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Lookup
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intelligence
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visual builder
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CUSTOMER DATA
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Twilio Segment ↗
Unify your customer data with Segment CDP to power personalized engagement
* Connections ↗
Integrate web and mobile app data with a single API
Reverse ETL
* Cloud with an upload download symbol
Protocols ↗
Protect the integrity of your data
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Orchestrate multichannel customer journeys
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Add user verification to protect against fraud.
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Create multichannel marketing campaigns.
SMS marketing Customer surveys
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Provide personalized, data-driven service.
* IVR & self-service
Set up a modern IVR with AI-enabled support.
Call tracking
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TWILIO PROGRAMMABLE MESSAGING LOGO TWILIO SERVICES
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AN OPEN BOOK DOCUMENTATION
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COMPANY
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channel.
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software.
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lasting customer relationships
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practices
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See the top trends shaping customer engagement in our annual report
* Twilio Events
Join upcoming group events
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COMMUNICATIONS
--------------------------------------------------------------------------------
* Twilio Messaging logo
Messaging
SMS Whatsapp Conversations
* Twilio SendGrid Email API logo
Email ↗
* Twilio Programmable Voice logo
Voice
Conferencing SIP trunking
--------------------------------------------------------------------------------
* Twilio Verify logo
Verify
* Twilio Lookup logo
Lookup
* Serverless
* Twilio Video logo
Video
APPLICATIONS
--------------------------------------------------------------------------------
* Twilio Flex logo
Twilio Flex
* Twilio Engage logo
Twilio Segment ↗
* Twilio Marketing Campaigns logo
Marketing Campaigns
See all pricing
Data is collected based on search terms. Privacy Policy
* Contact sales
* Start for free
* Menu
Data is collected based on search terms. Privacy Policy
* Products
COMMUNICATIONS
--------------------------------------------------------------------------------
* Twilio Messaging logo
Messaging
Send and receive multichannel text and media messages in 180+ countries
SMS WhatsApp Conversations RCS
* Voice
Make, receive, and monitor calls around the world
PSTN SIP Trunking SDK
* 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 SendGrid Email API logo
Email
Deliver email messages reliably at scale with SendGrid
* Twilio Task Router logo
Serverless
Build, deploy, and run apps with Twilio’s serverless environment and
visual builder
* Twilio Phone Numbers logo
Phone Numbers
Access local, national, and toll-free phone numbers
Toll-Free 10DLC Short Codes
* Twilio Video logo
Video
Connect virtually with secure, high-quality video calling at global scale
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
CUSTOMER DATA
--------------------------------------------------------------------------------
* Twilio Segment logo
Twilio Segment ↗
Unify your customer data with Segment CDP to power personalized engagement
* Connections ↗
Integrate web and mobile app data with a single API
Reverse ETL
* Cloud with an upload download symbol
Protocols ↗
Protect the integrity of your data
* Unify ↗
Unify customer data across every channel
Profiles Sync
* Journeys ↗
Orchestrate multichannel customer journeys
See all products
* Solutions
USE CASES
--------------------------------------------------------------------------------
* Verification & identity
Add user verification to protect against fraud.
Fraud prevention
* Alerts & notifications
Deliver notifications across text, email, voice.
Appointment reminders Lead alerts Mass texting
* Marketing & promotions
Create multichannel marketing campaigns.
SMS marketing Customer surveys
* Contact Center
Provide personalized, data-driven service.
* IVR & self-service
Set up a modern IVR with AI-enabled support.
Call tracking
TEAMS
--------------------------------------------------------------------------------
* Marketing
Keep customers engaged on any channel
* Product & Engineering
Connect with target users reliably and securely
* Customer Experience
Deliver personalized sales and support experiences at scale
* Developers
Tutorials and docs to start building on Twilio
INDUSTRIES
--------------------------------------------------------------------------------
* Financial Services
* Healthcare
* Hospitality
* Public Sector
* Real Estate
* Retail
BUSINESS SIZE
--------------------------------------------------------------------------------
* Enterprise
* Startup
* Nonprofit ↗
See all solutions
PEOPLE SHAKING HANDS PARTNERS
--------------------------------------------------------------------------------
* Find a partner
Work with a Twilio partner to buy or build the right solution
* Partner with us
Join our Partner Program to build or sell Twilio solutions to your
customers.
