www.twilio.com
Open in
urlscan Pro
65.9.66.110
Public Scan
Submitted URL: https://golink.segment.com/NjY3LU1QUS0zODIAAAGJZGuXGWwHy8VGhkajT12gFBvCSDbNLflM3mhyzxi-uVOyHCJs7K0X1kUn3paZj-vZAaD9g7E=
Effective URL: https://www.twilio.com/legal/privacy?mkt_tok=NjY3LU1QUS0zODIAAAGJZGuXGZOFaTpEJ_kx7uQfoTwMH2bDbEZMS8b2sI3Z_Jyiz4TNB2R8UP...
Submission: On January 23 via api from US — Scanned from DE
Effective URL: https://www.twilio.com/legal/privacy?mkt_tok=NjY3LU1QUS0zODIAAAGJZGuXGZOFaTpEJ_kx7uQfoTwMH2bDbEZMS8b2sI3Z_Jyiz4TNB2R8UP...
Submission: On January 23 via api from US — Scanned from DE
Form analysis 0 forms found in the DOM
Text Content
___
Skip to main content
Skip to content
Twilio
* Products
Featured Products
* MessagingX
Send and receive text messages
SMSWhatsAppChat
* Twilio Engage
Create omnichannel campaigns with a unified, data-first platform
* Twilio Flex
Build with the most flexible cloud contact center
* Trusted Activation
Prevent sign up fraud, account takeovers, and protect transactions
Channels
* SendGrid Email API
Deliver email messages reliably at scale
* Programmable Voice
Make, receive, and monitor calls around the world
* Programmable Video
Build HD real-time video applications
Applications
* Twilio Segment
Unify your customer data to power personalized engagement
* Marketing Campaigns
Create and manage email marketing campaigns
* Twilio Frontline
Connect employees to customers securely from anywhere
* Serverless
Build, deploy, and run apps with Twilio's serverless environment
Connectivity
* Internet of Things
Connect IoT devices to global cellular networks
* Elastic SIP Trunking
Deploy SIP trunks globally in minutes
* Phone Numbers
Access local, national, and toll-free phone numbers
* Short Codes
Send text and picture messages at scale
* Solutions
By Use Case
* Customer Engagement Platform
Build durable customer relationships with personalized, data-driven
engagement
* Marketing
Keep customers engaged on any channel
SMS Marketing
* Operations
Streamline workforce operations and customer fulfillment
Alerts & NotificationsIdentity & Verification
* Customer Service
Deliver personalized customer experiences at scale
Contact CenterIVR & Bots
By Industry
* Financial Services
* Healthcare
* Hospitality
* Public Sector
* Real Estate
* Retail
By Business
* Enterprise
* Startup
* Nonprofit
Resources
* Why Twilio
The trusted platform for data-driven customer engagement across any
channel.
* Customer Stories
See what customers are building with Twilio
* Resource Center
Browse our content library for more resources on how you can create
lasting customer relationships
* Twilio Beta Center
Discover our current beta programs and find out how you can participate
* A2P 10DLC
Prepare for the new A2P 10DLC requirements
* Developers
Documentation
* Twilio Flex
* SMS
* Programmable Voice
* Video
* Email
* WhatsApp API
* Elastic SIP Trunking
* Super SIM
* Verify
* Functions
* Studio
* Twilio CLI
See all docs
Community
* Ahoy!
Get inspired by the latest from our developer community
* Blog
Read tutorials, community projects, and product updates
* Stack Overflow
Ask the Twilio community for help
* Champions
Become a Twilio community Champion
* Developer Events
Beta
Join upcoming group events
Tools & Resources
* CodeExchange
Usable code samples for faster builds
* Changelog
See updates and additions to Twilio products
* API Status
Check real-time monitoring of APIs and all services
* Twilio Education
Learn practical coding skills through live training, student programs, and
TwilioQuest
* Services & Support
Partners
* Find a partner
Work with a Twilio partner to buy or build the right solution
* Partner with us
Join our Build Program as a technology or consulting partner
Twilio Services
* Professional Services
Get technical and strategic advice from Twilio experts
* Training
Learn how to architect, build, and support your apps
Support
* Talk to Support
* Help Center
* Frequently Asked Questions
* Support Plans
* Pricing
Featured Products
* SMS
* WhatsApp API
* Conversations
* Twilio Engage
* Verify
* Lookup
* Twilio Flex
Channels
* Programmable Voice
* Video
* Email
Applications
* Marketing Campaigns
* Twilio Frontline
* Twilio Segment
* Serverless
Connectivity
* Super SIM
* Wireless
* Narrowband
* Elastic SIP Trunking
See all pricing
Sign up
Log inContact sales
* Contact sales
* Sign up
* Menu
English
日本語
English
* 089 143777310
* Support
Help Center
Talk to Support
Training
--------------------------------------------------------------------------------
Contact sales
--------------------------------------------------------------------------------
Support Plans
Partner Solutions
* Log in
Diese Seite ist nur auf Englisch verfügbar. Ihre bevorzugte Sprache ist auf
Deutsch eingestellt.
Legal
* Customer Agreements
* Terms of Service
* Acceptable Use Policy
* Service and Country Specific Requirements
* Data Protection Addendum (DPA)
* Security Overview
* Service Level Agreement
* Advisory Services Terms
* Professional Services Terms
* European Electronic Communications Code Rights Waiver
* Customer Name Changes and Assignments
* Updates to Legal Terms and Conditions
* Build Partner Program Terms
* Partner Program Policies
* Partner Terms of Service (PTOS)
* Acceleration Program Participation Terms
* Supplier Agreements
* Supplier Purchase Order Terms and Conditions
* Country-Specific Terms
* Supplier Data Protection Addendum
* Supplier Code of Conduct
* Mobile Application & Twilio Community Terms
* Twilio Frontline End User App Terms
* Twilio Authy App Terms
* Twilio Community Terms of Use
* Intellectual Property
* DMCA Policy
* Trademark
* Privacy
* Data Privacy at Twilio
* Privacy Notice
* Binding Corporate Rules
* Sub-processors
* GDPR
* Privacy Shield
* Customer Data Protection Addendum
* Supplier Data Protection Addendum
* Resources for Law Enforcement
* Government Requests
* Transparency Report
* Civil Requests
* Submit a request or subpoena
* Code of Conduct & Ethics Hotline
* Twilio Code of Conduct
* Ethics and Whistleblower Hotline
* Digital Promotions General Rules
* Sweepstakes Rules
* Customer Research and User Experience
* Acknowledgement and Waiver
* Legal Notices for Twilio's Web Site
* Impressum (Germany)
Print this page
TWILIO PRIVACY NOTICE
Last updated on September 22, 2022 (View the prior version of our privacy notice
here; or here, for Segment's prior version).
