Provision record
Twilio · Twilio Sub-Processors · View original document ↗

Twilio Inc. acts as sub-processor for non-US contracting entities

High severity High confidence Explicit document language Common · 288 of 352 platforms

Key Facts

When does Twilio Inc. act as a sub-processor for the Twilio contracting entity?
Twilio Inc. acts as a sub-processor for the Twilio contracting entity when Twilio Inc. is not itself the party to the customer's agreement.
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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 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.

Consumer impact (what this means for users)

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.

How other platforms handle this

Zoom Medium

For notifications from Zoom such as those related to the services, phone authentication, meeting invites, meeting summaries and requests to enable AI features, Twilio may process the following data: Name Email address Phone number...

Tinder Medium

we may share data between our affiliates for the safety and security of our users and may take necessary actions if we believe you have violated these Terms, including banning you from our Services and/or our affiliates' services...

Skillshare Medium

Whenever we transfer personal data internationally, we use tools and transfer agreements to: make sure the data transfer complies with applicable law; and help to give your data the same level of protection as it has in the EU...

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
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

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-068212
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-068212
Captured: 2026-07-06 23:19:28 UTC
SHA-256: eb0c920c72df0732…
URL: https://conductatlas.com/platform/twilio/twilio-sub-processors/provision/CA-P-068212/twilio-inc-acts-as-sub-processor-for-non-us-contracting-entities/
Accessed: Aug. 19, 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 Twilio Inc. acts as sub-processor for non-US contracting entities clause do?

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.

How does this clause affect you?

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.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 288 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.