The document lists Anthropic, Amazon Bedrock, OpenAI, and Microsoft Azure as sub-processors for AI Products, each processing personal data contained in customer-defined workflows or communications, with primary processing in the USA and, for Microsoft Azure, also in the EU.
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 engagement of multiple AI vendors as sub-processors for personal data in customer-defined workflows creates layered processing chains in which the nature and extent of personal data processed by each AI vendor depends on the content of customer-configured workflows, and may require separate evaluation under GDPR, the EU AI Act, and applicable AI governance frameworks.
Interpretive note: The document describes AI vendor processing as covering 'personal data contained in customer defined workflows' without specifying which data categories are transmitted to each vendor, creating interpretive uncertainty about the scope of AI sub-processing for individual customer configurations.
Under these terms, personal data contained in customer-defined workflows processed through Twilio's AI Products may be transmitted to and processed by Anthropic, Amazon Bedrock, OpenAI, and Microsoft Azure in the USA or EU; the specific data categories processed depend on customer workflow configurations, and customers retain responsibility for ensuring their use of AI Products is consistent with their own data protection obligations.
Cross-platform context
See how other platforms handle AI Vendor Sub-Processors for Customer-Defined Workflows and similar clauses.
Compare across platforms →"Anthropic All AI Products Personal data contained in communications sent through Flex. Vendor for AI functionality in product USA ... Amazon Bedrock All AI Products Personal data contained in customer defined workflows Vendor for AI functionality in product USA ... OpenAI All AI Products Personal data contained in customer defined workflows Vendor for AI functionality in product USA ... Microsoft Azure All AI Products Personal data contained in customer defined workflows Vendor for AI functionality in product USA, EUExcerpt from Twilio's Sub-Processors
1) REGULATORY LANDSCAPE: This provision engages GDPR Article 28 (sub-processor obligations), GDPR Chapter V (cross-border transfers for US-based AI vendors), and potentially the EU AI Act depending on the AI system risk classification applicable to …
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The engagement of multiple AI vendors as sub-processors for personal data in customer-defined workflows creates layered processing chains in which the nature and extent of personal data processed by each AI vendor depends on the content of customer-configured workflows, and may require separate evaluation under GDPR, the EU AI Act, and applicable AI governance frameworks.
Under these terms, personal data contained in customer-defined workflows processed through Twilio's AI Products may be transmitted to and processed by Anthropic, Amazon Bedrock, OpenAI, and Microsoft Azure in the USA or EU; the specific data categories processed depend on customer workflow configurations, and customers retain responsibility for ensuring their use of AI Products is consistent with their own data …
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