Twilio · Twilio Terms of Service · View original document ↗

Data Use and Privacy

Medium severity Unique · 0 of 325 platforms
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Recent governance activity Twilio recorded 5 documented changes in the last 30 days.
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Document Record

What it is

Twilio may collect and use data about your use of the platform for product improvement, security, and compliance purposes, with more detailed privacy terms available in a separate privacy policy.

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)

The clause establishes the operational scope of Twilio's data processing authority and clarifies the division of responsibility between the service provider and customer regarding data quality. This authorization is bounded by reference to a separate Data Protection Addendum, which specifies additional data handling requirements.

Recent Activity

This document changed recently

Medium May 9, 2026

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 →
Medium Apr 19, 2026

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 →
Medium Apr 10, 2026

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 →

Consumer impact (what this means for users)

Businesses should review Twilio's Privacy Policy and Data Processing Addendum to understand how communications data — including end-user message content — is handled, retained, and protected under applicable privacy laws.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Export Your Data
    Log into your Twilio Console and use the available data export tools to download your account data and communications logs. For GDPR or CCPA data subject requests related to end-user data, submit a request through Twilio's privacy portal or Help Center.

How other platforms handle this

Waze Medium

We may use aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you for any purpose, including sharing it with partners, advertisers, and other third parties. This information is not subject to the restrictions in this Privacy Policy.

Threads Medium

We use the information we collect to send you ads and other commercial and sponsored content. We use the information we have to deliver our products, including to personalize features and content and make suggestions for you on and off our products. We share information across the Meta Companies.

Adyen Medium

In providing the services, Adyen will process personal data in accordance with its Privacy Policy and applicable data protection laws, including the General Data Protection Regulation. You are responsible for ensuring that you have the necessary consents and legal bases to share personal data with A...

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▸ View Original Clause Language DOCUMENT RECORD
"
You grant Twilio and its Affiliates the right to process Customer Data as necessary to provide the Services in a manner that is consistent with this Agreement and the Twilio Data Protection Addendum. You are responsible for the quality and integrity of Customer Data.

— Excerpt from Twilio's Twilio Terms of Service

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

Data handling provisions in the ToS are supplemented by separate privacy policies and DPAs. Compliance teams must ensure appropriate DPAs are executed for GDPR Article 28 processor obligations, CCPA service provider arrangements, and any applicable sector-specific regulations such as HIPAA if health-related communications are processed.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has authority over unfair or deceptive data practices and enforces privacy obligations for commercial entities handling consumer communications data.
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
CAN-SPAM
United States Federal
ePrivacy Directive
European Union
FTC Act Section 5
United States Federal
GDPR
European Union

Provision details

Document information
Document
Twilio Terms of Service
Entity
Twilio
Document last updated
May 5, 2026
Tracking information
First tracked
March 20, 2026
Last verified
March 20, 2026
Record ID
CA-P-001325
Document ID
CA-D-00251
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
c676355dfb24b05dc010ed0bcb79197bc98b3cee9aa736daf4b9636c006d3b01
Analysis generated
March 20, 2026 11:02 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Twilio
Document: Twilio Terms of Service
Record ID: CA-P-001325
Captured: 2026-03-20 11:02:43 UTC
SHA-256: c676355dfb24b05d…
URL: https://conductatlas.com/platform/twilio/twilio-terms-of-service/data-use-and-privacy/
Accessed: May 20, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Twilio's Data Use and Privacy clause do?

The clause establishes the operational scope of Twilio's data processing authority and clarifies the division of responsibility between the service provider and customer regarding data quality. This authorization is bounded by reference to a separate Data Protection Addendum, which specifies additional data handling requirements.

How does this clause affect you?

Businesses should review Twilio's Privacy Policy and Data Processing Addendum to understand how communications data — including end-user message content — is handled, retained, and protected under applicable privacy laws.

Is ConductAtlas affiliated with Twilio?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Twilio.