Privacy is Twilio’s code: Twilio has built our global privacy program based on
our Binding Corporate Rules (BCRs), which serve as our code of conduct that
governs our global processing of personal data. No matter where you are in the
world, where you reside, where your citizenship lies, or where your data comes
from, we offer the same high standards of privacy protection to all our
customers. More specifically, “No Shenanigans” is one of our company values, and
we intend to exemplify that with our Privacy Notice, which we hope will provide
clear, detailed, and easy-to-read information about Twilio's privacy practices
and how we process personal information.
In addition, we provide in-time and in-context information about how you can
control the data you collect and retain in our API documentation. Because we
offer many different products — and our customers can configure them in many
different ways — we provide privacy-specific information in our documentation to
enable our customers to make choices when using our products. Please check the
documentation for the product you’re using to learn more about the data elements
it collects and how you can make decisions about that information.
In addition to the Twilio Privacy Notice, both Authy and Frontline — our
standalone apps — have their own privacy notices. If you’re looking for
information about Authy or Frontline, please follow those links.
When we refer to Twilio, we mean the Twilio entity with which you have
contracted. For ease of reference throughout this Privacy Notice, “Twilio” also
refers to the companies that are members of the Twilio Group (the “Twilio Group
Members”) listed in our Binding Corporate Rules. If there are any capitalized
terms in this Privacy Notice that are not defined, then those terms will have
the meaning defined in your agreement with us.
CONTENTS OF THIS NOTICE
Section
What can you find there?
How Twilio processes your personal information
Twilio collects personal information such as Customer Account Data directly from
you — as a customer or a visitor — when you visit Twilio’s website, request a
product, service or access to an event, or when you contact a member of the
Twilio team or sign up for a Twilio account to use our products and services.
Twilio also indirectly collects the personal information of your end users
called Customer Usage Data (e.g., communications metadata) and Customer Content
(e.g., communications content).
Data about our customers
We process customer contact details such as your name, email, and phone number
directly from you when you make a request, contact a member of our team, or
sign-up for a Twilio account. Read this section to learn more about the types of
data we collect about you, why we collect it, and how we store it.
Data about our customers’ end users
We process your end users’ communications-related data such as phone numbers,
email addresses, friendly names that you create for your end users. We also
process the content of communications sent by you or your end users to provide
services to you and to carry out necessary functions of our business as a
communications service provider. Please read this section to learn more about
the types of data we collect about your end users, why we collect it, and how we
store it.
How Twilio shares personal information
First things first: we do not sell your personal information, or the personal
information of your end users. We also do not allow any personal information to
be used by third parties for their own marketing purposes (except in cases where
you explicitly request or provide consent for us to do so, such as at a
conference when you direct us to share your information with a sponsor).
However, we do need to share it in some circumstances. These may be to provide
you services (e.g., to route a call or send an email), or when necessary for our
suppliers to provide services to us, or for another reason listed here.
How to make choices about your data
Twilio provides you with many ways to make choices about your data and your end
users’ data, such as accessing it, correcting it, deleting it, or updating your
choices about how it is used.
Cookies and tracking technology
Twilio uses common information-gathering tools such as cookies, web beacons,
pixels and other similar tracking technologies to automatically collect
information as you navigate our websites, our services or when you interact with
emails we sent to you. You can manage these technologies easily on our websites.
Global privacy compliance at Twilio
Twilio is a global company that is committed to complying with privacy laws
around the world. Read this section to learn more about our global privacy
compliance and how we protect the personal information of specific groups, such
as employees and employee applicants.
International data transfers
Twilio relies on our Binding Corporate Rules (“BCRs”) as our primary data
transfer mechanism. Where Twilio’s BCRs do not apply, such as to cross-border
data transfers of the SendGrid services, we will rely instead on other
safeguards to transfer personal information, as described in this section.
Twilio product privacy
Some of our products, such as SendGrid and Segment, work a bit differently in
terms of applicable privacy protections. We’ve provided this section to explain
where there are differences and how we are continuing to ensure privacy
compliance.
Security information
While there is no such thing as perfect security, we are committed to
maintaining reasonable and appropriate security measures to ensure that your
personal information is protected both online and offline. Read this section to
learn more about our security measures and how you can better protect your
account.
Handling disputes
In the unlikely event that we are unable to resolve a privacy concern quickly
and thoroughly, we provide a path of dispute resolution.
Other information you may find useful
Here you’ll find other useful information about our data protection practices
and about this notice. Our use of automated decision making is minimal; we use
it primarily for anti-fraud purposes. Finally, we may update our Privacy Notice
from time to time, and we will notify our customers in advance of material
changes.
HOW TWILIO PROCESSES YOUR PERSONAL INFORMATION
When we talk about “personal information” or “personal data,” we’re talking
about a broad range of information. Data protection laws around the world define
this concept in different ways, but in general, we mean any information that
relates to an identifiable, living individual person. In other words, a person’s
phone number is personal information, while a business’s phone number is not.
In addition, some data protection laws and privacy laws in certain jurisdictions
differentiate between “controllers” and “processors” of personal information. A
controller decides why and how to process personal information. A processor does
not make decisions about personal information; it only processes personal
information on behalf of a controller based on the controller’s instructions.
With this background, let’s take a high level look at the personal information
Twilio collects and how we process it.
If you are a customer of ours, Twilio processes personal information in
different ways when you use our products and services.
* We process your personal information as a customer (or potential customer) of
Twilio’s services — information that we refer to as Customer Account Data
(e.g., your contact information) — when you visit a Twilio public-facing
website like twilio.com; sign up for a Twilio event, like SIGNAL; reach out
to our Sales team; or sign up for a Twilio, Authy, Segment, or SendGrid
account and use our products and services.
