The document states that each sub-processor processes personal data for the period during which the customer uses the applicable Twilio service, plus any retention periods specified in the customer's agreement with Twilio.
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
This provision establishes the temporal scope of sub-processor personal data processing as coextensive with the customer's service usage and contractual retention terms, meaning that the duration of third-party access to personal data depends on the specific retention provisions in each customer's individual agreement with Twilio.
Under these terms, personal data is processed by sub-processors for as long as the customer uses the applicable service and for any additional retention period specified in their Twilio agreement; customers should review their specific agreement with Twilio to understand the retention periods that govern sub-processor access to their data.
Cross-platform context
See how other platforms handle Processing Duration Tied to Customer Service Use and Retention Periods and similar clauses.
Compare across platforms →"Duration of processing: 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.Excerpt from Twilio's Sub-Processors
1) REGULATORY LANDSCAPE: This provision engages GDPR Article 5(1)(e) (storage limitation principle), which requires that personal data be kept for no longer than necessary for the purposes for which it is processed.
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This provision establishes the temporal scope of sub-processor personal data processing as coextensive with the customer's service usage and contractual retention terms, meaning that the duration of third-party access to personal data depends on the specific retention provisions in each customer's individual agreement with Twilio.
Under these terms, personal data is processed by sub-processors for as long as the customer uses the applicable service and for any additional retention period specified in their Twilio agreement; customers should review their specific agreement with Twilio to understand the retention periods that govern sub-processor access to their data.
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