“If Twilio Inc. is not the Twilio party to the agreement, then Twilio Inc. is acting as a sub-processor for that Twilio party. (For example. If you are contracting with Twilio Ireland Ltd, then Twilio Inc. is acting as a sub-processor...)”
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 means Twilio Inc. can process customer personal data as a sub-processor even when it is not the direct contracting party, which affects the chain of data processing responsibility and applicable protections.
If you contract with a non-US Twilio entity, Twilio Inc. still processes your data but in the capacity of a sub-processor rather than as the primary data processor.
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"If Twilio Inc. is not the Twilio party to the agreement, then Twilio Inc. is acting as a sub-processor for that Twilio party. (For example. If you are contracting with Twilio Ireland Ltd, then Twilio Inc. is acting as a sub-processor...)Excerpt from Twilio's Sub-Processors
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This means Twilio Inc. can process customer personal data as a sub-processor even when it is not the direct contracting party, which affects the chain of data processing responsibility and applicable protections.
If you contract with a non-US Twilio entity, Twilio Inc. still processes your data but in the capacity of a sub-processor rather than as the primary data processor.
ConductAtlas has identified this type of provision across 281 platforms. See the full comparison.
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