* We process the personal information of your end users who use or interact
with your application that you’ve built on Twilio’s platform, like the people
you communicate with by way of that application. This includes information we
use to route messages and metadata about messages — we refer to this
information as Customer Usage Data — and it also includes the contents of
communications, which we refer to as your Customer Content. You can see a
more detailed definition of “Customer Content” in our Data Protection
Addendum, which is part of our agreement with you.
Twilio processes these categories of personal information differently because
the direct relationship we have with you, our customer, is different from the
indirect relationship we have with your end users.
When Twilio processes your Customer Account Data and your Customer Usage Data,
Twilio is acting as a controller. We are also a controller for our employees’
personal data. When Twilio processes your Customer Content, we are acting as a
processor.
If you are a visitor to our website (by which we mean any website that links
back to this Privacy Notice in its footer, such as to twilio.com, segment.com,
or sendgrid.com), or if you are not a Twilio user and you are attending one of
our events, like SIGNAL, we collect a minimal amount of data about you
(depending on how much you’ve chosen to share with us). This might be as little
as an IP address or a cookie, and it might be your contact information. We also
consider this Customer Account Data. You can read below about how we process
visitors’ Customer Account Data.
If you are an applicant to a job at Twilio, or you are a Twilio employee, you
can read below about how we process employee and applicant data. You can also
read our Global Employee Privacy Notice, which we extend to job applicants.
If you are an end user of a Twilio customer, this Privacy Notice does not apply
to the services that our customers provide to their end users. Our customers
have their own policies regarding the collection, use, and disclosure of the
personal information of their end users. If you are an end user of one of our
customers and want to learn about how that customer handles your personal
information, we encourage you to read the customer’s privacy policy. Only the
customer can assist you with requests for access or deletion.
Jump back up to the summary
--------------------------------------------------------------------------------
DATA ABOUT OUR CUSTOMERS
In short, Twilio requires the minimal amount of data necessary to provide
services to you, and the amount or type of data we collect depends on the
product or service you choose or how you use it. If you choose to share
additional information with us so that we can better customize your account and
our services, we’ll process that with the same care and respect. We do not sell
your personal information and we do not share your information with third
parties for those third parties’ own business interests. This Privacy Notice
describes the data we collect from our customers at a high level, but you can
always learn more by reading our API documentation.
We use the information we collect and share it with our service providers
primarily to provide the services you’ve requested from us, and as needed for
our operational purposes (e.g., to do the things we need to do to function as a
business, such as to collect payment). In addition, we may use data about our
customers to detect, prevent, or investigate security incidents, fraud, or abuse
and misuse of our platform and services.
DATA WE PROCESS DURING ACCOUNT CREATION AND ACCOUNT USAGE
When you sign up for an account with us, we ask for certain information like
your contact details and billing information to facilitate payment and
communication. We also collect some information automatically, like your IP
address, when you log in to your account or when your software application built
on Twilio makes requests to our APIs. We use this to understand who is using our
services and how, and to detect, prevent and investigate fraud, abuse, or
security incidents.
INFORMATION YOU SHARE DIRECTLY:
Name and contact information. When you sign up for a Twilio, SendGrid, or
Segment account with us, we will ask you to give us your name, email address,
and optionally, your company name, and to create a password. You can also name
your account (or accounts, if you have more than one). We collect this
information so we know who you are — this helps us communicate with you about
your account(s), recognize you when you communicate with us through the account
portal or otherwise, bill you correctly, and provide other services.
Telephone number. When you first sign up for an account, we may also ask you for
a telephone number (where it’s relevant to the service you’re using) so we can
communicate a verification code to that telephone number and have you enter the
code into our website. This helps us verify that you’re actually a human being.
A Twilio team member may also contact you at this number to help you with
onboarding unless you choose not to be contacted.
When you set up two-factor authentication for your account, we may ask you to
enter a telephone number to set up the process. You have the option to use that
telephone number as the method for us to communicate verification codes to you
to verify that it is you logging into your account. You can alternatively use
the Authy App or other similar authenticator application for verification codes.
We don’t use this two-factor authentication phone number for purposes other than
providing verification codes; however, if you’ve given us your phone number in
another context, such as in connection with your Twilio account, we may contact
you that way.
Payment information. When you upgrade your trial account, we’ll ask you to
provide our payment processor with your payment method information like a credit
card or your Paypal account and your billing address. Our payment processor,
acting on our behalf, gathers this so we can bill you for your use of our
products and services. Our payment processor will share your billing address
with Twilio. We’ll also use your billing address for tax calculation and audit
purposes.
Subscriber records. For some products, we may also obtain proof of identity from
you that includes a proof of address, name, physical address, or other
identification information. For example, to use our Trust Hub or to obtain a
phone number in certain countries, local law may require us to have a physical
service address on file for the individual who will be using that Twilio number,
whether that’s you or your end user. We may also need proof of identity and
physical service address. We call these “subscriber records.”
We may have to share subscriber records with local government authorities or
with the local telecommunications carrier that provides connectivity services.
We may also use this physical service address for tax purposes. However, we
don’t share subscriber records for purposes other than this, and we treat these
records with our highest confidentiality.
Personalization details. Some of our products, such as our short code service,
may require you to complete an application form by providing details about your
company and your intended use of the product. We’ll use this information for the
purpose of determining eligibility for these products. We may also use it in
connection with improving our own internal processes and services or to train
our team members.
INFORMATION WE GENERATE OR COLLECT AUTOMATICALLY:
SIDs. When you sign up for an account with Twilio, we’ll automatically assign
you and each of your accounts a unique ID — a SID — and we’ll automatically
generate an API token for each of your accounts. These are used like a username
and password to make API requests. Instead of using these API tokens, you
canprovision API Keys and use your API key for authentication when making
requests to our APIs. We keep a record of these credentials so we know it is you
making the requests when your application makes requests to our API using these
credentials.
Device information and IP addresses. When you use our account portal, we collect
your IP address and other data through tracking technologies like cookies, web
beacons, and similar technologies. We also collect IP addresses when you make
requests to our APIs and in our server logs. We use this information to
understand how customers are using our platform, who those customers are (if
they are a company and the IP address is associated with that company), what
country they are logging in from (for analytics and export control purposes),
and to help improve the navigation experience. You can learn more about cookies
in the section titled “Cookies and Tracking Technologies” below.