TWILIO PROGRAMMABLE MESSAGING LOGO TWILIO SERVICES
--------------------------------------------------------------------------------
* Professional Services
Get technical and strategic advice from Twilio experts
* Training
Learn how to architect, build, and support your apps
* Developers
AN OPEN BOOK DOCUMENTATION
--------------------------------------------------------------------------------
* Twilio Flex
* SMS
* Voice
* Email
* WhatsApp API
* Elastic SIP Trunking
* Verify
* Functions
* Studio
* Twilio CLI
See all docs
> TWO USERS IN A CIRCLE COMMUNITY
--------------------------------------------------------------------------------
* Ahoy!
Get inspired by the latest from our developer community
* Developer Blog
Read tutorials, community projects, and product updates
* Stack Overflow
Ask the Twilio community for help
* Champions
Become a Twilio community Champion
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
* Beta Products and Features
Explore new launches and request access to early releases
* Why Twilio
COMPANY
--------------------------------------------------------------------------------
* Why Twilio
The trusted platform for data-driven customer engagement across any
channel.
* About Us
Twilio company page
* Twilio Magic
Twilio core values
* Diversity
Diversity, equity, and inclusion
* Investor Relations
Information for Twilio investors
* Press & Media
Latest announcements and launches
OUR PLATFORM
--------------------------------------------------------------------------------
* Customer Engagement Platform
Build durable customer relationships with personalized, data-driven
engagement
Communication Customer Data
* Trust Center
Twilio’s security, data privacy, regulatory compliance, and resiliency
policies.
* Super Network
Simplify, strengthen and unite carrier communication networks using
software.
RESOURCES
--------------------------------------------------------------------------------
* Resource Center
Browse our content library for more resources on how you can create
lasting customer relationships
* Customer Stories
See what customers are building with Twilio
* Blog
Explore the latest product updates, technical tutorials, and best
practices
* State of Customer Engagement
See the top trends shaping customer engagement in our annual report
* Twilio Events
Join upcoming group events
* Pricing
COMMUNICATIONS
--------------------------------------------------------------------------------
* Twilio Messaging logo
Messaging
SMS Whatsapp Conversations
* Twilio SendGrid Email API logo
Email ↗
* Twilio Programmable Voice logo
Voice
Conferencing SIP trunking
--------------------------------------------------------------------------------
* Twilio Verify logo
Verify
* Twilio Lookup logo
Lookup
* Serverless
* Twilio Video logo
Video
APPLICATIONS
--------------------------------------------------------------------------------
* Twilio Flex logo
Twilio Flex
* Twilio Engage logo
Twilio Segment ↗
* Twilio Marketing Campaigns logo
Marketing Campaigns
See all pricing
* Start for free
* Login
* Console
* Contact sales
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CUSTOMER AND PARTNER AGREEMENTS
Terms of Service
Acceptable Use Policy
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Data Protection Addendum (DPA)
Security Overview
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Twilio Segment Customer Data Platform Destination Integration and Listing Terms
AI/ML Terms
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Customer Name Changes and Assignments
Updates to Legal Terms and Conditions
PRIVACY
Data Privacy at Twilio
Privacy Notice
Binding Corporate Rules
Customer Proprietary Network Information (CPNI)
Sub-processors
GDPR
Customer Data Protection Addendum
Supplier Data Protection Addendum
Global Applicant Privacy Notice
MOBILE APPLICATION TERMS
Twilio Frontline End User App Terms
Twilio Authy App Terms
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Submit a request or subpoena
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Acknowledgement and Waiver
LEGAL NOTICES FOR TWILIO'S WEB SITE
Impressum (Germany)
ITALY ALIAS DATABASE CODE OF CONDUCT
Code of Conduct (Italy)
TWILIO PRIVACY NOTICE
Effective December 19, 2024 Last Updated: November 12, 2024 (View the prior
version of our privacy notice here)
INTRODUCTION
The Privacy program of Twilio Inc. and its group companies (‘Twilio’, ‘we’ or
‘our’) is built on our Binding Corporate Rules ('BCRs'), which serve as our code
of conduct that governs our global processing of personal data.
In order to provide products and services to our customers and conduct our
day-to-day business operations, including the operation of our websites, we
collect, use and share, or otherwise process personal data about our customers,
our customers’ authorized users ('end users') and their customers, our website
visitors and business contacts.
Personal data is any information that directly identifies you, such as your name
and email address, or that indirectly identifies you, for example a phone number
or device identifier.
The personal data we may collect and process about you varies depending on our
relationship with you. We may have a direct relationship with you because you
have set up an account or consented to receive marketing communications from us,
or we may have an indirect relationship with you via your relationship with one
of our customers; for example you may be their employee or their customer.
We take privacy, data protection and our legal obligations very seriously. We
are committed to being transparent with you about how we use personal data. This
Privacy Notice aims to describe our privacy practices in a clear, accessible and
easy to understand way and to let you know how you can exercise your rights in
relation to your data.
