www.twilio.com Open in urlscan Pro
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      Get technical and strategic advice from Twilio experts
   
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      Learn how to architect, build, and support your apps
   
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   See all pricing


 1. PROVEN LEADER IN PERSONALIZED CUSTOMER ENGAGEMENT
    
    Learn how Twilio is different from competitors and why you should use the
    proven leader for your customer engagement strategy.


 2. EMBED VOICE AND VIDEO CALLS IN YOUR APPLICATION
    
    Integrate voice and video calling into your applications with Twilio and
    WebRTC. Our SDKs for JavaScript, iOS, and Android give you the tools to
    create voice and video experiences across all major browsers and devices.


 3. EMBED VOICE DIRECTLY INTO YOUR APPLICATIONS
    
    Quickly and conveniently embed real-time voice and PSTN calling into your
    mobile and web-based applications with our plug-and-play Twilio Voice SDKs.


 4. VOICE WITH THE POWER OF PROGRAMMABILITY
    
    Scale your calling capabilities in seconds, globally, with Twilio
    Programmable Voice. Build a custom voice calling experience with a variety
    of innovative APIs, SDKs, and integrations. Get started today!

Data is collected based on search terms. Privacy Policy

 * Contact sales
 * Start for free
 * Menu


 1. PROVEN LEADER IN PERSONALIZED CUSTOMER ENGAGEMENT
    
    Learn how Twilio is different from competitors and why you should use the
    proven leader for your customer engagement strategy.


 2. EMBED VOICE AND VIDEO CALLS IN YOUR APPLICATION
    
    Integrate voice and video calling into your applications with Twilio and
    WebRTC. Our SDKs for JavaScript, iOS, and Android give you the tools to
    create voice and video experiences across all major browsers and devices.


 3. EMBED VOICE DIRECTLY INTO YOUR APPLICATIONS
    
    Quickly and conveniently embed real-time voice and PSTN calling into your
    mobile and web-based applications with our plug-and-play Twilio Voice SDKs.


 4. VOICE WITH THE POWER OF PROGRAMMABILITY
    
    Scale your calling capabilities in seconds, globally, with Twilio
    Programmable Voice. Build a custom voice calling experience with a variety
    of innovative APIs, SDKs, and integrations. Get started today!

Data is collected based on search terms. Privacy Policy

 * Products
   
   CUSTOMER DATA
   
   --------------------------------------------------------------------------------
   
    * Twilio Segment logo
      Customer Data Platform
      
      Unify your customer data with Segment to power personalized engagement
   
    * Connections ↗
      
      Integrate web and mobile app data with a single API
   
    * Protocols ↗
      
      Protect the integrity of your data
   
    * Journeys ↗
      
      Design cross-channel engagement
   
    * Profiles Sync ↗
      
      Sync customer profiles to the warehouse
   
    * Reverse ETL ↗
      
      Move warehouse data to your applications
   
   COMMUNICATIONS
   
   --------------------------------------------------------------------------------
   
    * Twilio MessagingX logo
      Messaging
      
      Send and receive multichannel text and media messages in 180+ countries
      
      SMS WhatsApp Chat
    * Twilio SendGrid Email API logo
      Email
      
      Deliver email messages reliably at scale with SendGrid
   
    * Twilio Programmable Voice logo
      Voice
      
      Make, receive, and monitor calls around the world
      
      PSTN Sip Trunking SDK
    * Twilio Phone Numbers logo
      Phone Numbers
      
      Access local, national, and toll-free phone numbers
      
      Toll-Free 10DLC Short Codes
   
   --------------------------------------------------------------------------------
   
    * Twilio Verify logo
      Verify
      
      Globally-managed multichannel 2FA and passwordless authentication
   
    * Twilio Lookup logo
      Lookup
      
      Know your customer and assess identity risk with real-time phone
      intelligence
   
    * Twilio Developer Center logo
      Serverless
      
      Build, deploy, and run apps with Twilio’s serverless environment
   
    * Twilio Video logo
      Video
      
      Build HD real-time video applications
   
   APPLICATIONS
   
   --------------------------------------------------------------------------------
   
    * Twilio Flex logo
      Twilio Flex
      
      Digital engagement center for customer service and sales
      
      Contact Center
    * Twilio Engage logo
      Twilio Engage
      
      Create multi-channel campaigns with a unified data-first platform
   
    * Twilio Marketing Campaigns logo
      Marketing Campaigns
      
      Create and manage email marketing campaigns with SendGrid

 * 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
    * Product & Engineering
      