When you use our account portal, we also collect information about your device,
such as your computer or mobile device operating system type and version number,
manufacturer and model, browser type, screen resolution, unique identifiers, and
general location information such as city or town. We do not collect precise
geographical information.
DATA WE PROCESS FROM OUR WEBSITE, EVENTS, AND INTERACTIONS
When you visit our website, sign up for a Twilio event or request more
information about Twilio, we collect information automatically using tracking
technologies, like cookies, and through web forms where you type in your
information. We collect this information to provide you with what you request
through the web form, to learn more about who is interested in our products and
services, and to improve navigation experience on our pages. You can learn more
about cookies in the section titled “Cookies and Tracking Technologies” below.
INFORMATION YOU SHARE DIRECTLY:
In some places on Twilio’s public-facing websites, you can fill out web forms to
ask to be contacted by our Sales Team, sign up for a newsletter, register for a
Twilio event, or take a survey. The specific personal information requested on
these forms will vary based on the purpose of the form. We will ask you for
information necessary for us to provide you with what you request through the
form (for example, we will ask you for your email address if you want to sign up
for an email newsletter and for your phone number if you want a member of our
Sales Team to call you). We may also ask you for additional information to help
us understand you better as a customer, such as your Twilio use case, your
company name, or your role at your company. If you sign up to receive ongoing
marketing communications from Twilio, like a newsletter, you can always choose
to opt out of further communications through a preferences page which will be
linked from any marketing email you receive from Twilio. You can also contact
our Customer Support Team to communicate your choice to opt out.
If you contact our Sales or Customer Support Teams, those teams keep a record of
that communication, including your contact details and other information you
share during the course of the communication. We store this information to help
us keep track of the inquiries we receive from you and from customers generally
so we can improve our products and services and provide training to team
members. This information also helps our teams manage our ongoing relationships
with our customers. Because we store a record of these communications, please be
thoughtful about what information you share with our Sales and Customer Support
Teams. While we will take appropriate measures to protect any sensitive
information you share with us, it is best to avoid sharing any personal or other
sensitive information in these communications not necessary for these teams to
assist you.
INFORMATION WE COLLECT AUTOMATICALLY:
When you visit Twilio websites, including our web forms, we and our service
providers acting on our behalf automatically collect certain information using
tracking technologies like cookies, web beacons, and similar technologies. We
use this information to understand how visitors to our websites are using them
and which pages and features of the websites are most popular. This helps us
understand how we can improve our websites and track performance of our
advertisements. In addition, we use tracking technologies to help improve the
navigation experience on Twilio websites. We don’t sell this information to
third parties. For more details on our use of cookies and other tracking
technologies, please read the below section titled “Cookies and Tracking
Technologies.”
MARKETING INFORMATION
We use your email address to send you information about other Twilio products,
services or events in which we think you may be interested. You can opt out of
receiving marketing communications from us at any time through your marketing
preferences page by clicking the “unsubscribe” link at the bottom of any
marketing email you receive from Twilio. You can also contact our Customer
Support Team to communicate your choice to opt out. Please note that it may take
up to three days to remove your contact information from our marketing
communications lists, so you may receive correspondence from us for a short time
after you make your request. You will not be able to opt out of service emails
from us, such as password reset emails, billing emails, or notifications of
updates to our terms, unless you deactivate your account.
We may also use publicly-available information about you that we have gathered
through services like LinkedIn, or we may obtain information about you or your
company from third party providers. We use this information to help us
understand our customer base better, such as your industry, the size of your
company, and your company’s website URL. We also use this information to reach
out to potential candidates for roles at Twilio.
When you visit a Twilio website, we process your information to market our
services to you on other websites. You are able to opt out of targeted
advertisements by using the cookie consent management tool, TrustArc. To learn
more about how we process this information and how to make choices about what is
collected, please see the “Cookies and Tracking Technologies” Section below.
HOW LONG WE STORE YOUR CUSTOMER ACCOUNT DATA
Twilio will store your Customer Account Data as long as needed to provide you
with our services and to operate our business. If you ask Twilio to delete
specific personal information from your Customer Account Data (see ‘Choices
About Your Customer Account Data’ below), we will honor this request unless
deleting that information prevents us from carrying out necessary business
functions, such as billing for our services, calculating taxes, or conducting
required audits.
More specifically, within 60 days following closure of your account, we will
either delete other Customer Account Data or transform it such that it can no
longer be used to identify you, with the following exceptions, depending on and
in accordance with applicable law:
* Customer Account Data is stored for up to seven years following closure of
your account. However, we may retain invoice records, including their digital
equivalent, for longer periods for accounting, tax, and audit purposes.
* Where we collect subscriber records, we will retain this data for such time
as needed for legal, security and anti-fraud purposes.
* We may retain your communications with Twilio’s Customer Support Teams for up
to three years after your account is closed.
* We may need to retain data due to special circumstances (such as due to an
open investigation, audit, or other legal matter).
Please read our support page on data retention for more detailed information
about our retention and deletion practices.
Jump back up to the summary
--------------------------------------------------------------------------------
DATA ABOUT OUR CUSTOMERS’ END USERS
WHAT CUSTOMER USAGE DATA AND CUSTOMER CONTENT TWILIO PROCESSES AND WHY
We use Customer Usage Data and Customer Content to provide services to you and
to carry out necessary functions of our business as a communications service
provider. We do not sell your end users’ personal information and we do not
share your end users’ information with third parties for those third parties’
own business interests.
The particular end user personal information Twilio processes when you, our
customer, use our products and services, and the reasons Twilio processes end
user personal information, depends on how you use our products and services and
which Twilio products and services you use. For that reason, our API docs for
each of our products and services are the best place to find information about
our processing of personal information when you use that Twilio product and
service. In many cases, you can opt to store records of your communications or
other activities in your Twilio account, and these records may include your end
users’ personal information. You may also have the option to use additional
features or tools within Twilio’s products or services that allow you to do
things such as analyze the records, including end user personal information, in
your Twilio account. In those cases, Twilio will process this information to
provide you with the service you request.
For Twilio’s customers, our Data Protection Addendum describes more about how we
process Customer Content in accordance with your instructions. That Data
Protection Addendum is a part of your agreement with us by default.