This Privacy Notice applies where Twilio processes personal data as a data
controller, in connection with the products and services we provide to our
customers (“Services”) and the operation of our business, including our
websites. As a data controller, we determine the purpose (why) and means (how)
of personal data processing and are ultimately responsible for the correct
handling of your data, in accordance with applicable law.
This Notice does not apply to the Personal Data we process in relation to job
applicants. This is covered by our Global Applicant Privacy Notice.
We also process personal data for most of our Services as a data processor. As a
data processor, we process personal data related to our customers' employees,
end users and customers on behalf of our customers to provide Services to them
in accordance with their instructions. These instructions are set out in our
customer agreements, Data Protection Addendum, service specific terms or through
a customer's use or configuration of a product feature. You should contact
these organizations directly for information about how they process your
personal data as a data controller and to exercise your rights in relation to
that data.
CONTENTS OF OUR PRIVACY NOTICE
Personal Data We Process
How We Process Personal Data
How We Disclose Personal Data
International Data Transfers
How We Secure Personal Data
How Long We Retain Personal Data
Your Rights and Choices About Your Data
How To Exercise Your Rights and Choices
How We Use Cookies and Other Tracking Technologies
Children
Automated Decision-Making
How to Contact Us
Changes to Our Privacy Notice
Twilio Product Privacy
PERSONAL DATA WE PROCESS
The personal data we collect about you depends on your relationship with us and
the purposes for which we process that personal data. The following describes
the types of personal data that we collected and disclosed for a business
purpose in the preceding 12 months.
Personal Data You Share With Us Directly
Contact Information - When you sign up for a Twilio, Sendgrid or Segment account
and use any of our products and services, request product information, ask for a
call from our sales team, or participate in events, we ask you to provide us
with your name, company name, business address, phone number, email address and
other contact information. We also ask you to create a password and name your
account (or accounts, if you have more than one).
Customer Account Data - We process certain personal data to manage our
relationship with you and administer you or your company’s account. This
includes purchase history, names or contact information of individuals
authorized to manage the Twilio account on behalf of our customer to set up,
access and manage billing. We also collect personal data required to administer
use of your account and the Services, and information to allow us to verify your
identity for Know Your Customer or other identity verification purposes.
Customer Content - We receive and store the content of communications received
from you or our customers and other personal data uploaded to the Services or
generated for our customers’ use as part of the Services, which we may be
authorized by you or our customer to use, where necessary for specific
legitimate business purposes and in accordance with applicable law.
Marketing and Contact Preferences - We use information about how you would like
to be contacted and choices you have made to send you marketing communications.
Payment Information - In connection with products and services you pay for, we
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 Services. Our payment processor will share your billing address with Twilio
for this purpose.
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
or your company’s intended use of the product to determine eligibility for
these products.
Professional Information - The information we process about you with respect to
your employment or profession, including company, job title, email address,
phone number and online business networking profile.
Subscriber Records - For some of our communications products, we may also obtain
proof of identity from you or our customer 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 our customer's end
user.
Support and Feedback - When you interact with us on our websites (including via
our Help Center Assistant), through our AI chatbot, over the phone or via email,
we process the phone number or email address that you use, the content of your
interaction and the feedback you provide about our services. You may also
provide us with feedback about our Services in surveys and questionnaires. We
will let you know when a call may be recorded, in accordance with applicable
law.
Personal Data We Generate or Collect Automatically
Communications Usage Data - When you or our customers use Twilio communications
products, we collect electronic communications metadata, such as phone numbers
and routing information, the source and destination of a communication, location
of the device generated in the context of delivering the communication, date,
time, duration and type of communication, status of the message, error data and
traffic records.
Device Information and IP Addresses - When you use our account portal, we
collect your IP address and device information through tracking technologies
like cookies, web beacons, pixels, and similar technologies. We also collect IP
addresses when you make requests to our APIs and in our server logs.
Additionally, we 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 when you use our account portal. We do not
collect precise geolocation information.
Online Activity Information - When you visit Twilio websites, including our web
forms, we use tracking technologies such as cookies, web beacons, and pixels to
collect the following data: your device and browser, time zone setting, web
pages visited, products you view or search for, page response times, download
errors, length of visits to certain pages, page interaction information, IP
address.
Security Identifiers or SIDs - When you sign up for an account with Twilio,
we’ll automatically assign you and each of your accounts a unique security ID
and generate an API token for each account. 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.