      Connect with target users reliably and securely
      
      Alerts & Notifications Identity & Verification
    * Customer Experience
      
      Deliver personalized customer experiences at scale
      
      Contact Center IVR & Bots
   
   BY INDUSTRY
   
   --------------------------------------------------------------------------------
   
    * Financial Services
    * Healthcare
    * Hospitality
    * Public Sector
    * Real Estate
    * Retail
   
   BY BUSINESS
   
   --------------------------------------------------------------------------------
   
    * Enterprise
    * Startup
    * Nonprofit
   
   RESOURCES
   
   --------------------------------------------------------------------------------
   
    * CustomerAI
      
      Combine real-time engagement data with AI to know your customers better
   
    * 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
   
    * Trust Center
      
      Twilio’s security, data privacy, regulatory compliance, and resiliency
      policies

 * Developers
   
   AN OPEN BOOK DOCUMENTATION
   
   --------------------------------------------------------------------------------
   
    * Twilio Flex
    * SMS
    * Programmable Voice
    * Video
    * Email
    * WhatsApp API
    * Elastic SIP Trunking
    * Super SIM
    * Verify
    * Functions
    * Studio
    * Twilio CLI
   
   See all docs
   
   > TWO USERS IN A CIRCLE 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
   
   WRENCH AND SCREWDRIVER 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

 * Services & Support
   
   PEOPLE SHAKING HANDS 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
   
   DESKTOP COMPUTER WITH A USER ICON TWILIO SERVICES
   
   --------------------------------------------------------------------------------
   
    * Professional Services
      
      Get technical and strategic advice from Twilio experts
   
    * Training
      
      Learn how to architect, build, and support your apps
   
   CUSTOMER SERVICE HEADSET 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 Segment
    * Serverless
   
   CONNECTIVITY
   
   --------------------------------------------------------------------------------
   
    * Elastic SIP Trunking
   
   See all pricing

 * Start for free
 * Login
 * Console
 * Contact sales

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TWILIO PRIVACY NOTICE

Last Updated: August 1, 2023 (View the prior version of our privacy notice
here or the prior Authy privacy notice here and prior Frontline privacy notice
here)

 

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 data.


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 An icon of a
outbound link arrow . 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.

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 data

Twilio collects personal data 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 data 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 data

First things first: we do not sell your personal data, or the personal data of
your end users. We also do not allow any personal data 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, or share
personal data for cross-context behavioral advertising.

--------------------------------------------------------------------------------

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 data 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 data, as described in this section.

--------------------------------------------------------------------------------

Twilio product privacy

Some of our products, such as Authy, Frontline, 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 data 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 DATA

When we talk about “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 data, 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 data. A
controller decides why and how to process personal data. A processor does not
make decisions about personal data; it only processes personal data on behalf of
a controller based on the controller’s instructions.

With this background, let’s take a high level look at the personal data Twilio
collects and how we process it.

If you are a customer of ours, Twilio processes personal data in different ways
when you use our products and services.

 * We process your personal data 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 data 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 data 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 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 data 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 data, we
encourage you to read the customer’s privacy policy. Only the customer can
assist you with requests for access or deletion.

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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 data 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 by
email, text or voice call about your account(s), service-related information,
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 An icon of a
outbound link arrow  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
can provision API Keys An icon of a outbound link arrow  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 data 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  An icon of a outbound link arrow 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 update your communication
preferences An icon of a outbound link arrow using our online form or 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 data 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 An icon of a outbound link arrow
 for more detailed information about our retention and deletion practices.

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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 data and we do not share your
end users’ information with third parties for those third parties’ own business
interests or cross-context behavioral advertising.

The particular end user personal data Twilio processes when you, our customer,
use our products and services, and the reasons Twilio processes end user
personal data, depends on how you use our products and services and which Twilio
products and services you use. For that reason, our API docs An icon of a
outbound link arrow  for each of our products and services are the best place to
find information about our processing of personal data 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 data. 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 data, 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 data 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 An icon of a outbound link
arrow  for each of our products and services, along with
SendGrid’s documentation An icon of a outbound link arrow  and
Segment’s documentation An icon of a outbound link arrow , 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 An icon of a
outbound link arrow .

As a Twilio customer, if the Twilio product or service you use enables you to
store records of your usage on Twilio, including personal data 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.

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HOW TWILIO SHARES PERSONAL DATA

We do not sell your personal data or the personal data of your end users. We
also do not allow any personal data 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) or share personal data for cross-context
behavioral advertising. 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.

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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.

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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.

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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.

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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 data. 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.

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Compliance with Legal Obligations.

We may disclose your or your end users’ personal data 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 data 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.

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Twilio Group Members

We may share your personal data or your end users’ personal data 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.

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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.

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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.

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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 contact Customer Support.