HOW LONG WE STORE CUSTOMER USAGE DATA AND CUSTOMER CONTENT
Details regarding how long your end user personal information may be stored on
Twilio systems will depend on which Twilio products and services you are using
and how you are using them. For that reason, our API docs for each of our
products and services, along with SendGrid’sdocumentation and Segment’s
documentation, are the best place to find more detailed information about
managing end user data collected and stored in connection with your use of our
products and services. We also provide an overview of our retention periods in
our support documentation.
As a Twilio customer, if the Twilio product or service you use enables you to
store records of your usage on Twilio, including personal information contained
within those records, and you choose to do so, then Twilio will retain these
records for as long as you instruct, up until termination of your account. In
some cases, use of extended storage may cost more. If you later instruct us to
delete those records (please see below for information on how to delete your
records), we will do so. Please note that it may take up to 30 days for the data
to be completely removed from all systems.
Jump back up to the summary
--------------------------------------------------------------------------------
HOW TWILIO SHARES PERSONAL INFORMATION
We do not sell your personal information or the personal information of your end
users. We also do not allow any personal information to be used by third parties
for their own marketing purposes (except in cases where you explicitly request
or provide consent for us to do so, such as at a conference when you direct us
to share your information with a sponsor). However, we do need to share personal
data in order to provide our products and services to you, such as to route a
call you send through us or to store data you ask us to store. Below are the
different scenarios under which we may share your data with third parties.
Telephony operators as necessary for proper routing and connectivity.
Twilio provides an easier way for developers to build applications that make use
of the publicly switched telephone network (PSTN) to send communications.
Therefore, communications-related data is shared with and received from
telephony operators as necessary to route and connect those communications from
the sender to the intended recipient. How those telephony operators handle this
data is generally determined by those operators’ own policies and local
regulations.
Other communications service providers for proper routing and connectivity.
Twilio also enables sending or receiving communications through communications
service providers that do not use the PSTN, such as Viber and Facebook Messenger
(referred to as Over-the-Top (OTT) communications service providers). If you
choose to use Twilio to send or receive communications by way of these
providers, Twilio will share communications data with these providers as
necessary to route and connect those communications from the sender to the
intended recipient. How those OTT communications service providers handle this
data is determined by their own policies.
Third-party service providers or consultants.
Twilio engages certain third-party vendors and service providers to carry out
certain data processing functions on our behalf. These providers are limited to
only accessing or using this data to provide services to us and must provide
reasonable assurances they will appropriately safeguard the data.
Sub-processors.
A sub-processor is a vendor that is permitted to process data for which we are a
processor — in other words, Customer Content. We share Customer Content with
sub-processors who assist in providing the Twilio services, like our
infrastructure provider, or as necessary to provide optional functionality like
transcriptions. An up-to-date list of Twilio sub-processors is located here.
Add-on Partners.
Add-ons are additional features, functionality or services offered by Twilio’s
Add-on partners (who are third parties not affiliated with Twilio). Twilio may
make Add-ons available through the Twilio Marketplace. Some Add-ons may need to
access or collect some of your information, including personal information. If
you choose to use an Add-on, Twilio will share your information with the Add-on
partner so you can use the Add-on. Twilio does not control Add-on partners’ use
of your information and their use of your information will be in accordance with
their own policies. If you do not want your information to be shared with an
Add-on partner, then you should not use the Add-on.
Compliance with Legal Obligations.
We may disclose your or your end users’ personal information to a third party if
(i) we reasonably believe that disclosure is compelled by applicable law,
regulation, legal process, or a government request (including to meet national
security, emergency services, or law enforcement requirements), (ii) to enforce
our agreements and policies, (iii) to protect the security or integrity of our
services and products, (iv) to protect ourselves, our other customers, or the
public from harm or illegal activities, or (v) to respond to an emergency which
we believe in good faith requires us to disclose data to assist in preventing a
death or serious bodily injury. For more details, please see the procedure laid
out in our Binding Corporate Rules.
If Twilio is required by law to disclose any personal information of you or your
end user, we will notify you of the disclosure requirement, unless we are
prohibited by law. Further, we object to requests we do not believe were issued
properly.
Twilio Group Members.
We may share your personal information or your end users’ personal information
among Twilio Group Members. Twilio Group Members will only use the information
as described in this notice. You may see who Twilio Group Members are by looking
in our Binding Corporate Rules.
Business transfers.
If we go through a corporate sale, merger, reorganization, dissolution or
similar event, data we gather from you may be part of the assets transferred or
shared in connection with the due diligence for any such transaction. In that
situation, and that situation only, we might transfer your data in a way that
constitutes a sale under applicable law. If we do, we’ll let you know ahead of
time, and we will require any acquirer or successor of Twilio to continue to
process data consistent with this Privacy Notice.
Aggregated or de-identified data.
We might also share data about our customers with third parties if the data has
been de-identified or aggregated in a way so it cannot be used to identify you
or your end users.
Jump back up to the summary
--------------------------------------------------------------------------------
HOW TO MAKE CHOICES ABOUT YOUR DATA
CHOICES ABOUT YOUR CUSTOMER ACCOUNT DATA
Accessing and Controlling Account Data. As part of the services we provide to
our customers, we provide you with a number of self-service features at no
additional cost within the Twilio console itself, including the ability to
access your data, update any incorrect data, download a copy of your data,
delete your data, or restrict the use of your data. You can make various choices
about your Customer Account Data through the account portal when you log into
your Twilio account or through the marketing preferences center. Any other
requests about your data you cannot make through these self-service tools, you
can request by emailing support@twilio.com or contacting Customer Support.
Closing Your Account and Deletion. To request closure or deletion of your Twilio
account, you can email us at support@twilio.com or contact Customer Support.
Please be aware that closure or deletion of your Twilio account will result in
you permanently losing access to your account and the data in the account. After
closure of your account, certain information associated with your account may
remain on Twilio’s servers in an aggregated form that does not identify you or
your end users. Similarly, after you close your account, we will retain data —
including personal information — associated with your account that we are
required to maintain for legal purposes or for necessary business operations
(see “How Long We Store Your Customer Account Data” section above) until it’s no
longer needed.
Our Support portal provides documentation regarding how to delete the data you
control and how long we retain it.
