The document states that Twilio offers customers the option to subscribe to notifications when changes are made to the sub-processor list, allowing customers to receive updates when sub-processors are added, removed, or modified.
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
GDPR Article 28(2) requires that processors inform controllers of intended changes to sub-processors and provide the controller with an opportunity to object; this provision establishes the mechanism through which Twilio operationalizes that notification obligation for its customers.
Under these terms, customers who subscribe to sub-processor change notifications will receive updates when Twilio's sub-processor list is modified; customers who do not subscribe may not receive timely notice of sub-processor changes that could affect their own data protection obligations or objection rights.
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Compare across platforms →"Twilio customers may subscribe to notifications of sub-processor changes to receive updates.Excerpt from Twilio's Sub-Processors
1) REGULATORY LANDSCAPE: This provision engages GDPR Article 28(2), which requires processors to inform controllers of any intended changes concerning the addition or replacement of sub-processors, giving the controller the opportunity to object.
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GDPR Article 28(2) requires that processors inform controllers of intended changes to sub-processors and provide the controller with an opportunity to object; this provision establishes the mechanism through which Twilio operationalizes that notification obligation for its customers.
Under these terms, customers who subscribe to sub-processor change notifications will receive updates when Twilio's sub-processor list is modified; customers who do not subscribe may not receive timely notice of sub-processor changes that could affect their own data protection obligations or objection rights.
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