The document states that where the contracting Twilio entity is not Twilio Inc. (for example, where a customer contracts with Twilio Ireland Ltd.), Twilio Inc. itself acts as a sub-processor for the provision of services, processing data in the USA subject to the same regional processing footnote.
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 provision establishes that intra-group data transfers from non-US Twilio contracting entities to Twilio Inc. are structured as sub-processing relationships, which has direct implications for the transfer mechanism and contractual documentation required by EU and UK customers contracting with Twilio Ireland Ltd. or other non-US Twilio entities.
Under these terms, EU and UK customers contracting with Twilio Ireland Ltd. or another non-US Twilio entity have their personal data processed by Twilio Inc. in the United States in a sub-processor capacity, requiring a valid cross-border transfer mechanism and associated documentation under GDPR or UK GDPR.
Cross-platform context
See how other platforms handle Twilio Inc. as Twilio Group Sub-Processor and similar clauses.
Compare across platforms →"Twilio Inc. All Services 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 for the provision of the services.) Provision of the Twilio Services USA*Excerpt from Twilio's Sub-Processors
1) REGULATORY LANDSCAPE: This provision engages GDPR Article 28 and Chapter V, as intra-group transfers from Twilio Ireland Ltd.
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This provision establishes that intra-group data transfers from non-US Twilio contracting entities to Twilio Inc. are structured as sub-processing relationships, which has direct implications for the transfer mechanism and contractual documentation required by EU and UK customers contracting with Twilio Ireland Ltd. or other non-US Twilio entities.
Under these terms, EU and UK customers contracting with Twilio Ireland Ltd. or another non-US Twilio entity have their personal data processed by Twilio Inc. in the United States in a sub-processor capacity, requiring a valid cross-border transfer mechanism and associated documentation under GDPR or UK GDPR.
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