Closing Your Account and Deletion. To request closure or deletion of your Twilio
account, you can 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 data —
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 An icon of a outbound link arrow  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 An icon of
a outbound link arrow  for each of our products and services, along with
SendGrid’s documentation An icon of a outbound link arrow  and
Segment’s documentation An icon of a outbound link arrow , 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 data 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 data. 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.

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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 An icon of a
outbound link arrow . To manage privacy and storage settings for flash cookies,
click here An icon of a outbound link arrow .

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 An icon of a outbound
link arrow  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 
An icon of a outbound link arrow  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 An icon
of a outbound link arrow  page, the Network Advertising Initiative An icon of a
outbound link arrow  page, and the Digital Advertising Alliance’s Consumer
Choice An icon of a outbound link arrow  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.

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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 DATA


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 data described above will depend on the personal data concerned and the
specific context in which we collect it.

However, we will normally collect personal data from you only where we need the
personal data 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 data from you or
may otherwise need the personal data to protect your vital interests or those of
another person, such as in the case where we request personal data 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 data, 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

STATE 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 data that we collect
   about you, including how we collect and share it;
 * that we provide you access to, and a copy of, the personal data we collect
   about you;
 * that we update or correct any inaccurate personal data we have about you; and
 * that we delete the personal data we have about you.

Please scroll up to our section above on How to make choices about your data for
more information about how to make a request.

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
any specific state, such as California, Colorado, Utah, or Virginia, to make
this request. We won’t discriminate against you or change the price of our
services if you make a request, but if you ask us to delete your data, it may
affect your ability to use our service.

If you’re a Californian interested in what personal data 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 data 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 data. 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
data 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 An icon of a outbound
link arrow .

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INTERNATIONAL DATA TRANSFERS

As a global organization, we may need to transfer your personal data 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 data remains protected.

Data transfers to the United States and elsewhere. When you use our account
portal, or our other products and services, personal data 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 An icon of
a outbound link arrow  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 An icon of a outbound
link arrow , 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.

 

EU-US Data Privacy Framework (“EU-US DPF”) and Swiss-US Data Privacy Framework
(Swiss-US DPF).  As set forth by the U.S. Department of Commerce Twilio is
 officially certified under the EU-US DPF and Swiss-US DPF and relies on these 
certifications as its primary transfer mechanisms for transfers of personal data
from the EU and Switzerland to the US. Twilio adheres to the DPF principles for
onward transfers of personal data to third parties and remains liable for
damages caused by third parties under the DPF unless Twilio did not cause the
event giving rise to damage. The U.S. Federal Trade Commission has jurisdiction
over Twilio’s compliance with the EU-US DPF and the Swiss-US DPF.To learn more
about the DPF Program, and to view our certifications, please visit the DPF
website here. An icon of a outbound link arrow

Twilio’s Binding Corporate Rules. Twilio has established and implemented a set
of Binding Corporate Rules for internal transfers of personal data 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 data that Twilio
processes regardless of where the information resides. You can access Twilio’s
BCR controller and processor policies here.

Where neither the EU-US DPF, Swiss-EU DPF nor Twilio's BCRs apply, such as to
cross-border data transfers of the SendGrid services to a country other than the
US, we rely instead on other data transfer mechanisms to transfer personal data
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 data 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.

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
data transferred among participating APEC economies. More information about the
APEC framework can be found here An icon of a outbound link arrow .

 

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TWILIO PRODUCT PRIVACY


AUTHY SERVICES

The Authy service is our standalone two-factor authentication (2FA) service for
desktop and mobile. The Authy apps generate one time passwords and push
notifications that can be used as a part of a two-step verification process with
your Authy-compatible accounts to add another layer of security. Authy’s 2FA can
be used on its own or with applications that directly integrate with Authy’s
2-factor authentication API.

Data Collection and Authy. For the most part, Authy collects the same data the
Twilio services collect, and for the same reasons. However, Authy collects
slightly different data elements due to the nature of the service.

Identifiers. Once you open the Authy app, we ask you to provide us with a phone
number to create your Authy account. We send a verification code to that phone
number to be sure that the person creating the Authy account also has control
over the phone number entered. This phone number is considered your “primary
device,” and will be the identifier for your Authy account. We use that phone
number to identify you, to provide you 2FA services, and to maintain logs for
security and anti-fraud purposes. We do not use that phone number to provide
sales or support to you; however, if you sign up for other Twilio services, we
may ask you for your phone number in those contexts, and use it for those
purposes.

We collect your email address, and we use it for identity verification and
account recovery purposes. We will also use your email address to send system
emails to you, such as to let you know about suspicious logins or updates to
this policy. We may also send notices about Twilio products or events to you,
but you may click on the unsubscribe link that will appear at the bottom of any
of our marketing emails or you can contact customer support to opt out.