Customer Proprietary Network Information - When you use certain US voice-based
communications services, Twilio collects information associated with your
service usage. This includes information such as the number of phone calls, call
destinations, call locations, type, and service configuration, and is known as
Customer Proprietary Network Information (CPNI). CPNI does not include
information such as your name, address, phone number, or the content of phone
calls. We use CPNI to market Twilio-related products or services to which you
are not already subscribed unless you have exercised your right to opt out. For
information about your CPNI choices, see the section “Your Rights and Choices
About Your Data” below.
Personal Data Collected From Other Sources
Add-On Service Data - In the event you purchase our services through one of
our Add-On Partners, they may share your personal data with us to fulfill their
contractual obligations. Add-On Partners may share your personal data in the
form of leads when you download Twilio content on the Add-On Partner’s website
or you participate in events and webinars of which Twilio is a sponsor.
Professional Data - We collect certain personal data such as employment or
professional information from sources other than you. We may combine this data
with other personal data that you share with us.
Publicly-Available Sources - 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, such as your
industry, the size of your company, and your company’s website URL.
Social Media Data - Social media service providers such as Google, LinkedIn, and
Meta may provide us with information about you, in accordance with your privacy
settings on those sites.
Telecommunication Data - We receive communication-related data from
telecommunications operators, aggregators and carriers that may include phone
type, carrier history, SIM status and history, city and/or country where phone
was first registered, contract and account type, IP address city and/or country
and a validation result of personal data provided by our customer and whether it
matches data held by the carrier.
HOW WE PROCESS PERSONAL DATA
The purposes for which we process personal depends on your relationship with us.
We only use personal data that is necessary to fulfill the specified purposes
listed below as applicable to you and in accordance with applicable data
protection law.
PURPOSE
PERSONAL DATA PROCESSED
LEGAL BASIS FOR PROCESSING
--------------------------------------------------------------------------------
Creating and managing accounts, including verification of the identity of our
customer’s end user for Know-Your-Customer (KYC) or identity verification
purposes.
Add-On Service Data
Contact Information
Customer Account Data
Online Activity Information
Payment Information
Professional Information
Subscriber Records
Legitimate Interest
Legal Obligation
--------------------------------------------------------------------------------
Carrying out Twilio’s core business operations, such as account administration,
accounting, auditing and compliance, business analytics, filing taxes, finance,
forecasting, consolidated management and reporting, product strategy and revenue
planning.
Add-On Service Data
Professional Information
Customer Account Data
Support and Feedback
Customer Content
Communications Usage Data
Payment Information
Publicly Available Sources
Social Media Data
Legitimate Interest
--------------------------------------------------------------------------------
Billing and relationship management.
Add-On Service Data
Contact Information
Communications Usage Data
Payment Information
Legitimate Interest
--------------------------------------------------------------------------------
Providing, optimizing and maintaining our services, platform, including
debugging and troubleshooting.
Add-On Service Data
Subscriber Records
Online Activity Information
Communications Usage Data
Customer Content
Device Information
Legitimate Interest
--------------------------------------------------------------------------------
Preventing, detecting and investigating security incidents and managing the
security of Twilio’s platform, services, websites and accounts.
Add-On Service Data
Communications Usage Data
Customer Content
Device Information
Online Activity Information
Payment Information
Subscriber Records
Telecommunication Data
Contact Information
Legitimate Interest
Legal Obligation
--------------------------------------------------------------------------------
Determining eligibility for certain products.
Add-On Service Data
Contact Information
Payment Information
Personalization Details
Subscriber Records
Legitimate Interest
--------------------------------------------------------------------------------
For routing and connectivity purposes to send messages on behalf of our
customers, including transmitting, distributing and exchanging communications
using phone numbers, either through the public switched telephone network or
other communications networks.
Add-On Service Data
Communications Usage Data
Legitimate Interest
--------------------------------------------------------------------------------
Providing customer support, including responding to your requests and
communicating with you about your account and use of the services, including
suspicious activity or security alerts.
Contact Information
Customer Content
Communications Usage Data
Professional Information
Support and Feedback
Other personal data provided by requestor
Legitimate interest
--------------------------------------------------------------------------------
Sending important notifications about our products and services.
Add-On Service Data
Contact Information
Customer Account Data
Legitimate Interest
--------------------------------------------------------------------------------
Complying with legal and regulatory obligations, telecommunication provider
requirements and communications industry codes of practice.
Subscriber Records
Customer Content
Communications Usage Data
Legal Obligation
Legitimate Interest
--------------------------------------------------------------------------------
Sending marketing communications in accordance with your marketing preferences.
Add-On Service Data
Contact Information
Marketing and Contact Preferences
Professional Data
Publicly Available Sources
Social Media Data
Legitimate Interest
Consent
--------------------------------------------------------------------------------
Analyzing your interest in our products and delivering marketing campaigns that
are relevant to you.
