Twilio · Twilio Sub-Processors · View original document ↗

Transfer Impact Assessments for cross-border transfers

High severity High confidence Explicitdocumentlanguage Common · 290 of 352 platforms
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Recent governance activity Twilio recorded 2 documented changes in the last 30 days.
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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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

Transfer Impact Assessments are a recognized mechanism for evaluating the risks of sending personal data to jurisdictions with different legal protections; Twilio's completion of these assessments indicates a formal review has occurred for each qualifying transfer.

Consumer impact (what this means for users)

For every sub-processor engagement that requires cross-border transfer of personal data, Twilio has formally assessed the transfer's impact.

How other platforms handle this

Squarespace Medium

For countries without an adequacy decision, we transfer, in accordance with Article 46 of the GDPR, personal information to recipients that have entered into the approved form of transfer contract (SCCs)...

Adobe Medium

we also transfer personal information to all other countries in which Adobe or its affiliates, providers, and partners operate. We carry out these transfers in compliance with applicable laws – for example, by putting data transfer agreements in place...

Webull Medium

disclosure is required by a third-party to complete a transaction initiated by the user

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▸ View Original Clause Language DOCUMENT RECORD
"
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.

— Excerpt from Twilio's Twilio Sub-Processors

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Twilio Sub-Processors
Entity
Twilio
Document last updated
July 6, 2026
Tracking information
First tracked
July 6, 2026
Last verified
July 9, 2026
Record ID
CA-P-068165
Document ID
CA-D-00933
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
eb0c920c72df0732ba3434b4acbc87ddf3cac2ad805f3e24639ec619d81bba39
Analysis generated
July 6, 2026 23:19 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Twilio
Document: Twilio Sub-Processors
Record ID: CA-P-068165
Captured: 2026-07-06 23:19:28 UTC
SHA-256: eb0c920c72df0732…
URL: https://conductatlas.com/platform/twilio/twilio-sub-processors/provision/CA-P-068165/transfer-impact-assessments-for-cross-border-transfers/
Accessed: July 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Twilio's Transfer Impact Assessments for cross-border transfers clause do?

Transfer Impact Assessments are a recognized mechanism for evaluating the risks of sending personal data to jurisdictions with different legal protections; Twilio's completion of these assessments indicates a formal review has occurred for each qualifying transfer.

How does this clause affect you?

For every sub-processor engagement that requires cross-border transfer of personal data, Twilio has formally assessed the transfer's impact.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.

Is ConductAtlas affiliated with Twilio?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Twilio.