Other Choices About Your Customer Account Data. In addition, you can express
other choices about your Customer Account Data (e.g., accessing it, deleting it,
restricting its use, porting it, or withdrawing consent for its use) by
contacting Customer Support.
CHOICES ABOUT YOUR END USERS’ DATA
We also offer you the ability to delete, access, or exercise other choices about
end user data, namely Customer Usage Data and Customer Content. Your ability to
make choices about this data depends on the Twilio product or service you use
and how you use the product or service. For that reason, our API docs for each
of our products and services, along with SendGrid’sdocumentation and Segment’s
documentation, are the best place to find more detailed information about
managing end user data collected and stored in connection with your use of our
products and services.
In some cases, we may retain a copy of your usage records, including the
personal information contained in them, to carry out necessary functions like
billing, invoice reconciliation, troubleshooting, along with detecting,
preventing, and investigating spam, fraudulent activity, and network exploits
and abuse. Sometimes legal matters arise that also require us to preserve
records, including those containing personal information. These matters include
litigation, law enforcement requests, or government investigations. If we have
to do this, we will delete the impacted records when we are no longer legally
obligated to retain them. We may, however, retain or use records after they have
been anonymized, if the law allows.
Jump back up to the summary
--------------------------------------------------------------------------------
COOKIES AND TRACKING TECHNOLOGIES
Twilio uses common information-gathering tools such as cookies, web beacons,
pixels and other similar tracking technologies to automatically collect
information as you navigate our websites, your account or when you interact with
emails we sent to you.
COOKIES
A cookie is a piece of data contained in a very small text file that is stored
in your browser or elsewhere on your hard drive. Cookies allow Twilio to
identify your device as you navigate our websites or your account. This makes
navigating and interacting with our websites or your account more efficient,
easy and meaningful for you.
By themselves, cookies do not identify you specifically. Rather, they recognize
your web browser. So, unless you identify yourself specifically to Twilio, like
signing into your account, we don’t know who you are just because you visited
our website.
Twilio uses both session and persistent cookies. Session cookies are cookies
that disappear from your computer or browser when you turn off your computer.
Persistent cookies stay on your computer even after you’ve turned it off.
Additionally, the cookies on our websites fall into three categories: (1)
Required Cookies, (2) Functional Cookies, and (3) Advertising Cookies. To learn
more about each category of cookie, you can visit our cookie consent tool by
clicking on the “Cookie Preferences” link on the bottom right of the Twilio
website you are visiting.
HOW TO CONTROL & DELETE COOKIES
TrustArc Consent Tool. Twilio uses “TrustArc” as our cookie consent tool, which
you can utilize to customize your cookie preferences. When you visit our website
for the first time, a cookie consent banner will pop up and ask you to customize
your cookie preferences. If you decide to change your preferences at a later
date, you can easily do so by clicking on the “Cookie Preferences” link on the
bottom right of the Twilio website you are visiting. Please note that Required
Cookies cannot be disabled and if you decide to opt-out of Functional Cookies,
certain functionality of our websites or your account may be impacted.
Using Your Browser. In addition to using our TrustArc Cookie Consent tool, you
can use your browser settings to opt out of Functional Cookies and Advertising
Cookies. For more information on how to do that, click here. To manage privacy
and storage settings for flash cookies, click here.
Do Not Track. Some browsers allow a “do not track” (DNT) setting that requests
that a web application disable its tracking of an individual user. When you
choose to turn on the DNT setting in your browser, your browser will send a
special signal to websites, analytics companies, ad networks, plug-in providers,
and other web services you encounter while browsing and stop tracking your
activity. To set up DNT, you can visit the All About DNT page. If you do choose
to set up DNT, we will automatically turn off all non-required cookies on
Twilio’s websites for you. Please note that this may impact the functionality of
our websites or your account.
Global Privacy Control. Global Privacy Control (GPC) is a technical
specification that you can use to inform websites of your privacy preferences in
regard to ad trackers. To set up GPC, you can visit the Global Privacy Control
page. If you do choose to set up GPC, we will automatically turn off all
non-required cookies on Twilio’s websites for you. Please note that this may
impact the functionality of our websites or your account.
Opting out of Advertising Cookies. To learn more about how to opt out of
targeting and advertising cookies, you can go to the Your Online Choices page,
the Network Advertising Initiative page, and the Digital Advertising Alliance’s
Consumer Choice page. These opt-out tools are provided by third parties, not
Twilio. We do not control or operate these tools or the choices that advertisers
and others provide through these tools.
WEB BEACONS
Twilio also uses web beacons to gather data about your use of our websites, your
account, and how you interact with emails we have sent to you. Web beacons are
clear electronic images that can recognize certain types of data on your
computer, like when you view a particular website tied to the web beacon, and a
description of a website tied to the web beacon. Additionally, we may put web
beacons in marketing emails that notify us when you click on a link in the email
that directs you to a Twilio website. We use web beacons to operate and improve
our websites and email communications to you.
Jump back up to the summary
--------------------------------------------------------------------------------
GLOBAL PRIVACY COMPLIANCE AT TWILIO
Twilio is a global company with customers and offices all around the world. As
such, our approach to privacy compliance is a global one. No matter where you
are located, whether in the United States, the European Economic Area (EEA), the
United Kingdom (UK), Latin America, or the Asia-Pacific region, we remain
committed to abiding by all applicable data protection laws.
REGIONS REQUIRING A LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
If you are from a region that requires a legal basis for processing personal
data (such as the EEA or the UK), our legal basis for collecting and using the
personal information described above will depend on the personal information
concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only where we
need the personal information to perform a contract with you, or where the
processing is in our legitimate interests and not overridden by your data
protection interests or fundamental rights and freedoms, or where we have your
consent to do so. In some cases, we may also have a legal obligation to collect
personal information from you or may otherwise need the personal information to
protect your vital interests or those of another person, such as in the case
where we request personal information from you in the context of a government
audit or in response to a request from law enforcement.
If you have questions about or need further information concerning the legal
basis on which we collect and use your personal information, please contact us
using the contact information provided below.
Broadly speaking, we use Customer Account Data to further our legitimate
interests to:
* understand who our customers and potential customers are and their interests
in Twilio’s product and services;
* manage our relationship with you and other customers;
* carry out core business operations such as accounting, filing taxes, and
fulfilling regulatory obligations; and
* help detect, prevent, or investigate security incidents, fraud and other
abuse or misuse of our products and services.
