In order to receive text messages from ${programName}, Twilio, a
third party communications provider, is processing communications
metadata such as telephone numbers in order to provide you with text
messages. This Notice explains how Twilio processes (e.g. collects,
uses, stores, and shares) your personal data. Twilio will process any
personal data about you in accordance with this Notice and with
applicable law.
1. WHO IS TWILIO?
The company responsible for processing your personal data is:
Twilio Inc.
375 Beale Street Suite 300
San Francisco CA
94105 USA
You can always contact Twilio or the Twilio Data Privacy Officer at
privacy@twilio.com with questions or concerns about how Twilio process
your personal data.
2. HOW DOES TWILIO COLLECT PERSONAL DATA ABOUT YOU?
Twilio gets your personal data from you directly as part of the SMS
services offered with ${programName}.
3. WHY DOES TWILIO PROCESS YOUR PERSONAL DATA?
Twilio processes personal data about you for the purpose of
providing SMS services, as you have signed up to receive text messages
from ${programName}.
You are not required to provide Twilio with your personal data. If
you do not want Twilio to use your personal data, you will not be able
to receive text messages from ${programName}.
4. WHAT PERSONAL DATA DOES TWILIO PROCESS ABOUT YOU?
For the purposes described above in Section 3, Twilio may process
the following types of personal data:
- Communications metadata processed by Twilio for the purposes
of transmitting, distributing or exchanging customer content;
including data used to trace and identify the source and destination
of a communication, such as individual data subjects’ telephone
numbers, data on the location of the device generated in the context
of providing the Twilio Services, and the date, time, duration and
the type of communication.
5. WHY IS TWILIO ALLOWED BY LAW TO PROCESS YOUR PERSONAL DATA?
Twilio’s processing of your personal data requires a legal basis. By
law, Twilio is allowed to process your personal data described above
in Section 1, as the processing is necessary for Twilio’s legitimate
interests. The legitimate interests are the provision of the services,
billing, reconciling invoices with telecommunications carriers, and in
the context of troubleshooting and detecting problems with the network.
6. HOW DOES TWILIO SHARE YOUR PERSONAL DATA?
Twilio may share your personal data under the following scenarios:
- Telephony operators as necessary for proper routing and
connectivity. 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.
- Third-party service providers or consultants.
Twilio engages certain third-party service providers to carry out
certain data processing functions on their behalf. These providers
are limited to only accessing or using this data to provide services
to them and must provide reasonable assurances they will
appropriately safeguard the data. In addition, Twilio uses Sift
Science as a service provider to help them detect potentially
fraudulent or malicious accounts or customer activity. Sift Science
uses machine learning as part of its service and certain customer
account data Twilio shares with them may be used in building machine
learning models to help detect potential fraud or malicious activity
that not only benefits Twilio, but other Sift Science customers as
well. Sift Science provides additional information about their data
practices in their privacy notice.
Twilio does not share end user personal data with Sift Science.
- Sub-processors. Twilio may share customer content with
sub-processors who assist in providing the Twilio services, like
their infrastructure provider, or as necessary to provide optional
functionality like transcriptions. An up-to-date list of their
sub-processors is located here.
- Compliance with Legal Obligations. Twilio may disclose your
personal information to a third party if (i) they reasonably believe
that disclosure is compelled by applicable law, regulation, legal
process or a government request (including to meet national security
or law enforcement requirements), (ii) to enforce their agreements
and policies, (iii) to protect the security or integrity of their
services and products, (iv) to protect themselves, their other
customers, or the public from harm or illegal activities, or (v) to
respond to an emergency which they believe in good faith requires
them to disclose data to assist in preventing a death or serious
bodily injury. If Twilio is required by law to disclose any of your
personal information, they will notify you of the disclosure
requirement, unless prohibited by law. Further, they object to
requests they do not believe were issued properly.
- Affiliates. Twilio may share your personal information or your
end users’ personal information with an affiliate company, like a
subsidiary of Twilio Inc. They and their subsidiaries will only use
the information as described in this Notice.
- Aggregated or
de-identified data. Twilio might also share data with third parties
if the data cannot be used to identify you.
7. WHEN DOES TWILIO TRANSFER YOUR PERSONAL DATA OUTSIDE THE EU/EAA?
For the purposes described above in Section 3, Twilio transfers your
personal data to countries outside the European Economic Area (EEA).
The level of data protection in certain countries outside the EEA does
not conform to the level of data protection for personal data
currently applied and enforced within the EEA.
Twilio therefore use the following safeguards, as required by law,
to protect your personal data in case of such transfers:
8. HOW LONG WILL TWILIO KEEP YOUR PERSONAL DATA?
Twilio will keep your personal data for the following period of time:
- For as long as needed to provide you with the services
requested by you
9. WHAT ARE YOUR RIGHTS?
In general, you have the following rights:
- You can get an overview of what personal data Twilio has about
you
- You can get a copy of your personal data in a structured,
commonly used and machine-readable format
- You can get an
update or correction to your personal data
- You can have
your personal data deleted or destroyed
- You can have Twilio
stop or limit processing of your personal data
- If you have
given consent for them to process your personal data (see Section
5), you can withdraw your consent at any time. Your withdrawal will
not affect the lawfulness of the processing carried out before you
withdrew your consent
- You can submit a complaint about how
Twilio processes your personal data to a Data Protection
Authority.
Under applicable law, there may be limits on these rights depending
on the specific circumstances of the processing activity. Contact
Twilio as described in Section 1 with questions or requests relating
to these rights.