Add-On Service Data
Contact Information
Marketing and Contact Preferences
Professional Data
Publicly Available Sources
Social Media Data
Legitimate Interest
Consent
--------------------------------------------------------------------------------
Deploying cookies and other tracking technologies in accordance with your online
settings.
Add-On Service Data
Contact Information
Marketing and Contact Preferences
Professional Data
Social Media Data
Legitimate Interest
Consent
--------------------------------------------------------------------------------
Understanding how visitors navigate our websites, and tracking and optimizing
the performance of our advertising activities.
Device Information
Online Activity Information
Publicly Available Sources
Social Media Data
Legitimate Interest
--------------------------------------------------------------------------------
Understanding how customers are using our platform and improving the website
navigation experience.
Add-On Service Data
Contact Information
Marketing and Contact Preferences
Online Activity Information
Professional Data
Legitimate Interest
Consent
--------------------------------------------------------------------------------
Conducting questionnaires and surveys to improve our products and provide
training to our employees.
Add-On Service Data
Contact Information
Customer Account Data
Marketing and Contact Preferences
Personalization Details
Professional Data
Support and Feedback
Legitimate Interest
Consent
--------------------------------------------------------------------------------
Managing your participation in our events and webinars and granting you access
to whitepapers and on-demand resources.
Add-On Service Data
Contact Information
Customer Account Data
Marketing and Contact Preferences
Professional Data
Support and Feedback
Legitimate Interest
Consent
--------------------------------------------------------------------------------
--------------------------------------------------------------------------------
Collecting sales insights and performing lead scoring.
Contact Information
Professional Data
Publicly Available Sources
Social Media Data
Legitimate Interest
--------------------------------------------------------------------------------
Developing our business by updating, expanding, and analyzing our customer
relationship records.
Contact Information
Marketing and Contact Preferences
Payment Information
Professional Data
Publicly Available Sources
Social Media Data
Legitimate Interest
Consent
--------------------------------------------------------------------------------
Identifying potential job candidates.
Publicly Available Sources
Social Media Data
Legitimate Interest
--------------------------------------------------------------------------------
Developing or improving our products and services, including anonymizing,
de-identifying, pseudonymizing and aggregating personal data for this purpose.
Communications Usage Data
Customer Content
Personalization Details
Support and Feedback
Legitimate Interest
--------------------------------------------------------------------------------
As otherwise authorized by you or our customer in Service specific terms or
through your or our customer’s use and configuration of features in a product.
Data used will vary based on customer authorization
Legitimate Interest
--------------------------------------------------------------------------------
Protecting the health and safety of our employees, visitors and our properties.
Contact Information
Customer Account Data
Legal Obligation
--------------------------------------------------------------------------------
Protecting the rights and freedoms of individuals, meeting legal obligations,
including complying with valid court orders, disclosure requests, subpoenas, and
other appropriate legal mechanisms and complying with telecommunications
providers requirements and communications industry codes of conduct.
Add-On Service Data
Communications Usage Data
Customer Content
Device Information
Online Activity Information
Marketing and Contact Preferences
Payment Information
Subscriber Records
Telecommunication Data
Legal Obligation
Legitimate Interest
--------------------------------------------------------------------------------
HOW WE DISCLOSE PERSONAL DATA
We disclose personal data to third parties in limited circumstances in order to
provide the Services and to otherwise run our business. Below are the different
scenarios under which we may disclose your data to third parties.
Telecommunications Service Providers
Twilio’s communications products provide an easier way for developers to build
applications that make use of the publicly switched telephone network (PSTN) to
send communications. Therefore, we engage with a global network of
telecommunications operators, aggregators, carriers and other communication
service providers (collectively, “telecommunications service providers”) as
necessary to route and connect those communications from the sender to the
intended recipient. How telecommunications service providers handle this data is
generally determined by their own policies and local regulations.
Where telecommunications service providers transmit the content of a
communication, they function neither as data controllers nor data processors,
instead they act simply as a conduit to transmit communication content. In the
event telecommunications services providers process any personal data for their
own purposes such as communications metadata required to transmit the message,
or for billing or fraud prevention purposes, they also act as data controllers.
We may have to share Subscriber Records with local government authorities or
local telecommunications carriers that provide connectivity services. However,
we don’t share subscriber records for purposes other than this, and we treat
these records with our highest confidentiality.
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, these are referred to as Over-the-Top (OTT) communications service
providers. If you or our customer chooses to use Twilio to send or receive
communications by way of these providers, Twilio will disclose communications
content and other data to these providers as necessary to route and connect
those communications from the sender to the intended recipient. How those OTT
communications service providers, as data controllers, handle this data is
determined by their own policies and local regulations.