UNITED STATES
CALIFORNIA CONSUMER ACCESS AND DELETION RIGHTS
For those customers that would like more information about our use of Customer
Account Data or Customer Usage Data, you have the ability to request:
* that we provide details about the categories of personal information that we
collect about you, including how we collect and share it;
* that we provide you access to the personal information we collect about you;
and
* that we delete the personal information we have about you.
Please be aware that when you ask us for these things, we will take steps to
verify that you are authorized to make the request. You do not have to be from
California to make this request.
If you’re a Californian interested in what personal information we have shared
lately for our business purposes, here’s a list:
* Identifiers
* Commercial information
* Financial information
* Internet or other electronic activity information
* Geolocation information
* Professional or employment information
By “our business purposes,” we mean that we only share personal information as
we describe in the section above (in other words, with telephony operators,
communications providers, and so on).
OTHER REGIONS
If you are in a region other than the EEA, the UK, or the United States, we
aren’t forgetting you! There are just some specific requirements those regions
ask us to put in our Privacy Notice. Some countries, like Brazil, also have
specific privacy notice requirements, and we address those requirements in our
general privacy sections above. If there are specific changes we need to make to
our legal language to comply with a country’s privacy or data protection laws,
you can find those changes in our Data Protection Addendum.
PRIVACY COMPLIANCE FOR SPECIFIC INDIVIDUALS
Employee Applicant and Employee Data. Whether you are applying for a position at
Twilio or are a current or former employee, we remain committed to practicing a
“no shenanigans” approach to your personal information. For up to date
information on the types of data we process about you and how we protect it,
please see our Employee Privacy Notice.
Information from Children. We do not knowingly permit children (under the age of
13 in the US and UK or 16, if you live in the EEA) to sign up for a Twilio
account. If we discover someone who is underage has signed up for a Twilio
account, we will take reasonable steps to promptly remove that person’s personal
information from our records. If you believe a person who is underage has signed
up for a Twilio account, please contact us at privacy@twilio.com.
Jump back up to the summary
--------------------------------------------------------------------------------
INTERNATIONAL DATA TRANSFERS
As a global organization, we may need to transfer your personal information to
Twilio affiliates, contractors, service providers, and to third parties in
various countries and jurisdictions around the world. In each case, we take care
to use appropriate safeguards to ensure your personal information remains
protected.
Data transfers to the United States and elsewhere. When you use our account
portal, or our other products and services, personal information of you and your
end users processed by Twilio may be transferred to the United States, where our
primary processing facilities are located, and possibly to other countries where
we or our service providers operate. These transfers will often be made in
connection with routing your communications in the most efficient way.
Safeguards for data transfers. Twilio employs appropriate safeguards for
cross-border transfers of personal data, as required by applicable local law.
Where we must transfer end users’ personal data to a third country, we conduct a
transfer impact assessment, which we make available on our support pages. Our
Data Protection Addendum, which we provide to all customers, includes more
detailed information about our cross-border data transfers.
Twilio’s Binding Corporate Rules. Twilio has established and implemented a set
of Binding Corporate Rules for internal transfers of personal information
between Twilio Group Members in the European Union and Twilio Group Members
elsewhere. Twilio’s BCRs have been approved by European Union Data Protection
Authorities and are a commitment by Twilio to adequately protect personal
information that Twilio processes regardless of where the information resides.
You can access Twilio’s BCR controller and processor policies here.
Where Twilio’s BCRs do not apply, such as to cross-border data transfers of the
SendGrid services, we rely instead on other data transfer mechanisms to transfer
personal information outside the EEA, the UK, and Switzerland, such as Standard
Contractual Clauses and the International Data Transfer Agreement.
Transfers from other countries. When we transfer personal information outside
countries other than those in the EEA, the UK, and Switzerland, we strive to
comply with the cross-border data transfer rules of those countries, such as by
cooperating with that country’s data protection authority or providing a written
agreement to each customer that meets the data protection requirements of the
country.
Privacy Shield Principles. While Twilio does not rely on Privacy Shield for
cross-border data transfers, we still adhere to the Privacy Shield Principles as
a matter of good practice and we maintain our Privacy Shield certification. To
learn more about the Privacy Shield program, and to view our certification,
please visithttps://www.privacyshield.gov/. You can access our Privacy Shield
Statement here.
APEC CBPR & PRP Participation. Twilio’s privacy practices, described in this
Privacy Notice, comply with the APEC Cross Border Privacy Rules (“CBPR”) and
Privacy Recognition for Processors (“PRP”) Systems. The APEC CBPR and PRP
systems provide a framework for organizations to ensure protection of personal
information transferred among participating APEC economies. More information
about the APEC framework can be found here.
Jump back up to the summary
--------------------------------------------------------------------------------
TWILIO PRODUCT PRIVACY
SEGMENT SERVICES
The Segment services, once an independent product, are now part of Twilio’s
overall product line. They are treated the same as the rest of Twilio’s products
and are covered by our Data Protection Addendum and our Binding Corporate Rules.
For more specific information, you can learn more about the Segment services in
the Segment documentation.
SENDGRID SERVICES
The SendGrid services work a little differently from the rest of Twilio’s
services, and we’d like to make sure you’re aware of those differences. Most
importantly, SendGrid services are not currently covered by Twilio’s Binding
Corporate Rules, which means that we rely on Standard Contractual Clauses (which
you can find in our Data Protection Addendum) for any cross-border data
transfers relating to the SendGrid services. However, even where SendGrid
services are not covered by our Binding Corporate Rules, we are committed to
providing a high level of data protection for our SendGrid customers.
Data Collection and Email. For the most part, the SendGrid services collect the
same data the Twilio services collect, and for the same reasons. The SendGrid
services also collect some additional data in the form of web beacons placed in
the body of emails delivered using the SendGrid platform. This allows us to keep
track of whether or not an email has been delivered, opened, clicked on, whether
it bounced or was treated as spam. You can learn more about web beacons in the
section titled “Cookies and Tracking Technologies” above.
