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 is an ongoing warranty obligation, meaning a failure to maintain adequate consents or notices at any point during the Agreement constitutes a breach of warranty.
Interpretive note: The excerpt is truncated after 'all Customer Data' and may contain additional qualifications about the scope of Customer Data or the processing activities covered.
The updated terms establish a different dispute resolution process for customers domiciled or registered in Mexico. Previously, Mexico was subject to the standard arbitration venue clause routing disputes to San Francisco, California. Under the revised agreement, Mexican customers must first engage in good faith negotiations with Twilio's senior representatives for 30 days; if unresolved, disputes proceed to binding arbitration under Centro de Arbitraje de México (CAM) rules, conducted in English in Mexico City before a sole arbitrator. The agreement also explicitly states that Mexican consumer protection law (Ley Federal de Protección al Consumidor) does not apply to the commercial relationship between the parties. Mexico-domiciled customers should review the updated dispute resolution procedures and understand that consumer protection law carve-out before continuing use.
View change record →The updated terms establish two new regional service entities: CISA Telecomunicaciones for Mexico and Teravoz Telecom for Brazil, meaning customers in those jurisdictions will contract with the local entity rather than Twilio Inc. The agreement now permits orders to be placed through Twilio's online self-service purchasing workflow in addition to traditional written order forms, streamlining how purchase terms can be documented. The updated language also removes the prior commitment that Twilio will not materially decrease overall service functionality, replacing it with a general statement that services may change over time without specific protections on functionality levels.
View change record →The updated terms now route Twilio service agreements for Mexico and Brazil customers to new regional entities rather than Twilio Inc., which may affect service delivery, dispute resolution venue, and applicable local law. The definition of Order Form was expanded to explicitly include self-service online purchases, clarifying that terms negotiated through Twilio's account interface carry the same contractual weight as traditional executed agreements. The terms also removed language stating that Twilio would not materially decrease overall service functionality, replacing it with a simpler statement that services may change over time, which narrows the operational commitment Twilio makes regarding service stability. You can review the separate agreements that now govern your use based on your regional location.
View change record →You are required to continuously ensure that all necessary consents, permissions, and notices are in place for Twilio's processing of Customer Data, not just at the outset.
How other platforms handle this
We will only collect, use and disclose your personal data with your consent, unless otherwise permitted or required by law. Your consent may be given expressly or implied, depending on the circumstances and the sensitivity of the information involved.
You may give us your Identity Data, Contact Data, Financial Data, Profile Data, and other information by filling in forms or by corresponding with us by post, phone, e-mail or otherwise.
telemetry information collected includes: (i) microservice settings, (ii) usage data and (iii) hardware environment.
"You represent and warrant that you have provided, and will continue to provide, adequate notices, and that you have obtained, and will continue to obtain, the necessary permissions and consents required to enable Twilio to process all Customer Data...Excerpt from Twilio's Terms of Service
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This is an ongoing warranty obligation, meaning a failure to maintain adequate consents or notices at any point during the Agreement constitutes a breach of warranty.
You are required to continuously ensure that all necessary consents, permissions, and notices are in place for Twilio's processing of Customer Data, not just at the outset.
ConductAtlas has identified this type of provision across 296 platforms. See the full comparison.
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