Third Party Service Providers
Twilio engages third-party vendors and service providers to carry out certain
personal data processing functions on our behalf. These providers are limited to
only accessing or using personal data to provide services to us and must provide
reasonable assurances they will appropriately safeguard the data.
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 disclose your information to 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 disclosed to an
Add-on partner, then you should not use the Add-on.
Twilio Group Members
We may disclose your personal data among Twilio Group Members. Twilio Group
Members will only use the information as described in this Privacy Notice.
Twilio Group Members are listed in Appendix 1 in our Binding Corporate Rules.
Compliance with Legal Obligations
We may disclose your personal data to a third party if:
* 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);
* to enforce our agreements and policies;
* to protect the security or integrity of our services and products;
* to protect ourselves, our other customers, or the public from harm or illegal
activities; or
* 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 about you, we will
notify you of the disclosure requirement to the extent legally permitted and
where Twilio determines such disclosure will not interfere with an ongoing
investigation. Further, we object to information requests we do not believe were
issued properly.
Business Transfers
In connection with a corporate sale, merger, reorganization, dissolution or
similar event, personal data about you may be part of the assets transferred or
disclosed in connection with the due diligence for any such transaction. If
required by law, we will notify you prior to such a transfer and provide you
with information about any choices you may have with respect to your personal
data.
Aggregated, Anonymized or De-identified Data
Aggregated, anonymized and de-identified data may be derived by Twilio from your
personal data but is generally not considered personal data under data
protection law as this data does not directly or indirectly reveal your
identity. We may use and disclose de-identified, anonymized or aggregated data
to third parties. We do not disaggregate or reidentify de-identified data.
INTERNATIONAL DATA TRANSFERS
As a global organization, we may need to transfer your personal data to Twilio
affiliates, contractors, service providers and third parties in various
countries and jurisdictions around the world. When we transfer your personal
data, 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, your
personal data 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.
Safeguards for Data Transfers
Twilio employs appropriate safeguards for cross-border transfers of personal
data, as required by applicable local law.
EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S.
DPF and Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF“)
As set forth by the U.S. Department of Commerce Twilio is officially certified
under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and Swiss-U.S. DPF
and relies on these certifications as its primary transfer mechanisms for
transfers of personal data from the EU and Switzerland to the U.S. 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 DPF. To
learn more about the DPF Program, and to view our certifications, please visit
the DPF website.
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 as a data controller. 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 Policy here.
Where neither the EU-U.S. DPF, the UK extension to the EU-U.S. DPF, Swiss-EU DPF
nor Twilio's BCRs apply, 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 UK’s International Data Transfer Agreement.
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.
HOW WE SECURE PERSONAL DATA
To protect personal data from loss, or unauthorized use, access or disclosure,
Twilio uses reasonable and appropriate security measures designed 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. All systems used to support our business are
governed by Twilio’s Information Security Policy and Standards which are built
on industry standards and best practices such as the ISO 27001 and NIST
standards. More information about our security measures can be found in our
Security Overview.
HOW LONG WE RETAIN PERSONAL DATA
We endeavor not to retain personal data in a form which permits identification
of individuals for longer than is necessary for the purposes for which that data
is processed. We retain personal data in accordance with Twilio's record
retention policies and guidelines as revised and updated from time to time.
Twilio will store your Customer Account Data as long as needed to provide you or
our customer with the Services and to operate our business. If you ask Twilio to
delete specific personal data from your Customer Account Data (see ‘Your Rights
and Choices About Your 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.
YOUR RIGHTS AND CHOICES ABOUT YOUR DATA
Depending on the data protection laws applicable to you, you may have the
following rights in relation to your personal data that we process as a data
controller:
* 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;
* that we delete the personal data we have about you;
* that we restrict processing of personal data about you;
* that we provide you with your personal data in a structured, commonly used
format and to transmit that information to another controller, and where
feasible, transmit the information directly;
* that we provide you with the right to object to the processing of personal
data, including profiling;
* that we provide you with a free, easy mechanism to object to use of your
personal information for direct marketing purposes;
* that you not be subject to a decision based solely on automated processing,
including profiling, that produces legal effects or similarly affects your
individual rights;
* to withdraw your consent; and
* to complain to a competent supervisory authority and/or to commence
proceedings in a court of competent jurisdiction.
Twilio will honor your rights subject to limitations in certain situations, such
as where Twilio can demonstrate that it has a legal requirement or legitimate
interest to process your data or can legitimately apply an exemption to the
exercise of a right under applicable law. More information about these rights
can be found in our Binding Corporate Rules Controller Policy Rule 10.