Customer Content and Email Recipients’ Personal Information. Like Twilio,
SendGrid is a data processor for Customer Content, like email communications
contents and the contents of marketing campaigns. SendGrid is also a data
processor for email recipients’ email addresses and other recipients’ personal
information. If you’re a customer, our Data Protection Addendum describes more
about how we process Customer Content in accordance with your instructions.
SEPARATE POLICIES
As mentioned above, in addition to the Twilio Privacy Notice, both Authy and
Frontline have their own privacy notices, because they are standalone apps. If
you’re looking for information about Authy or Frontline, please follow those
links.
Jump back up to the summary
--------------------------------------------------------------------------------
SECURITY INFORMATION
HOW WE SECURE PERSONAL INFORMATION
Our security measures. We use appropriate security measures to protect the
security of your personal information both online and offline. These measures
vary based on the sensitivity of the personal information we collect, process
and store and the current state of technology. We also take measures to ensure
service providers that process personal data on our behalf also have appropriate
security controls in place. When we transfer data across borders, we also take
supplementary measures to ensure that data is protected. You may read more about
our security measures in our Security Overview, and if you are located in a
country that requires you to obtain information about our supplemental measures,
you may read more about those measures here.
Please note that no service is completely secure. While we strive to protect
your data, we cannot guarantee that unauthorized access, hacking, data loss or a
data breach will never occur.
Security measures you can take. To protect the confidentiality of your account
and protect against unauthorized use of your account, we recommend enabling
two-factor authentication for your account. Additionally, you must keep your
account password and Auth Token confidential and not disclose them publicly or
to unauthorized individuals — this includes accidentally distributing them in a
binary or checking them into source control. Please let us know right away if
you think your password or Auth Token was compromised or misused. For
instructions on changing your password, click here. For instructions on changing
your Auth Token, click here.
Similarly, if you provision an API Key, you should keep your secret, well...
secret. You should store your API Key, Account SID, and secret in a secure
location. Information on provisioning and revoking API Keys can be foundhere.
HOW WE USE PERSONAL INFORMATION FOR SECURITY PURPOSES
We may collect and use Customer Account Data or Customer Usage Data to detect,
prevent, or investigate security incidents, fraud, or abuse and misuse of our
platform and services. In addition, we also use records containing end user
personal information to debug, troubleshoot, or investigate security incidents;
to detect and prevent spam or fraudulent activity; and to detect and prevent
network exploits and abuse. Specifically, we monitor text message content to
detect spam, fraudulent activity, and violations of our Acceptable Use Policy.
We may anonymize personal information and use it for our legitimate business
needs, and, where allowed by law, this may include records containing end user
personal information.
Jump back up to the summary
--------------------------------------------------------------------------------
HANDLING DISPUTES
We hope we can resolve any disputes relating to our data protection practices
between us. However, if you have a dispute with us relating to our data
protection practices, you can raise your concern or dispute by contacting the
Office of the Data Protection Officer either via email at privacy@twilio.com or
by mail at any of the following addresses:
Worldwide Headquarters
EEA Headquarters
UK Headquarters
Twilio Inc.
101 Spear Street, Ste 500
San Francisco, CA 94105
Twilio Ireland Limited
3 Dublin Landings, North Wall Quay
Dublin 1, Ireland
Twilio UK Limited
100 New Bridge Street
London, United Kingdom, EC4V 6JA
If we can’t resolve the dispute through those channels and you are not in the
EEA, UK, or Switzerland, please see Section 9.7 (Dispute Resolution) of our
Terms of Service, which describes how disputes will be resolved between us. As
described in that section, JAMS’ Comprehensive Arbitration Rules and Procedures
will conduct the dispute resolution proceedings. Please be sure to review our
Terms of Service, including Section 9.7, before you use any of our products and
services.
For individuals in the EEA, the UK, or Switzerland, you have additional rights
to make a complaint to a competent data protection authority or commence
proceedings in a court of competent jurisdiction in accordance with applicable
data protection laws. We also provide an additional independent dispute
resolution provider which you may utilize at no cost to you. We outline this
process in our Privacy Shield Statement (while we do not rely on Privacy Shield
for data transfers, we continue to comply with the framework, including its
dispute resolution process).
If you are a resident of the EEA or the UK, you also have the right to lodge a
complaint with your local data protection authority or the Data Protection
Commissioner in Ireland (where our EEA headquarters are based) or the
Information Commissioner’s Office in the UK.
Irish Data Protection Commissioner
Officer of the Data Protection Commissioner
Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, Ireland
Phone: +353 57 868 4757
Fax: +353 57 868 4757
Email: info@dataprotection.ie
Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow
Cheshire, SK9 5AF, United Kingdom
Phone: 0303 123 1113 (local rate)
Fax: 01625 524 510
Email: icocasework@ico.org.uk
If you have an unresolved privacy or data use concerns related to Twilio's
participation in CBPR certification that we have not addressed satisfactorily,
please contact our U.S.-based third-party dispute resolution provider (free of
charge) at https://feedback-form.truste.com/watchdog/request.
For more information about Twilio’s complaint handling procedures, see the
Complaint Handling Procedure in our BCRs.
Jump back up to the summary
--------------------------------------------------------------------------------
OTHER INFORMATION YOU MAY FIND USEFUL
AUTOMATED DECISION MAKING AND MACHINE LEARNING
Twilio may use automated decision making leveraging a variety of signals derived
from records we collect to help monitor, identify, and suspend accounts sending
spam or engaging in other abusive or fraudulent activity. Holders of accounts
suspended under these circumstances are notified of the suspension and given an
opportunity to request human review of the suspension decision.
CHANGES TO OUR PRIVACY NOTICE
We may change this Privacy Notice from time to time, and if we do, the most
current version will be available at https://www.twilio.com/legal/privacy with
the date indicating when it was last updated. These changes might be minor, such
as updating an address or fixing a typo, or they might be material, such as
making a change that affects your rights. If we make changes that affect your
rights, we will provide advance notice to you, such as by posting a message in
the Twilio console, or we’ll send an email via the address we have on file for
you. We will comply with applicable law with respect to any changes we make to
this notice and seek your consent to any material changes if this is required by
applicable law.
Jump back up to the summary
--------------------------------------------------------------------------------
* Legal
* Privacy
* Twilio.org
* Press & Media
* SIGNAL
* Investors
* Jobs
* Copyright © 2023 Twilio Inc.
All Rights Reserved.
Feedback