Twilio · Twilio Sub-Processors · View original document ↗

Telecommunications providers excluded as sub-processors

Medium 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)

This exclusion means telecommunications providers are not subject to the sub-processor obligations and protections described elsewhere in the document, which limits the data protection framework applied to them.

Consumer impact (what this means for users)

Telecommunications providers used by Twilio fall outside the sub-processor framework, meaning the protections Twilio imposes on sub-processors do not apply to them.

How other platforms handle this

Ancestry Medium

These companies are subject to contractual obligations governing privacy, data security, and confidentiality consistent with applicable laws.

Lime Medium

if you are accessing and using Lime Services under a corporate account...you acknowledge and agree that Lime may share certain of your usage information with whomever provided you with access to the Lime Services

Adobe Medium

We will disclose personal information to companies that help us run our business to detect, prevent, or otherwise address fraud, deception, illegal activity, misuse of Adobe Services and Software, and security or technical issues.

See all platforms with this clause type →

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▸ View Original Clause Language DOCUMENT RECORD
"
Please note that telecommunications providers used by Twilio are not processors of Twilio or sub-processors of our customers.

— 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-068169
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-068169
Captured: 2026-07-06 23:19:28 UTC
SHA-256: eb0c920c72df0732…
URL: https://conductatlas.com/platform/twilio/twilio-sub-processors/provision/CA-P-068169/telecommunications-providers-excluded-as-sub-processors/
Accessed: July 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Twilio's Telecommunications providers excluded as sub-processors clause do?

This exclusion means telecommunications providers are not subject to the sub-processor obligations and protections described elsewhere in the document, which limits the data protection framework applied to them.

How does this clause affect you?

Telecommunications providers used by Twilio fall outside the sub-processor framework, meaning the protections Twilio imposes on sub-processors do not apply to them.

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.