If you are a US resident interested in what personal data we have disclosed
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 disclose personal data as we
describe in the section "How We Disclose Personal Data" above. Also, as
described in the “How We Use Cookies & Other Tracking technologies” section
below, we process personal data to deliver ads targeted to your interests on
other companies’ websites and mobile apps. Some of these activities may be
considered “sharing” or “targeted advertising” under certain laws. You have the
right to opt out of the processing of your personal data for targeted
advertising, and can do so by adjusting your preferences using our Cookie
Preferences Tool located on the bottom right of the Twilio website you are
visiting. Any choices concerning cookies are browser and/or device specific. If
you clear your cookies from your browser on any of your devices, your choices
will need to be reset.
You also have the right to request the restriction of processing of your
sensitive personal information. Where applicable, the respective sensitive
personal information will be marked accordingly and may only be processed by us
for certain purposes. At the current time, however, we do not use or disclose
sensitive personal information for purposes other than those expressed in this
Privacy Notice or otherwise permitted by applicable law, and these uses cannot
be limited under California law.
You may have additional rights under our Binding Corporate Rules in the EU. For
example, where you believe your personal data has been transferred by an
EU-based Twilio company to our US headquarters and processed by the US company
in breach of the Binding Corporate Rules, you may have a right to:
* Lodge a complaint with the Twilio company that transferred your data outside
Europe;
* Lodge a complaint with the supervisory authority in the same country as the
Twilio company that transferred your data outside Europe; and
* Bring a court action against the Twilio company that transferred your data
outside Europe.
If Twilio processes your personal data as a data processor on behalf of a
customer, we will either direct you to contact our customer to exercise your
rights.
HOW TO EXERCISE YOUR RIGHTS AND CHOICES
The following sections provide information about how to exercise certain rights
in relation to your personal data. To exercise any other rights, please contact
us at privacy@twilio.com.
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 contacting 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. 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 Retain Personal Data” section above) until it’s no longer needed.
In some instances, we will need to verify your identity before honoring your
request. We will generally verify your identity by asking you to provide
personal data related to your recent interactions with us. Thereafter, we will
process your request and inform you of any decisions we have made about your
request. Additionally, you may exercise your privacy rights through an
authorized agent. If we receive your request from an authorized agent, we may
ask for evidence that you have provided such agent with a power of attorney or
that the agent otherwise has valid written authority to submit requests to
exercise rights on your behalf. If you are an authorized agent seeking to make a
request, please contact us at privacy@twilio.com.
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 Services.
Customer Proprietary Network Information (CPNI)
As an individual Twilio account holder or as an authorized representative of a
Twilio customer in the US, you have the right to restrict Twilio’s use of CPNI.
To opt-out of the use of CPNI data related to your Twilio account to market
other Twilio products and services based on your usage of our products, click
here. Please note that, if you have subscribed for the services on behalf of an
organization, the CPNI relates to the service usage by that organization and not
you individually. Opting-out of the use of CPNI for marketing will not
unsubscribe you from other types of marketing contacts from Twilio and will not
affect the status of the services you currently have with us. Your approval or
opt-out of the use of your CPNI outside of the services to which you are already
subscribed is valid until you affirmatively revoke or limit such approval.
Communication Preferences
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 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.
HOW WE USE COOKIES AND OTHER 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 send to you.
Cookies
A cookie is a 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.
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.
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.
Manage Your Cookie Preferences
Twilio uses a 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. Any choices concerning cookies are
browser and/or device specific. If you clear your cookies from your browser on
any of your devices, your choices will need to be reset.
Manage Cookies Using Your Browser
In addition to using our 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
cookies, click here.
Universal Opt-Out Mechanisms
Global Privacy Control (GPC) and Do Not Track (DNT) are tools 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. To set DNT, you can visit
the All About DNT page. Please note that this may impact the functionality of
our websites or your account.
Opt 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.
CHILDREN
Our products and services are not directed to or intended to be used by children
(under the age of 13 in the US and UK, or 16 in the EEA). We do not knowingly
permit children to sign up for a Twilio account. If we become aware that a child
has signed up for an account, we will take reasonable steps to deactivate the
account and remove their personal data from our records as quickly as possible.
If you believe an underage person has signed up for a Twilio account, please
contact us at privacy@twilio.com with the subject line “Children”.
AUTOMATED DECISION MAKING
Automated decision-making occurs when an electronic system uses personal data to
make a decision about you, without human involvement. Twilio uses automated
decision-making leveraging a variety of signals derived from records we collect
or obtain from third party vendors, to help monitor, identify, and suspend
accounts sending spam or engaging in other abusive or fraudulent activity. If
your account is suspended under these circumstances you will be notified of the
suspension and given an opportunity to request human review of the suspension
decision.
