
View official text ↗
Indiana Consumer Data Protection Act
US-IN
View official text ↗
Kentucky Consumer Data Protection Act
US-KY
View official text ↗
Universal Opt-Out Mechanism Expansion 2026
US
View official text ↗
Archival ProvenanceSource & Archival Record
Last Captured July 6, 2026 22:44 UTC
Capture Method Automated scheduled archival capture
Document ID CA-D-000933
Version ID CA-V-004531
SHA-256 eb0c920c72df0732ba3434b4acbc87ddf3cac2ad805f3e24639ec619d81bba39
✓ Snapshot stored ✓ Text extracted ✓ Change verified ✓ Hash verified

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