Twilio Sub-Processors
Last Updated: October 31, 2024
Third Party Sub-Processors
Twilio uses the third party companies below (each, a “sub-processor”) to process personal data (i) on behalf of Twilio customers; (ii) in accordance with customer instructions as communicated by Twilio; and (iii) in strict accordance with the terms of a written contract between Twilio and the sub-processor.
Twilio imposes obligations on its sub-processors to implement appropriate technical and organizational measures ensuring that the sub-processing of personal data is protected to the standards required by applicable data protection laws. Further information relating to sub-processor security measures can be found via the external links below.
Where the engagement of a sub-processor requires the cross-border transfer of personal data, Twilio has performed Transfer Impact Assessments for such data transfer.
Twilio maintains an up-to-date list of the names and locations of all sub-processors below. Twilio customers may subscribe to notifications of sub-processor changes to receive updates.
Duration of processing: For each sub-processor below, processing of personal data will be for the duration that the customer uses and continues to use the applicable service(s), and for the retention periods as set out in customer’s agreement with Twilio.
Please note that telecommunications providers used by Twilio are not processors of Twilio or sub-processors of our customers. Additional information about this position can be found here.
Sub-Processor
Applicable Service(s)
Subject matter
Nature and purpose of processing
Location(s) of processing
External links for additional information relating to security
Adaptive Mobile
Programmable Messaging
Personal data contained in communications sent through the Twilio Services
Prevention of illegal or unwanted communications over Twilio’s messaging services
USA
AWS
All services
Personal data contained in communications sent through or uploaded to the services.
Infrastructure Provider providing hosting services and storage.
AWS
Programmable Voice
Personal data contained in voice communications.
Text to speech functionality for customers using Amazon Polly, Amazon Comprehend, and Amazon Transcribe.
AWS
Programmable Video
Personal data contained in streamed videos.
Streaming and interactive video.
AWS
Marketing Campaigns (SendGrid)
Personal data contained in email communications.
Automation and storage services for marketing campaigns.
AWS
Email (SendGrid)
Personal data contained in email communications.
Routing and transmission of emails.
AWS
CDP (Segment)
Personal data contained in communications sent through the Segment Services
Infrastructure Provider providing hosting services and storage.
USA or EU (Dublin) as selected by customers
Confluent
Twilio Flex
Personal data contained in communications sent through Twilio Flex.
Infrastructure management
USA
Datadog
Segment
System and event logs only
Operational monitoring
DVELP/Sabio
Twilio Flex
Personal data contained in voice communications.
Connectivity services to customer’s Google CCAI instance.
UK (provision of the services), Belgium, Finland, Germany, Netherlands, and Poland (data persistence/backups)
Frame.AI
Twilio Flex
Personal data contained in voice transcriptions and conversations messages
AI/ML features as enabled by the customer for the purpose of calculation of scores and data analysis
USA
GoodData Corporation
Twilio Flex
Personal data contained in communications sent through Twilio Flex.
Data analytics functionality for customers who have enabled the feature in Twilio Flex.
Segment/Twilio Engage
Personal data contained in communications sent through the Segment Services
Data storage compute and queries
USA or EU (Zurich & London) as selected by Customers
Programmable Voice;
Twilio Flex
Personal data contained in voice communications.
Speech recognition functionality for customers who have enabled the feature on supported products.
USA*
Google RCS
Verify
Phone numbers and message content
Message delivery for outbound/inbound Twilio Verify services.
USA, South America: Chile, Europe: Ireland, Netherlands, Denmark, Finland, Belgium, Asia: Taiwan, Japan, Singapore
Meta
Whatsapp Channel
Phone numbers and message content
Outbound/inbound message delivery
OpenAI
Flex Agent Copilot
Personal data contained in customer defined workflows
Customer.AI features as enabled by customer for the purpose of summarization, sentiment analysis and disposition
OpenAI
Segment Generative Audiences
Personal data contained in communications Sent through Segment Services
Customer.AI features as enabled by customer for the purpose of generating audiences
OpenAI
Voice Intelligence
Personal data contained in voice communications
Customer.AI features as enabled by customer for the purpose of summarization and sentiment analysis
Snowflake
Marketing Campaigns (SendGrid)
Personal data contained in email communications.
Automation and storage services for Marketing Campaigns.
Temporal Cloud
Twilio Flex
Personal data contained in customer defined workflows
Scheduling and execution of the customer defined workflows.
USA
VoiceBase
Programmable Voice;
Twilio Flex
Personal data contained in voice communications.
Transcription services for customers who have enabled transcriptions on supported products.
* If using Regional Twilio for supported products, Customer Content is stored and processed in the region selected (Ireland or Australia). Exceptions will occur as necessary to investigate issues of fraud and abuse. At this time, all other data relating to your account and use of the Twilio Services will continue to be processed in the United States to allow Twilio to continue to provide and improve our Services to you.
Sub-Processor
Applicable Service(s)
Subject matter
Nature and purpose of processing
Location(s) of processing
External links for additional information relating to security
DataBank
Sendgrid Services
Personal data contained in communications sent through or uploaded to the services.
Infrastructure Provider providing hosting services and storage.
North America
Lumen
Sendgrid Services
Personal data contained in communications sent through or uploaded to the services.
Infrastructure Provider providing hosting services and storage.
North America
Digital Realty
Sendgrid Services
Personal data contained in communications sent through or uploaded to the services.
Infrastructure Provider providing hosting services and storage.
North America
Twilio Inc.
All Services
If Twilio Inc. is not the Twilio party to the agreement, then Twilio Inc. is acting as a sub-processor for that Twilio party. (For example. If you are contracting with Twilio Ireland Ltd, then Twilio Inc. is acting as a sub-processor for the provision of the services.)
Provision of the Twilio Services
USA*
* If using Regional Twilio for supported products, Customer Content is stored and processed in the region selected (Ireland or Australia). Exceptions will occur as necessary to investigate issues of fraud and abuse. At this time, all other data relating to your account and use of the Twilio Services will continue to be processed in the United States to allow Twilio to continue to provide and improve our Services to you.