If you are a user of an application that directly integrates with Authy’s
2-Factor Authentication API, those applications collect your phone number, user
name, and email address and share that information with us so we can use it to
associate your account on that application with your Authy account. When that
application shares your phone number, user name, and email address with us, we
will create an Authy account for you if you do not have one already. We will use
your phone number to communicate to you verification codes so you can log into
your account on that application.

Device Information. When you download and open the Authy desktop or mobile app,
we automatically collect information about the type of device you have
downloaded the app on and your device identifier. We collect this to ensure we
deliver the right version of the app for your device and so that we can provide
appropriate follow up support as necessary. We also use your device information
to ensure proper delivery of our service and to provide and deliver support and
maintenance of the Authy app.

Login History and Authy Account History. When you use an Authy token to log into
an account, whether the token was generated on the app or one sent to you via
your phone number, we collect and keep information associated with your login
activity including information like your IP address, what application you logged
in to, that you logged in, and when. If you change your phone number or email
associated with your Authy account, we will also keep a log of that. We collect
this information to monitor for suspicious activity and also as another piece of
information that could be used to verify your identity if we suspect your
account may be compromised.

Geolocation information. If you have location services turned on, we collect
your location based on your IP address. We use this information for anti-fraud
purposes, to check for suspicious activity and, again, as another piece of
information we can use to verify your identity if we suspect your account may be
compromised.

How we share personal data. In general, Authy shares personal data in the same
way Twilio does (see How Twilio shares personal data for more). Authy does not
sell personal data and does not share personal data for third parties’
behavioral advertising purposes.

However, Authy users should be aware that an application that integrates with
the Authy 2-Factor API can access your phone number, email address, and user
name. It will also be able to access your primary device type and information
associated with your login activity to that application. It may also retain this
information on its own servers. We may also share other information related to
your account with that application to help them and us detect suspicious or
fraudulent activity on your account. That application will only be able to see
information related to your account on their service; it will not be able to see
other accounts for which you use Authy to provide 2FA.


FRONTLINE SERVICES

To use the Frontline services, you must log in to the Frontline app using a
third party account (through your Single Sign-On provider). The authentication
of your login details is handled by that third party and we only collect the
information you expressly agree to share with us at the time you give permission
to link the Frontline app with the third party account. We only gather the
information you and our customers give us access to, and we only use it for the
purposes for which you and our customers have provided it to us. Please see
the Frontline App Terms for specific details about your relationship with us.



If you are an end user of the Frontline services, Twilio is a processor of your
personal data. Please reach out to your employer (or the entity that has
authorized your access to the Frontline app) to make a request for us to update
or erase any information about you or to stop using any information about you.


SEGMENT SERVICES


The Segment services 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 An icon of a outbound link arrow .


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 Data. 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 data. If you’re a
customer, our Data Protection Addendum describes more about how we process
Customer Content in accordance with your instructions.

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SECURITY INFORMATION


HOW WE SECURE PERSONAL DATA


Our security measures. We use appropriate security measures to protect the
security of your personal data both online and offline. These measures vary
based on the sensitivity of the personal data 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 An icon of a outbound link arrow .

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 An icon of a outbound link
arrow . For instructions on changing your Auth Token, click here An icon of a
outbound link arrow .

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 found here An
icon of a outbound link arrow .

If you have any Twilio service, such as Authy or Frontline, on your mobile
device, you should take measures to protect your device. First, you should set a
password and activate biometrics (like Touch ID), where available, for all
devices on which you have downloaded your Twilio app. For the Authy mobile app,
you also have the option of setting an app-specific protection pin. You can do
this by going into your Authy app and clicking on settings. In settings, you
should click on “Protection Pin.” You can choose to include a Protection Pin
which will require you to enter a pin number of your choosing before accessing
settings and your Account Info. Depending on your device’s capabilities, you may
also be able to add biometric protection. You can also choose to protect the
entire app which will require you to enter your chosen Pin and/or use biometric
to open the Authy app on your device. We recommend that if you have downloaded
Authy onto a shared device, that you use this last option of protecting the
entire app.

If you have multiple devices associated with your account and one of your
devices is lost or stolen, you can remove that device from your circle of
trusted devices by going into one of the other devices associated with your
account, and over which you still control, and remove the lost or stolen device
under Settings > Devices. If you only have a single device that is associated
with your account and that device is lost or stolen, you can alert us by
contacting our Customer Support Team.


HOW WE USE PERSONAL DATA 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 data 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 data and use it for our legitimate business needs,
and, where allowed by law, this may include records containing end user personal
data.

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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.

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