We may rely on other automated decision-making where:
* We have notified you of the decision and provided you with the opportunity to
request a human review of the decision
* It is necessary to perform a contract with you and appropriate measures are
in place to safeguard your rights
* We have your consent and we have put in place appropriate measures to
safeguard your rights
HOW TO CONTACT US
If you have any questions, concerns or complaints about this Privacy Notice or
our data protection practices, please do not hesitate to contact our Data
Protection Officer by emailing us at privacy@twilio.com or by writing to us at
any of the following addresses:
Worldwide Headquarters
Twilio Inc.
101 Spear Street, 5th Floor
San Francisco CA 94105
EEA Headquarters
Twilio Ireland Limited
70 Sir John Rogerson's Quay
Dublin 2
D02 R296, Ireland
Complaints
We will endeavor to resolve questions, concerns or complaints you raise with us
in accordance with our Complaints Handling Procedure. In the unlikely event that
we are unable to resolve your concern, you can find information about your
options to seek assistance through independent dispute resolution mechanisms or
complaints to your local data protection authority here.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and
the Swiss-U.S. DPF, Twilio commits to refer unresolved complaints concerning our
handling of personal data received in reliance on the EU-U.S. DPF and the UK
Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative
dispute resolution provider based in the United States, the European Union, the
United Kingdom, and/or Switzerland. If you do not receive timely acknowledgment
of your DPF Principles-related complaint from us, or if we have not addressed
your DPF Principles-related complaint to your satisfaction, please
visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to
file a complaint. The services of JAMS are provided at no cost to you.
You have the possibility, under certain conditions, to invoke binding
arbitration for complaints regarding DPF compliance that are not resolved by any
of the other DPF mechanisms. You can find more information in the
DPF ANNEX-I-introduction.
If your question or complaint relates to personal data we process as a data
processor on behalf of a customer, we will direct you to contact our customer to
address your question or complaint.
CHANGES TO OUR PRIVACY NOTICE
We will periodically review this Privacy Notice and may change it to address
legal, technical or business development requirements. When we change this
Privacy Notice, the most current version will be available at
https://www/twilio.com/legal/privacy with the date indicating when it was last
updated. If we make material changes that affect your rights, we will provide
you with advance notice, such as by posting a message in the Twilio console or
sending an email to the address we have on file for you. We will comply with
applicable law with respect to any changes we make to this Notice. We will also
seek your consent to material changes, where required by applicable law.
TWILIO PRODUCT PRIVACY
Twilio offers a range of industry-leading communications and customer data
platform services to our customers. Depending on the Service, Twilio may be a
data controller and data processor of personal data used to provide the
Services.
Twilio processes personal data (Communications Usage Data and Customer Content)
for most of our Services as a data processor acting on the instruction of our
customer and in accordance with the terms of our agreement with a customer, our
Data Protection Addendum, and service specific terms. Our services provide
customers with ways to control, access and secure their data.
We also offer customers the ability to store, delete, access, or exercise other
choices about their personal data. The ability to make these choices depends on
the Twilio product or service being used and how it is being used by a customer.
Customers are referred to our API docs for each of our products and services,
along with SendGrid’s documentation and Segment’s documentation to find more
detailed information about managing personal data collected and stored in
connection with their use of our products and services. We also provide an
overview of our retention and deletion practices, including how to delete data
you control in our support documentation. We provide information about the
security measures we use to protect our customer’s data 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.
For some of the Services we also act as a data controller where disclosed and
agreed to by our customer in the agreement, Data Protection Addendum, product
specific terms or via the customers’ use and configuration of a product or
feature.As a data controller, Twilio is responsible for the processing of the
personal data.
For more detail on our Services, please find information below or by visiting
our products page.
AUTHY
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.
Due to the nature of the Authy service, Twilio collects the following additional
personal data elements to other Twilio services:
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 also collect your email address, and we use it for
identity verification and account recovery purposes.
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 as another piece of information we can use to verify
your identity if we suspect your account may be compromised.
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.
SENDGRID SERVICES
The SendGrid services also collect 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 “How We Use Cookies and Other Tracking
Technologies” above.
VOICE INTELLIGENCE
Voice Intelligence incorporates artificial intelligence and machine learning to
transcribe and analyze voice calls into a structured format that allows our
customers to drive their business processes. To translate voice calls into
structured content, Twilio processes certain data as a controller, including
personal data contained in voice calls disclosed to us by our customer through
their use of the service.
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